IN THE MUSCOGEE (CREEK) NATION SUPREME COURT

IN THE MUSCOGEE (CREEK) NATION SUPREME COURT

CITIZENSHIP BD. OF THE

MUSCOGEE (CREEK) NATION

Appellant

v.

RHONDA K. GRAYSON and

JEFFREY D. KENNEDY

Respondents

MAR 1 7 2026

Af

Case No.: SC 2023-10

(District Court Case No: CV-2020-34)

MOTION FOR LEAVE TO FILE AMICI CURIAE BRIEF BY THE NAACP LEGAL

DEFENSE & EDUCATIONAL FUND, INC. AND LAWYERS’ COMMITTEE FOR CIVIL

RIGHTS UNDER LAW

Jennifer N. Lamirand, MCN Bar No. 1068

BRESSLER, AMERY & ROSS, P.C.

210 Park Avenue, Suite 2750

Oklahoma City, Oklahoma 73102

T: 405.901.5982

I. Sara Rohani

NAACP LEGAL DEFENSE &

EDUCATIONAL FUND, INC.

700 14th Street NW, Suite 600

Washington, DC 20005

T: 202-365-2154

Stuart Naifeh

NAACP LEGAL DEFENSE &

EDUCATIONAL FUND, INC.

40 Rector Street, 5th Floor

New York, New York 10006

T: 212.965.2200

Edward G. Caspar

Ryan Snow

LAWYERS’ COMMITTEE FOR CIVIL

RIGHTS UNDER LAW

1500 K Street NW, Suite 900

Washington, DC 20005

T: 202.662.8600

The proposed amici curiae, NAACP Legal Defense & Educational Fund, Inc. (“LDF”) and

the Lawyers’ Committee for Civil Rights Under Law (“Lawyers’ Committee”), respectfully move

this Court for leave to participate as amici curiae and to file the accompanying amici curiae brief

in the above captioned matter in support of Respondents’ Motion for Temporary Restraining Order

and Preliminary Injunction and Respondents’ Third Motion for Contempt, for Court Enforcement

of Order and Judgment, and for Order to Show Cause.

As the proposed amici curiae will set forth in their brief, if granted leave to submit, we

respectfully urge this Court to grant Respondents’ request for a temporary restraining order and

preliminary injunction and their renewed motion to enforce this Court’s July 23, 2025 Order and

Opinion. This relief is needed to prevent the disenfranchisement of as many as 4,000 Creek

Freedmen with pending citizenship applications currently held by the Citizenship Office pursuant

to Muscogee (Creek) Nation Executive Order No. 25-05 (“Executive Order No. 25-05”’). Pursuant

to this Court’s unambiguous and unanimous July 23 Order, Respondents and all Creek Freedmen

are equal citizens of the Muscogee (Creek) Nation (“MCN”) and must be allowed to exercise their

fundamental right to vote in the upcoming May 30 MCN election. Appellant’s delay in the

processing of these applications is legally indefensible and risks invalidating the results of the

election itself. As this Court has recognized, the descendants of the Creek Freedmen were

unequivocally granted MCN citizenship under Article 2 of the post-Civil War Treaty of 1866. This

citizenship guarantees these individuals the right to vote, a right that is both fundamental and

“preservative of all [other] rights.” Yick Wo v. Hopkins, 118 U.S. 356, 370 (1886). Abridging this

fundamental right is a grave violation of the civil rights of the Respondents and the other

descendants of the Creek Freedmen.

Executive Order No. 25-05 flouts this Court’s July 23 Order by directing the Citizenship

Office to cease processing citizenship applications of the Creek Freedmen—while maintaining the

“status quo” in continuing to process all other applications—effectively denying Respondents and

other Creek Freedmen equal protection of MCN laws and the rights and privileges guaranteed by

the 1866 Treaty and violating the separation of powers principles fundamental to the MCN

Constitution. This Court has already ruled that Respondents and all other Creek Freedmen are full

and equal MCN citizens. Allowing the election to proceed without their participation would render

it illegitimate and invite federal scrutiny that could lead to the invalidation of election results. See

Seminole Nation of Oklahoma v. Norton, 223 F. Supp. 2d 122, 147-148 (D.D.C. 2002) (holding

that the Department of the Interior did not act “arbitrarily, capriciously, or contrary to law” in

refusing to recognize Seminole Nation election results that excluded the votes of the Freedmen).

Finally, Appellant’s adherence to Executive Order No. 25-05 in the face of this Court’s

clear contrary command is blatantly violative of the constitutionally guaranteed separation of

powers. Allowing Executive Order No. 25-05 to stand undermines the rule of law as a whole and

invites further abuses of executive power, which will work to the detriment of all MCN citizens.

We urge this Court to order the aforementioned relief to prevent the further disenfranchisement of

Respondents and other Creek Freedmen.

As is required by this Court’s Rules of Appellate Procedure, amici state their specific

interests in this matter with more detail as follows. See MCN Rules of Appellate Procedure (2023),

Rule 7(B) (hereinafter “MCN RAP”). LDF is a nonprofit, non-partisan law organization

established under the laws of New York to assist Black people and other people of color in the

full, fair, and free exercise of their constitutional and statutory rights. Founded in 1940 under the

leadership of Thurgood Marshall, LDF focuses on eliminating racial discrimination in economic

justice, education, criminal justice, and political participation. LDF has worked for 80 years to

combat threats to Black people’s voting rights and political representation. Beginning with Smith

v. Allwright, LDF’s Supreme Court case challenging the use of whites-only primary elections in

1944, LDF has fought to overcome barriers to the full, equal, and active participation of Black

voters. Smith v. Allwright, 321 U.S. 629 (1944). Since its inception, LDF has been involved in a

wealth of minority rights cases as counsel or as amicus curiae before state and federal courts. See,

e.g., Robinson v. Callais, 144 8. Ct. 1171 (2024) (mem.); Alexander v. S. Carolina State Conf. of

the NAACP, 602 U.S. 1 (2024); Allen v. Milligan, 599 U.S. 1 (2023); Shelby Cnty. v. Holder, 570

U.S. 529 (2013); Nw. Austin Mun. Util. Dist. No. One v. Holder, 557 U.S. 193 (2009); Easley v.

Cromartie, 532 U.S. 234 (2001); Abrams v. Johnson, 521 U.S. 74 (1997); Bush v. Vera, 517 US.

952 (1996); Shaw v. Hunt, 517 U.S. 899 (1996); Houston Lawyers’ Ass’n v. Att’y Gen. of Tex.,

501 U.S. 419 (1991); Chisom v. Roemer, 501 U.S. 380 (1991); Thornburg v. Gingles, 478 U.S. 30

(1986); NAACP v. Hampton Cnty. Election Com’n, 470 U.S. 166 (1985); City of Mobile v. Bolden,

446 U.S. 55 (1980); E. Carroll Par. Sch. Bd. v. Marshall, 424 U.S. 636 (1976); Turner v. Fouche,

396 U.S. 346 (1970); Allen v. State Bd. of Elections, 393 U.S. 544 (1969); Anderson v. Martin,

375 U.S. 399 (1964); Terry v. Adams, 345 U.S. 461 (1953). LDF is committed to ensuring the fair

and equal participation of all historically disenfranchised voters — across America and the tribal

nations. LDF recently participated as amicus curiae in a case that challenged the unlawful dilution

of Native American voting rights in federal elections. See, e.g., Turtle Mountain Band of Chippewa

Indians et al. v. Howe, 145 S. Ct. 2876 (2025) (granting stay of decision reversing district court’s

finding of vote dilution of Native American voters).

The Lawyers’ Committee is a nonpartisan, nonprofit civil rights organization, formed at

the request of President John F. Kennedy in 1963, that uses legal advocacy to achieve racial justice.

For more than 60 years, the Lawyers’ Committee has advocated inside and outside the courts to

ensure that Black people and other people of color have the voice, opportunity, and power to make

the promises of democracy real. This includes being able to enjoy unencumbered access to the

ballot and the ability to elect candidates of their choice. The Lawyers’ Committee litigates voting

rights cases across the country, and has represented parties to many seminal voting rights cases

including Shelby County v. Holder, 570 U.S. 529 (2013); Arizona v. Inter Tribal Council of

Arizona, Inc., 570 U.S. 1 (2013); Veasey v. Abbott, 830 F.3d 216 (Sth Cir. 2016); and League of

United Latin American Citizens v. Abbott, 809 F.Supp.3d 502 (W.D. TX. 2025). The Lawyers’

Committee has also represented tribal nations in challenging the unlawful dilution of their voting

power and is committed to ensuring all Native voters are able to exercise their fundamental right

to vote. See, e.g., Voting Rights Win in New Mexico: Navajo Community Gains Equal Opportunity

to Elect Preferred Candidates in Second San Juan County Commission District, LAWYERS’

COMMITTEE (Mar. 25, 2024), https://www.lawyerscommittee.org/voting-rights-win-in-newmexico-navajo-community-gains-equal-opportunity-to-elect-preferred-candidates-in-second-sanjuan-county-commission-district/. This case is of utmost importance to the Lawyers’ Committee

because it threatens to deprive Creek Freedmen citizens of the ability to vote in free and fair

elections which will determine their ability to participate as equal citizens in the MCN and because

this threatens to damage the legitimacy of democratic institutions in the MCN.

In summary, LDF and the Lawyers’ Committee have a significant interest in the

Respondents obtaining their requested relief from this Court so that they, along with the other

Creek Freedmen, may exercise their fundamental right to vote in accordance with the rights of

citizenship guaranteed to them in the Treaty of 1866. Respondents’ fight to secure their and the

other Creek Freedmen’s fundamental right to vote, pursuant to their legally guaranteed right to

MCN citizenship, is exactly the work that LDF and the Lawyers’ Committee have dedicated

themselves to for decades to ensure equal rights under the law.

LDF and the Lawyers’ Committee submit this timely motion in accordance with this

Court’s rules. Under the rules of this Court, “a person who is not a party to a case, but has some

interest in the outcome of an appellate case may, upon a timely motion and with permission of the

Appellate Court, submit an amicus curiae brief in support of one party to the action or to

supplement the arguments of a party.” MCN RAP at Rule 7(B). To file an amicus curiae brief, a

party must “file a motion to intervene within fifteen (15) days of the entry of the initial review

decision accepting the appeal.” /d. at 7(C). In the instant case, Respondents’ Motion for Temporary

Restraining Order and Preliminary Injunction and Respondents’ Third Motion for Contempt, for

Court Enforcement of Order and Judgment, and for Order to Show Cause, upon which our motion

to intervene as amici curiae is based, was filed on March 9, 2026. This motion for leave has been

filed with this Court on March 17, 2026, eight days from the filing of Respondents’ motion. As

such, LDF and the Lawyers’ Committee have submitted a timely motion to participate as amici

curiae in accordance with this Court’s rules.

For the reasons set forth herein, LDF and the Lawyers’ Committee respectfully request this

Court grant leave to file the amici curiae brief attached hereto as Exhibit 1 in the above captioned

matter. Additionally, if granted leave to file said brief, the LDF and the Lawyers’ Committee stand

ready, at the preference of the Court, to submit as an addendum to the brief all rules, regulations,

laws, and authorities cited in the brief unless already filed with the Court. However, such an

addendum would extend beyond the page limits for brief submissions within the Court’s rules.

Therefore, if the Court prefers to receive copies of all authorities cited in the brief, LDF and the

Lawyers’ Committee respectfully request leave to submit an addendum that exceeds the page

limits for submissions within the Court’s rules.

Respectfully Submitted,

Jennifer N. Lamirand, MCN Bar No. 1068

BRESSLER, AMERY & ROSS, P.C.

210 Park Avenue, Suite 2750, Oklahoma City,

Oklahoma 73102

T: 405-901-5982

jlamirand@bressler.com

ATTORNEYS FOR AMICI CURIAE NAACP

LEGAL DEFENSE AND EDUCATIONAL FUND,

INC. AND LAWYERS’ COMMITTEE FOR

CIVIL RIGHTS UNDER LAW

Stuart Naifeh

NAACP LEGAL DEFENSE & EDUCATIONAL

FUND, INC.

40 Rector Street, Sth Floor, New York, New York

10006

T: 212.965.2200

F: 212.226.7592

snaifeh@naacpldf.org

I. Sara Rohani

NAACP LEGAL DEFENSE & EDUCATIONAL

FUND, INC.

700 14th Street NW, Suite 600, Washington, DC

20005

T: 202.365.2154

srohani@naacpldf.org

Edward G. Caspar

Ryan Snow

LAWYERS’ COMMITTEE FOR CIVIL RIGHTS

UNDER LAW

1500 K Street NW, Suite 900, Washington, DC

20005

T: 202.662.8600

F: 202.783.0857

ecaspar@lawyerscommittee.org

rsnow@lawyerscommittee.org

CERTIFICATE OF SERVICE

I hereby certify that on the 17th day of March 2026, I caused the foregoing to be transmitted

to the following counsel of record via U.S. Mail, postage prepaid:

Rod W. Wiemer

114 North Grand

Okmulgee, OK 74447

Tulsa, OK 74120

rwattys@sbcglobal.net

Geri Wisner

Clinton A. Wilson

Jeremy Pittman

THE MUSCOGEE (CREEK) NATION

OFFICE OF THE ATTORNEY GENERAL

P.O Box 580

Okmulgee, OK 74447

gwisner(@mcnag.com

cwilson@mcnag.com

jpittman@mcnag.com

Damario Solomon-Simmons, MCN # 354

SOLOMONSIMMONSLAW, PLLC

601 S. Boulder Ave., Ste. 602

Tulsa, Oklahoma 74119

(918) 551-8999 — Phone/(918) 558-8039 — Facsimile

dss@solomonsimmons.com

Jana L. Knott, MCN #1320

BASS LAW

252 NW 70th St.

Oklahoma City, OK 73116

(405) 262-4040 — Phone/(405) 262-4058 — Facsimile

jana(@basslaw.net

M. David Riggs, MCN # 1239

RIGGS, ABNEY, NEAL, TURPEN ORBISON & LEWIS, P.C.

502 West 6th Street

Tulsa, Oklahoma 74119

(918) 587-3161 — Phone/(918) 587-9708 — Facsimile

driggs@rigesabney.com

Tag,

Jennifer N. Zamirand

EXHIBIT 1

IN THE MUSCOGEE (CREEK) NATION SUPREME COURT

CITIZENSHIP BD. OF THE

MUSCOGEE (CREEK) NATION

Appellant

Case No.: SC 2023-10

(District Court Case No: CV-2020-34)

Vv.

RHONDA K. GRAYSON and

JEFFREY D. KENNEDY

Nemo! Nee Nee Noe’ Nee” Nee” Nee” Ne” ee” ee” ee”

Respondents

BRIEF OF AMICI CURIAE NAACP LEGAL DEFENSE & EDUCATIONAL FUND, INC.

AND LAWYERS’ COMMITTEE FOR CIVIL RIGHTS UNDER LAW IN SUPPORT OF

RESPONDENTS’ MOTION FOR TEMPORARY RESTRAINING ORDER AND

PRELIMINARY INJUNCTION AND THIRD MOTION FOR CONTEMPT, FOR COURT

ENFORCEMENT OF ORDER AND JUDGMENT, AND FOR ORDER TO SHOW

CAUSE

Jennifer N. Lamirand, MCN Bar No. 1068 Stuart Naifeh

BRESSLER, AMERY & ROSS, P.C. NAACP LEGAL DEFENSE &

210 Park Avenue, Suite 2750 EDUCATIONAL FUND, INC.

Oklahoma City, Oklahoma 73102 40 Rector Street, 5th Floor

T: 405.901.5982 New York, New York 10006

T: 212.965.2200

I. Sara Rohani Edward G. Caspar

NAACP LEGAL DEFENSE & Ryan Snow

EDUCATIONAL FUND, INC. LAWYERS’ COMMITTEE FOR CIVIL

700 14th Street NW, Suite 600 RIGHTS UNDER LAW

Washington, DC 20005 1500 K Street NW, Suite 900

T: 202-365-2154 Washington, DC 20005

T: 202.662.8600

TABLE OF CONTENTS

TABLE OF AUTHORITIES .............. ccc cecccceeessecessseeesestecsensesseeuanaeneeneaeaeeseeaeeaeeeeeeeeeeeoes iil

INTEREST OF AMICI CURITAE...................ccccccceeeeseeseeseeeeecsesucauaceneeneeeneeaaeeneneeceeeeeeesenees 1

ARGUMENT 000. eeeecceeencccecccceececeeeseeeeeeeseeseteesceesteeeeeteesestnsssessaanaueeaecacasessnseeeeseeeeeees 2

I. The Fundamental Right to Vote of the Creek Freedmen Must Not Be Infringed. ................ 4

II. This Court Must Ensure MCN Elections Are Not Undermined by Racial Discrimination and

13>. Cod LES (0) | Orr 5

III. Defiance of This Court’s July 23 Order Threatens the Rule of Law and Subverts the

Separation Of POWETS. ...........cccccccccesssssesssesceecceccececsesseneseeeeeeceseseececcaaaeseeeeeeeeeceeeeseeees 7

A. The Executive Order Violates the Separation of Powers and Threatens the Rule of Law.

veccaneececccccccenecansasececeeceeeseeseeceseesceeseesessesssssessessessssseetseceeauacaeceoasescesonseeessereeeeneeeeqes 7

B. The Executive Order Threatens the Ability of the MCN to Manage Its Elections. ..... 10

CONCLUSION 00000... ccccececcccccesssnscceececcesessessneeececeesucnsnacsneceeceeseqecaneeeecesseseeseceaceeseeseeeenees 11

li

TABLE OF AUTHORITIES

Page(s)

Cases

Abrams v. Johnson,

521 U.S. 74 (1997)... eecesssccsssssecsecescseccsccsseeesscseceesseessessssssscesecsesauessesenssessaesssesesesateseesseseneeeaes 1

Alexander v. S.C. State Conf. of the NAACP,

602 U.S. 1 (2024)... ee eeccesssescescceseeecesneesssssecssesuessesesecssesneseaesesseseesesesecseecsssesecsesseeenseenseneesss l

Allen v. Milligan,

599 U.S. 1 (2023)... eee eeeeecsseeeneescessececesseeeseeseessesssessessesssaeessessecsceaceneaeseeeeeeeaecseearesseaneensees 1,5

Allen v. State Bd. of Elections,

393 U.S. 544 (1969)... eeecccssscssessessscsseesessseesecseessecseessesesecseesssesscsesssesssensecresseesnecsseesaeeatenes 1

Anderson v. Martin,

375 U.S. 399 (1964)... eeccccscsssessccsscsseessessscsscssesceessessecssesseesssescesssssecscessessnesseseseeeseeseseaeennesees 1

Arizona vy. Inter Tribal Council of Ariz., Inc.,

570 US. 1 (2013). ee eceeecsseeeseeecetscceacessesesencseesesacesesansaeessesseeaeeassseeeeseneenecaseaseaeeceeseaseaeate 2

Beaver v. Muscogee (Creek) Nation Council,

C-85-4, 1 Okla. Trib. 57 (Muscogee (Creek) 1986) ..........ccccccsessssssssesssecsessscsseceseesseensesseesneeees 6

Boumediene v. Bush,

553 U.S. 723 (2008).......csccsccscsscssceeeceseeseesscssceseeccscesessesaceassacessecseeseeseceesensseseeseeaeeceseneeeeaseaeeets 8

Bush v. Vera,

517 U.S. 952 (1996)... ee cecesssccsscceccsececesecsnsesceecessessecssecseesscessesecesenecessceeaseasecseeeeeeseseseeeasenee 1

Chisom v. Roemer,

501 U.S. 380 (1991)... eee csescesceseceseessesesceseesecsecenseceaseaceaeseesnsensaceseeneesesreneeeasenesnseseveneneeees 1

Citizenship Bd. of the Muscogee (Creek) Nation v. Grayson & Kennedy,

SC-2023-10 (Muscogee (Creek) 2025) ......cccceccsscesscssesscescesceseeseseessssceseesseeeenseneeeeeae’ 3, 4, 6,9

City of Mobile v. Bolden,

446 U.S. 55 (1980)... ee cecsceessseetecescesecceseesacscescesesseesessecsaceasesenessseaeeeeeateaessseneeeseeseaseseeaenes 1

Clinton v. City of New York,

524 US. 417 (1998)... scsecsecssecescesecscesecsscsesaceaseneaceneesecseeeseeassassaseceeeaseaseneesseseeeatensnsens 7

In re Constitutionality of NCA-01-115,

SC-—01-03, 7 Okla. Trib. 366 (Muscogee (Creek) 2002) ...........ceccesssscesssesssseesseessessseescenneeseeess 7

ili

Cooper v. Aaron,

358 U.S. 1 (1958)... eee eeecsessseeseeeseesesseeaeeseeseeseeeceesascessceseesessesesceessassesseeseseasseseaaenessceaseas 8,9

Courtwright v. July,

SC-93-01, 3 Okla. Trib. 132 (Muscogee (Creek) 1993)... esceeessccseessesssteesereeeeeeseeneeeeeteeeeeees 6

Davis v. Passman,

442 US. 228 (1979)... ecceccsetscessessccseesssscnaccessesssessecesseseseccenseseaeeeaseessscssssnesceaseesseceseseneneeaeseeeses 9

E. Carroll Par. Sch. Bd. v. Marshall,

A2Z4 US. 636 (1976)... .cecccsccsssesssessecssccssscssecsesecestessceesecesecensecessesseseseesenssestecesseesassenaeeeeessesenass 1

Easley v. Cromartie,

532 U.S. 234 (2001)... ee cesescessseeescteeseesecsceneesecseeaecaseneeseeesessecseenseneeseeaeenssseeedsacseasesseaseaseeesaes 1

Ellis v. Nat’l Council,

SC-2005-03, 9 Okla. Trib. 190 (Muscogee (Creek) 2006)..........:..csccsscsssetsesessecseeseeesseeeaceaneeaes 8

Harjo v. Muscogee (Creek) Nation Election Bd.,

SC 07-50 (Muscogee (Creek) 2007)...........ccscsssccsssssteeeseccsssecsscecssscesseseeeessesseesseecessesseeeeseesaeeees 5

Houston Lawyers’ Ass’n v. Att’y Gen. of Tex.,

S01 U.S. 419 (1991). cssseesesseeneesesseeeesecsecsecsceneenaesessseeseedseessaescesseseseeeseesaeeaeeneenseseees® 1

Lane v. Wilson,

307 U.S. 268 (1939)... cceccssccssccesessscssseenseeesscseeceseesssesescessesesesseseseessseseseeseseeseeseeeceaeeenssseasenees 10

League of United Latin Am. Citizens v. Abbott,

809 F.Supp.3d 502 (W.D. TX. 2025) oe eeeecscseeseeseseessesseeceseeesesserecseesesessasseseesaseassneseseeasene 2

Maness v. Meyers,

419 U.S. 449 (1975)... ee cseeccesecsceeeseseesncessessceseesseeseesscaeesaeeeaceseesaeecsecscescsseeeaeeseeeseeeaeecaseseeeas® 8

Marbury v. Madison,

5 U.S. 137 (1803)... ee eecesccsseesseeeeecesseeesessceecesscesceesessceaeeneesseesseeseessenecsacessecscesseseaseseenasees 8, 10

Means v. Wilson,

522 F.2d 833 (8th Cir, 1975) oo... .cccccscsscsscesscsscssscsscsseesseesscecscesscessesnsesncessessesaeseaesestesassessessesees 5

Milam y. U.S. Dep’t of the Interior,

10 ILR 3013 (D.D.C. Dec. 23, 1982) oe ecceccescssesessssesessecsessesseseeseseeseeseseesesneasenseaseneenes 10, 11

NAACP v. Hampton Cnty. Election Comm'n,

470 U.S. 166 (1985)... eeccscecesccscenccessecesseceeeseeseceesscesecessceesaeeseeeaesseescseaeessesscessaeesneeseeseenacs 1

Nw. Austin Mun. Util. Dist. No. One v. Holder,

557 U.S. 193 (2009)... cccscccsssscssccessccescecsssecssscecssecesssseccessessecsueceessesessesesaseeesaeeeeesneecssesenaees |

iv

Okla. City Muscogee (Creek) Ass’n v. Muscogee Nat’l Council,

No. CV 89-08, 1 Okla. Trib. 293 oo. ccececssceteesecseescseeseesessesseseersseseeeee

Rice v. Cayetano,

528 U.S. 495 (2000)... cceececcssceessescesesseseesssesesesesscesesesesssseessessesecsessseseeosees

Robinson v. Callais,

144. S. Ct. 1171 (2024) eecscceeseeseeseesseeaessesatenessecuaeeaseeeesesasessensens

Seminole Nation of Okla. v. Norton,

223 F. Supp. 2d 122 (D.D.C. 2002)... eee eceeeesscnsesesteesneeeeseceseesecaecaceneeanens

Shaw v. Hunt,

5.17 U.S. 899 (1996) .cccccccsssccecesssecessssssvecssescessssssvecsessssssesesseessssveesessesssssesseeee

Shelby Cnty. v. Holder,

570 U.S. 529 (2013) ccccccscccsssssscessesserssssssesssecessssssvesessessssuveesessssnsetsessssssneeseesens

Singleton y. Allen,

782 F. Supp. 3d 1092 (N.D. Ala. 2025)....cccssccssecsssccsssssecsececersssessscssnssneesseeees

Smith v. Allwright,

321 U.S. 649 (1944)... ccccccsccceecsccsssssssssessseserssssssessesessssseeesecarssueesssersssneeesesesee

Terry v. Adams,

345 U.S. 461 (1953) .ccccccsscscecssscccsssssssveeseccesrssssvecsessssssseesesessssseeeseessssnanessesesse

In the Matter of the Constitutionality of NCA 24-077,

SC-2024-05 (Muscogee (Creek) Apr. 22, 2025) ........cescessesseeeseeseeesseenceseesees

Thornburg v. Gingles,

478 U.S. 30 (1986) ...cccssssssessscsssssssssesssssssssssssevssscessnsssessescesssnseseessssneestsceesssenees

Turner v. Fouche,

396 U.S. 346 (1970)...sccccscccccessccccssssssseseceecesssssecesscessssseesecessssneeseseessneveseseeseee

Turtle Mountain Band of Chippewa Indians et al. v. Howe,

145 S. Ct. 2876 (2025)... ec ccscssecsseecssssssscseseessesceaseecsceseeseseeeeseesseeseasseasene

Veasey v. Abbott,

830 F.3d 216 (Sth Cir. 2016) oo. ceecscescseeeceeeesseeseesseeseeseeaceetseeseeesees

Wesberry v. Sanders,

376 U.S. 1 (1964). cecesccseeceserscseeseseeseesseecsceacseseesesseseesesoesaeseeeessaeseeeees

Yick Wo v. Hopkins,

118 U.S. 356 (1886)..cccccccccccccssscecssscccsssssssssescecssssssssesesessssssesssersssveesesessassesesees

Pees eroarrennoasevoserene

Statutes

Indian C.R. Act of 1968, 25 U.S.C. §§ 1302(a)(8)..... cc cececesssseteceecsessecsscescesessesescesecsseeesseeeeeneeaes 4

Indian Citizenship Act of 1924, 8 U.S.C. § 1401 oo. ccecsssseesesseseeeesecsseseesecseessesesseseeeeesenseas 5

Other Authorities

Exec. Order No. 25-05, To Establish the Framework for Incorporating the

Qualification Requirements in Article II of The Treaty of 1866 (Aug. 28,

2025) .ceecceccscssccscsseseescsecssesessessssesscssaceesssesdsseseeaeaeseesssassesscessassesaseassesscaeeesacesssesaceesacesseeseeeeeeses 3

Muscogee (Creek) Const. art. IV, § 2....cccscsccsssecsssssseecssessseneessesecscesecsessesneesesecseceeesessessecseeeeeasens 4

Muscogee (Creek) Const. art. VID, § Lo... cccesesscsseessessseseccseeeseesseesseesesecessssasesecsseseesacesaseesssssessnes 7

Muscogee (Creek) Const. Preamble, Annotation, 1.1 ..........cccccccscssccsseecessceseeescesecssesseseessateesenenees 4

Treaty Between the Unites States of America and the Creek Nation of Indians

(Aug. 11, 1866)... eeesceesseeseeesseeseesessessessesseenseaesusssesseesseseeaeeaecasesseeesaesasesesaesasesesnesseeegs 4

US. Const. amend. XV oo... eeeecesssseeesecsscsseesaeesecsseeseesscessecoseessessessessnessuecsseaeessseneesesasenseseeenseeeaes 5

Voting Rights Win in New Mexico: Navajo Community Gains Equal Opportunity

to Elect Preferred Candidates in Second San Juan County Commission

District, LAWYERS' COMMITTEE (Mar. 25, 2024) ........cssccssccesscssseessceeeeeceecesssessecssesseceessceseeeees 2

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INTEREST OF AMICI CURIAE

Founded in 1940 by Thurgood Marshall, the NAACP Legal Defense & Educational Fund,

Inc. (“LDF”) is the nation’s first and foremost civil rights law organization. LDF’s mission is to

ensure the full, fair, and free exercise of constitutional and statutory rights for all Americans, and

to break down barriers that prevent African Americans from realizing their basic civil and human

rights. Beginning with Smith v. Allwright, 321 U.S. 649 (1944), LDF has represented Black voters

in most of the precedent-setting cases involving efforts to enforce or defend the constitutional right

to vote and the Voting Rights Act of 1965. See, e.g., Robinson v. Callais, 144 8. Ct. 1171 (2024)

(mem.); Alexander v. S.C. State Conf. of the NAACP, 602 U.S. 1 (2024); Allen v. Milligan, 599

USS. 1 (2023); Shelby Cnty. v. Holder, 570 U.S. 529 (2013); Nw. Austin Mun. Util. Dist. No. One

v. Holder, 557 U.S. 193 (2009); Easley v. Cromartie, 532 U.S. 234 (2001); Abrams v. Johnson,

521 U.S. 74 (1997); Bush v. Vera, 517 U.S. 952 (1996); Shaw v. Hunt, 517 U.S. 899 (1996);

Houston Lawyers’ Ass’n v. Att’y Gen. of Tex., 501 U.S. 419 (1991); Chisom v. Roemer, 501 U.S.

380 (1991); Thornburg v. Gingles, 478 U.S. 30 (1986); NAACP v. Hampton Cnty. Election

Comm'n, 470 U.S. 166 (1985); City of Mobile v. Bolden, 446 U.S. 55 (1980); E. Carroll Par. Sch.

Bd. v. Marshall, 424 U.S. 636 (1976); Turner v. Fouche, 396 U.S. 346 (1970); Allen v. State Bd. of

Elections, 393 U.S. 544 (1969); Anderson v. Martin, 375 U.S. 399 (1964); Terry v. Adams, 345

U.S. 461 (1953). LDF has also advocated on behalf of the voting rights of indigenous Americans

who have historically faced systemic disenfranchisement and high barriers to electoral

participation. See, e.g., Turtle Mountain Band of Chippewa Indians et al. v. Howe, 145 S. Ct. 2876

(2025) (granting stay of decision reversing district court’s finding of vote dilution of Native

American voters). These struggles are intertwined.

The Lawyers’ Committee for Civil Rights Under Law is a nonpartisan, nonprofit civil rights

organization, formed at the request of President John F. Kennedy in 1963, that uses legal advocacy

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to achieve racial justice. For more than 60 years, the Lawyers’ Committee has advocated inside

and outside the courts to ensure that Black people and other people of color have the voice,

opportunity, and power to make the promises of democracy real. This includes being able to enjoy

unencumbered access to the ballot and the ability to elect candidates of their choice. The Lawyers’

Committee litigates voting rights cases across the country, and has represented parties to many

seminal voting rights cases including Shelby County v. Holder, 570 U.S. 529 (2013); Arizona v.

Inter Tribal Council of Arizona, Inc., 570 U.S. 1 (2013); Veasey v. Abbott, 830 F.3d 216 (Sth Cir.

2016); and League of United Latin American Citizens v. Abbott, 809 F.Supp.3d 502 (W.D. TX.

2025). The Lawyers’ Committee has also represented tribal nations in challenging the unlawful

dilution of their voting power and is committed to ensuring all Native voters are able to exercise

their fundamental right to vote. See, e.g., Voting Rights Win in New Mexico: Navajo Community

Gains Equal Opportunity to Elect Preferred Candidates in Second San Juan County Commission

District, LAWYERS’ COMMITTEE (Mar. 25, 2024), https://www.lawyerscommittee.org/votingrights-win-in-new-mexico-navajo-community-gains-equal-opportunity-to-elect-preferredcandidates-in-second-san-juan-county-commission-district/. This case is of utmost importance to

the Lawyers’ Committee because it threatens to deprive Black Creek Freedmen citizens of the

ability to vote in free and fair elections which will determine their ability to participate as equal

citizens in the Muscogee (Creek) Nation and because this threatens to damage the legitimacy of

democratic institutions in the Muscogee (Creek) Nation.

ARGUMENT

In its July 23, 2025 Order and Opinion in this case (the “July 23 Order”), this Court

recognized that the Creek Freedmen, including Respondents, are entitled to full citizenship as

members of the Muscogee (Creek) Nation (“MCN”). See Citizenship Bd. of the Muscogee (Creek)

Nation v. Grayson & Kennedy, SC-2023-10, at 23 (Muscogee (Creek) 2025) (“July 23 Op.”). This

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Court also recognized that the Treaty of 1866, which establishes that right, stands supreme over

provisions of the MCN Constitution that are inconsistent with it. Jd. Attendant to the right of

citizenship is the right of the Creek Freedmen to vote and have their voices heard in the democratic

process. Executive Order No. 25-05, issued on August 28, 2025 (“Executive Order No. 25-05”),

defies the July 23 Order. See Exec. Order No. 25-05, To Establish the Framework for Incorporating

the Qualification Requirements in Article II of The Treaty of 1866 (Aug. 28, 2025). Executive

Order No. 25-05 purports to simply delay implementation of the July 23 Order to allow MCN laws

and regulations to be amended to conform with its requirements. But the Executive Order’s

effect—and the effect of Appellant’s submission to it—is to continue to enforce the provisions of

the MCN Constitution this Court has already invalidated, which deny the Creek Freedmen the

rights of citizenship to which they are entitled, including the right to vote in MCN elections. The

scheduling of a special election (the “May Election”) to make critical changes to the MCN

Constitution that will affect all MCN citizens—while continuing to exclude the Creek Freedmen

from participation—has raised the stakes of Appellant’s defiance.

This Court must not allow its orders to be disregarded and the rights of the Creek Freedmen

to be violated. Amici urge the Court to grant Respondents’ Motion for Temporary Restraining

Order and Preliminary Injunction and Third Motion for Contempt, for Court Enforcement of Order

and Judgment, and for Order to Show Cause. This Court should require the immediate processing

of all pending citizenship applications for the Creek Freedmen and impose any additional relief

necessary to ensure they can vote and have their votes counted in the May Election and any other

elections going forward.

I. The Fundamental Right to Vote of the Creek Freedmen Must Not Be Infringed.

The right to vote has long been recognized as a “fundamental political right...preservative

of all rights.” Yick Wo v. Hopkins, 118 U.S. 356, 370 (1886). “Other rights, even the most basic,

are illusory if the right to vote is undermined.” Wesberry v. Sanders, 376 U.S. 1, 17 (1964). This

principle is equally fundamental to the sovereignty of tribal nations. For nearly two hundred years,

tribal nations have been recognized as “distinct independent political communities...qualified to

exercise many of the powers and prerogatives of self-government.” MCN Const. Preamble,

Annotation, n.1, at 2 (citing Worcester v. State of Ga., 31 U.S. 515 (1832)). The unique selfgoverning nature of these nations depends on robust and inclusive participation by all eligible

citizens.

As this Court recognized in its July 23 Order, the Treaty of 1866 guaranteed the Creek

Freedmen all the rights and privileges of MCN citizens and equal protection under MCN law and

process. July 23 Op. Under the Treaty of 1866, the MCN was bound to abolish slavery and extend

the protection and privileges of MCN law to the Creek Freedmen and their descendants. Article 2

of the Treaty of 1866 grants to the Creek Freedmen and their descendants “all the rights and

privileges of native citizens” of the MCN and directs that MCN “laws...give equal protection to

all such persons,” regardless of “race or color.”

The rights attendant to citizenship include the right to vote in MCN elections. The MCN

Constitution provides that “[e]very citizen of the Muscogee (Creek) Nation, regardless of religion,

creed, or sex, shall be eligible to vote in the tribal elections.” MCN Const. art. IV, § 2. The right to

vote must be extended to all such citizens equally. MCN Const. Preamble, Annotation, n.1 at 1

(explaining that the Constitution guarantees “equal voting rights to all eligible tribal voters”); see

also Indian C.R. Act of 1968 (ICRA), 25 U.S.C. §§ 1302(a)(8) (providing that “[n]o Indian tribe

in exercising powers of self-government shall...deny to any persons within its jurisdiction the

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Equal Protection of the Laws”); cf Harjo v. Muscogee (Creek) Nation Election Bd., SC 07-50

(Muscogee (Creek) 2007) (Equal Protection clause of ICRA requires “one man one vote” rule to

be followed in all tribe electoral processes).

Il. This Court Must Ensure MCN Elections Are Not Undermined by Racial

Discrimination and Exclusion.

Our nation’s history of racial discrimination has taken its starkest form in race-based denial

of the right to vote. “Shortly after the Civil War, Congress passed and the States ratified the

Fifteenth Amendment . . . . In the century that followed, however, the Amendment proved little

more than a parchment promise. Jim Crow laws like literacy tests, poll taxes, and ‘good-morals’

requirements abounded, ‘render[ing] the right to vote illusory for blacks.’” Milligan, 599 U.S. at

10 (quoting South Carolina v. Katzenbach, 383 U.S. 301, 312-313 (1966)). Today, a century and a

half after Black Americans gained the right to vote, see U.S. Const. amend. XV, and a century after

the Indian Citizenship Act of 1924 guaranteed Native Americans the right to vote in State and

Federal elections, see 8 U.S.C. § 1401; Means v. Wilson, 522 F.2d 833, 838-839 (8th Cir. 1975),

our nation’s multi-racial democracy remains a work in progress.

Appellants’ denial of as many as four thousand Creek Freedmen’s citizenship applications

is an unacceptable step backward in the nation’s journey toward a full democracy. That this blatant

violation of Respondents’ right to full citizenship in defiance of the July 23 Order comes on the

eve of critical tribal elections to amend the MCN Constitution is unfortunately reminiscent of the

discrimination Black Americans have long faced when seeking to exercise their rights as citizens.

It is profoundly out of step with bedrock democratic principles. Excluding these eligible citizens

from critical elections that will affect them and their families--just as they affect other MCN

citizens--will render the election results illegitimate. Cf Rice v. Cayetano, 528 U.S. 495, 517

(2000).

The MCN has a distinguished tradition of protecting civil liberties. This Court upheld this

commitment when it struck down Article III, Section 2’s “by blood” citizenship requirement as

violative of the Treaty of 1866, and thus, of the U.S. Constitution’s Supremacy Clause. In doing

so, this Court recognized that permitting the exclusion of the Creek Freedmen from the MCN

citizenry would “elevate the most brazen and longstanding injustices over the law, both rewarding

wrong and failing those in the right.” See July 23 Op., at 22 n.51 (citing McGirt v. Oklahoma, 591

US. 894, 938 (2020)). This holding aligned with this Court’s longstanding practice of safeguarding

civil liberties. See, e.g., Courtwright v. July, SC-93-01, 3 Okla. Trib. 132, 141 (Muscogee (Creek)

1993) (striking down a chartered community voting requirement that restricted the right to vote to

individuals who had attended at least three community meetings, because it infringed on MCN

citizens’ “inalienable rights to equal protection and due process of the laws”); Beaver v. Muscogee

(Creek) Nation Council, C-85-4, 1 Okla. Trib. 57 (Muscogee (Creek) 1986) (upholding the results

of a runoff election and invalidating the National Council’s attempt to override them). This Court

should reaffirm that tradition and ensure that all branches of the MCN government uphold the

rights of the Creek Freedmen.

Directly contrary to this Court’s July 23 Order, the Executive Order threatens to deny the

Creek Freedmen’s descendants their right to vote in the upcoming elections—a right guaranteed

to all MCN citizens by MCN’s Constitution and Treaty of 1866 and by federal statute. Allowing

the Executive Order to deny the Creek Freedmen their fundamental right to vote through

obstruction and administrative delay is both contrary to law and to this Court’s clear precedents.

This Court should reaffirm the MCN’s commitment to inclusive democratic governance by

ensuring that all eligible Creek Freedmen may participate freely and equally in upcoming

elections.

Il. Defiance of This Court’s July 23 Order Threatens the Rule of Law and Subverts the

Separation of Powers.

The Executive Order both threatens the most fundamental of rights of the Creek Freedmen

and undermines the rule of law. The Executive Order seeks to defy this Court, jeopardizes the

constitutional order, and threatens rather than affirms the self-determination of the MCN. Intragovernmental compliance with court orders is essential to a well-functioning democracy.

Executive branch officials are not free to disregard the rulings of the judicial branch, nor may they

continue implementing laws or constitutional provisions that the judicial branch has held to be

unenforceable. Yet Executive Order No. 25-05 does precisely that. By functionally requiring

continued implementation of the “by blood” provisions of Article III, Section 2 of the MCN

Constitution, Executive Order No. 25-05 ignores the role of the courts and violates separation of

powers principles central to the MCN constitutional order, which ensure that the Nation is

governed by the rule of law. Indeed, “[l]iberty is always at stake when one or more of the branches

seek to transgress the separation of powers.” Clinton v. City of New York, 524 U.S. 417, 450 (1998).

A. The Executive Order Violates the Separation of Powers and Threatens the

Rule of Law.

The laws of MCN recognize the essential importance of respecting the separation of

powers. The Constitution of the MCN is “is patterned after the United States Constitution and

recognizes the separation of powers among the three branches of the Nation's government.” Jn re

Constitutionality of NCA-01-115, SC-01-03, 7 Okla. Trib. 366 (Muscogee (Creek) 2002). The

Constitution details that “judicial power of the Muscogee (Creek) Nation shall be vested in one

Supreme Court ... and in such inferior courts[.]””» MCN Const. art. VII, § 1. This power includes

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the “judicial interpretation of the Constitution of The Muscogee (Creek) Nation and Ordinances

of The Muscogee (Creek) Nation,” which “is vested only in the Judicial Branch[.]” Okla. City

Muscogee (Creek) Ass’n v. Muscogee Nat’l Council, No. CV 89-08, 1 Okla. Trib. 293, 305

(Muscogee (Cr.) D.Ct. (1989). As this Court has recognized:

The Muscogee (Creek) Nation Constitution is the epitome of what makes the

Muscogee Nation great; a document that has withstood the test of time, trials and

tribulations, forced assimilation, statehood and eventual rebirth. Through it all, this

Nation's Constitution with the Separation of Powers doctrine embodied in it has

emerged virtually unscathed in thought and spirit.

Ellis v. Nat’l Council, SC-2005-03, 9 Okla. Trib. 190 (Muscogee (Creek) 2006). “[T]o give

‘unbridled authority’ to a specific branch at the expense of the others ‘would be a crime against

[the] Great Nation.’” In the Matter of the Constitutionality of NCA 24-077, SC-2024-05, at 7,

(Muscogee (Creek) Apr. 22, 2025) (citation omitted).

Animating the separation of powers doctrine is a recognition of the dangers of unchecked

governmental power, particularly when considering infringements on the judiciary’s power by the

political branches. See, e.g., Boumediene v. Bush, 553 U.S. 723, 727 (2008) (acknowledging that

if “the political branches may switch the Constitution on or off at will [it] would lead to a regime

in which they, not this Court, say ‘what the law is.’”) (citing Marbury v. Madison, 5 U.S. 137, 177

(1803)). If individual rights and liberties are to be secured against governmental excesses, it is a

“basic proposition that all orders and judgments of courts must be complied with promptly.”

Maness v. Meyers, 419 U.S. 449, 458 (1975). If the political branches of the government can

selectively choose which judicial holdings to follow, the legitimacy of the law and its ability to

safeguard the citizenry from injustice is thrown into question. This type of disregard poses an

existential threat to democracy itself. See Cooper v. Aaron, 358 U.S. 1, 18-19 (1958) (holding that

a state governor could not impede a court order, and warning that, “‘[i]f the legislatures of the

several states may, at will, annul the judgments of the courts of the United States, and destroy the

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rights acquired under those judgments, the constitution itself becomes a solemn mockery’”)

(quoting United States v. Peters, 9 U.S. 115, 136 (1809)). The drafters of the U.S. Constitution

likewise acknowledged that the separation of powers “is of great importance in a republic not only

to guard the society against the oppression of its rulers, but to guard one part of the society against

the injustice of the other part.” See THE FEDERALIST No. 51 (James Madison). It is only through

upholding these checks and balances that “the rights of individuals, or of the minority, will be in

little danger from interested combinations of the majority.” Jd. Though the powers vested in the

Executive may be many, he is not “above the law. No officer of the law may set that law at defiance

with impunity.” Davis v. Passman, 442 U.S. 228, 246 (1979) (citation omitted).

Executive Order No. 25-05 threatens these principles. Although the Executive Order

purports to provide for orderly implementation of the July 23 Order, its clear intent and its plain

effect is to frustrate its implementation and delay action on Respondents’ and other Creek

Freedmen’s citizenship applications indefinitely, depriving them of the right to vote in the May

Election. Executive Order No. 25-05 is thus both in blatant violation of this Court’s unanimous

and unambiguous determination that Respondents and all other descendants of the Creek

Freedmen are in fact already citizens of the MCN under established law, while also violating the

separation of powers between the judiciary and the executive as established by the MCN

Constitution. See July 23 Op. at 21-22. The continued refusal to administratively process the Creek

Freedmen’s pending citizenship applications and Appellant’s failure to file the required status

reports lays bare that they have no intention of complying with this Court’s July 23 Order. The

Court’s order “nullifies sophisticated as well as simple-minded modes of discrimination. It hits

onerous procedural requirements which effectively handicap exercise of the franchise by the

colored race although the abstract right to vote may remain unrestricted as to race.” Lane v. Wilson,

307 U.S. 268, 275 (1939). This Court cannot permit such gamesmanship on the part of the

Appellant. See Singleton v. Allen, 782 F. Supp. 3d 1092, 1352-1353 (N.D. Ala. 2025) (explaining

that “federal courts have long held that an attempt to evade a court order is not legitimate’)

(collecting cases).

Preserving the authority of the judiciary to interpret the laws and ensure compliance with

its rulings by the political branches is critical in safeguarding the rights of historically marginalized

groups. Executive action that undermines the judiciary’s function in protecting minorities and

upholding guarantees of the law not only tramples upon individual rights but debases the notion

that MCN is “a government of laws, and not of men,” Marbury, 5 U.S. at 163, and threatens the

liberty of all MCN citizens.

B. The Executive Order Threatens the Ability of the MCN to Manage Its

Elections.

The lawless action of Appellants not only threatens the voting rights of Respondents but

also the MCN’s sovereign prerogative to conduct its own elections. Proceeding with an election

rendered illegitimate by the unlawful exclusion of the Creek Freedmen will invite federal scrutiny,

undermining federal sovereignty. Under almost perfectly analogous circumstances, federal

authorities have stepped in and invalidated tribal elections conducted in violation of the voting

rights of Freedmen granted citizenship under post-Civil War treaties. In Seminole Nation of

Oklahoma v. Norton, the Seminole Nation passed constitutional amendments designed to exclude

Creek Freedmen descendants from citizenship and then held elections without counting their

ballots. Because of this, the U.S. Department of the Interior refused to recognize the election

results. A U.S. District Court upheld the Department of the Interior’s refusal, recognizing the

“oppressive action on the Nation’s part against its own minority members.” Seminole Nation of

Okla. v. Norton, 223 F. Supp. 2d 122, 137, 147-148 (D.D.C. 2002). Likewise, in Milam v. United

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States Department of the Interior, the court confirmed that the Secretary of the Interior “is charged

not only with the duty to protect the rights of the tribe, but also the rights of individual members,”

whether the infringement comes “by non-members or by members of the tribe.” Milam v. U.S.

Dept of the Interior, 10 ILR 3013, 3015, 3017 (D.D.C. Dec. 23, 1982).

Allowing the May Election to go forward while the MCN continues to deny formal

recognition of citizenship to Respondents and other Creek Freedmen whose applications have been

arbitrarily delayed—individuals this Court has unanimously and unambiguously held are entitled

to MCN citizenship on an equal footing with other citizens—will result in an illegitimate election

the results of which are vulnerable to challenge. This Court can and should take whatever steps are

necessary to ensure that the MCN can conduct elections without federal intervention by enjoining

elections that exclude the Creek Freedmen in violation of the July 23 Order, or by otherwise

providing that all MCN citizens—including Creek Freedmen with pending citizenship

applications—can vote freely and equally in upcoming elections.

CONCLUSION

For the foregoing reasons, this Court should grant Respondents’ Motion for Temporary

Restraining Order and Preliminary Injunction and Third Motion for Contempt, for Court

Enforcement of Order and Judgment, and for Order to Show Cause.

Respectfully Submitted,

Vrngf-

Jennifer N. Lamirand, MCN Bar No. 1068

BRESSLER, AMERY & ROSS, P.C.

210 Park Avenue, Suite 2750, Oklahoma City,

Oklahoma 73102

T: 405.901.5982

jlamirand@bressler.com

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ATTORNEYS FOR AMICI CURIAE NAACP

LEGAL DEFENSE AND EDUCATIONAL FUND,

INC. AND LAWYERS’ COMMITTEE FOR CIVIL

RIGHTS UNDER LAW

Stuart Naifeh

NAACP LEGAL DEFENSE & EDUCATIONAL

FUND, INC.

40 Rector Street, 5th Floor, New York, New York

10006

T: 212.965.2200

F: 212.226.7592

snaifeh@naacpldf.org

I. Sara Rohani

NAACP LEGAL DEFENSE & EDUCATIONAL

FUND, INC.

700 14th Street NW, Suite 600, Washington, DC

20005

T: 202.365.2154

srohani@naacpldf.org

Edward G. Caspar

Ryan Snow

LAWYERS’ COMMITTEE FOR CIVIL RIGHTS

UNDER LAW

1500 K Street NW, Suite 900, Washington, DC

20005

T: 202.662.8600

F: 202.783.0857

ecaspar@lawyerscommittee.org

rsnow@lawyerscommittee.org

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