STEP 4: MOTION FOR LEAVE TO FILE AMICUS CURIAE BRIEFS

Pursuant to Rule 37.2(b), Theodore “Ted” Hayes, Jr. respectfully moves for leave to file the accompanying briefs. This filing is desirable because the parties have not adequately addressed the mandatory enforcement provisions of the Civil Rights Act of 1866. Amicus brings unique historical evidence regarding the March 27, 1866, Veto Message of President Andrew Johnson, which serves as a hostile admission of the Act’s intent. This Court’s intervention is required to ensure the Executive Branch “recognizes and maintains” the freedom of the specific class of citizens defined by the 39th Congress.