[PAGE 4: MOTION FOR LEAVE TO FILE AMICUS]

MOTION FOR LEAVE TO FILE AMICUS CURIAE BRIEFS PRO SE

Pursuant to Rule 37.2(b), Theodore “Ted” Hayes, Jr., moves for leave to file the attached briefs. These filings address the mandatory enforcement provisions

of the Civil Rights Act of 1866 and the historical authority of the President as Commander-in-Chief to recognize and maintain the freedom of the specific

class of citizens defined by the 39th Congress. Amicus provides a unique historical perspective on the Johnson Veto of 1866 as a hostile admission of the Act’s

intended scope.