moción de intervención caso matrimonio gay primer circuito 14-2184

7/26/2019 Mocin de Intervencin Caso Matrimonio Gay Primer Circuito 14-2184

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__________________________14-2184_____________________________

IN THE UNITED STATES COURT OF APPEALSFOR THE FIRST CIRCUIT

____________________________________________

ADA MERCEDES CONDE-VIDAL; MARITZA LOPEZ-AVILES; IRIS DELIARIVERARIVERA; JOSE A. TORRUELLAS-IGLESIAS; THOMAS J.

ROBINSON; ZULMA OLIVERASVEGA; YOLANDA ARROYO-PIZARRO;JOHANNE VELEZ-GARCIA; FAVIOLA MELENDEZ-RODRIGUEZ; PUERTO

RICO PARA TOD@S; IVONNE ALVAREZ-VELEZ,Plaintiffs-Appellants,

v.

DR. ANA RIUS-ARMENDARIZ, in her official capacity as Secretary of theHealth Department of the Commonwealth of Puerto Rico; WANDA LLOVET

DIAZ, in her official capacity as the Director of the Commonwealth of Puerto RicoRegistrar of Vital Records; ALEJANDRO J. GARCIA-PADILLA, in his official

capacity as Governor of the Commonwealth of Puerto Rico; JUAN C.ZARAGOSA-GOMEZ, in his official capacity as Director of the Treasury in

Puerto Rico,Defendants-Appellees

Appeal from the United States District Court from the District of Puerto Rico

Civil Case No. 14-1253 (PG)Honorable District Court Judge Juan Prez-Gimnez

BRIEF FOR EIGHT (8) NAMED SENATORS AND FIVE (5)NAMED REPRESENTATIVES DULY ELECTED BY THE PEOPLE OF THE

COMMONWEALTH OF PUERTO RICO AS INTERVENOR

MOTION FOR LEAVE TO INTERVENE AS DEFENDANT-APPELLEE FOR PURPOSESOF APPEAL

Case: 14-2184 Document: 00116823395 Page: 1 Date Filed: 04/14/2015 Entry ID: 590012


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Come Now Eight (8) duly elected Senators along with Four (4) duly elected

Representatives by Puerto Rico constituents, Honorable ngel Ramn

Chayanne Martnez-Santiago, Honorable Jos Joto" Prez-Rosa,

Honorable Luis Daniel Rivera-Filomeno, Honorable Pedro Pedrito

Rodrguez-Gonzlez, Honorable Migdalia Padilla-Alvelo, Honorable ngel

Rodrguez-Otero, Honorable Ramn Ruz-Nieves, Honorable Itzamar Pea-

Ramrez, Honorable Jos A. Toni Rodrguez-Quiles, Honorable Nardem

Jaime-Espinosa, Honorable Antonio L. Tony Soto-Torres, Honorable

Mara Milagros Tata Charbonier-Laureano, Jos E. Quiquito Melndez

Ortz (hereinafter Movants) through the undersigned counsel, and hereby

respectfully move this Court for leave to intervene as a party-appellee, either as a

matter of right or permissibly, in the above-captioned matter for purposes of filing

an appeal. In support of this motion, the Eight (8) Senators and the Five (5)

Representatives state the following:

[SPACE LEFT BLANK INTENTIONALLY]



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The Movants As Prospective Intervenors1

1. Honorable ngel Chayanne Martnez-Santiago and Honorable Jos Joto

Prez-Rosa are duly elected senators by Puerto Rico constituents residing within

the District of Arecibo. Both senators are a PNP members, minority party.

2. Honorable Luis Daniel Rivera-Filomeno and Honorable Pedro Pedrito

Rodrguez-Gonzlez, are both duly elected Senators by Puerto Rico constituents

residing within the District of Carolina. Both senators are PPD members, majority

party.

3. Honorable Angel Rodrguez-Otero is a duly elected senator by Puerto Rico

constituents residing within the District of Guayama. He is PPD member, majority

party.

4. Honorable Ramn Ruiz-Nieves is a duly elected senator by Puerto Rico

constituents residing within the District of Ponce. He is a PPD member, majority

party.

1Under Article III 1-3 of the Constitution of the Commonwealth of Puerto Rico

legislative power is vested solely upon the Legislative Assembly of Puerto Rico.



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5. Honorable Migdalia Padilla-Alvelo is a duly elected senator by Puerto Rico

constituents residing within the District of Bayamn. She is a PNP member,

minority party.

6. Honorable Itzamar Pea-Ramrez is a duly elected Senator At Large by Puerto

Rico constituents. She is a PNP member, minority party.

7. Honorable Jos A. Toni Rodrguez-Quiles, is duly elected representative for

District 16 (Isabela, San Sebastin, and Las Maras). He is a PPD member,

majority party.

8. Honorable Nardem Jaime-Espinosa is a duly elected representative for District

Thirty-five (35) (Humacao). He is PPD member, majority party.

9. Honorable Antonio L. Tony Soto-Torres, is a duly elected representative for

District 6 (Catao, Guaynabo, and Bayamn). He is a PNP member, minority

party.

10. Mara Milagros Tata Charbonier-Laureano, is a duly elected Representative

at Large. She is a PNP member, minority party.

11. Jos E. Quiquito Melndez Ortz is a duly elected Representative at Large.

He is a PNP member, minority party.

12. They all appear in their individual capacities as prospective Intervenors

(hereinafter Movants). Because the Appellee-Defendants have refused to



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defend Puerto Ricos marriage law (Article 68) on appeal, Movants move to

intervene for the purposes of pursuing an appeal, protecting its significant interests,

and ensuring that the critical constitutional questions presented in this case are

properly defended.

Argument

1. Appellants are comprised of a gay rights advocacy group and five same-

sex couples seeking the right to marry in Puerto Rico or recognition of their

foreign marriages sued four government officials to invalidate Article 68

under the Due Process and Equal Protection Clauses of the Fourteenth

Amendment. On October 21, 2014 the District Court dismissed their claims

under FED. R. CIV. P. 12(b)(6), based onMassachusetts v. HHS, 682 F.3d 1,

8 (1st Cir. 2012), and Baker v. Nelson, 409 U.S. 810 (1972). This appeal

ensued.

2. On March 20, 2015, the defendant-appellee, Commonwealth of Puerto Rico

(the Executive branch of government), changed its position before the Court by

filing its appellee brief, now in support of the appellants request for remedies

asserting, in summary, that it cannot be established that, what they describe as

Puerto Ricos ban on same-sex marriage, is narrowly tailored to advance a

compelling state interest and that constitutional strict scrutiny should be applied

whether it be under Equal Protection Clause or Due Process Clause. The



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position assumed by the Executive Branch is contrary to Puerto Ricos public

policy duly enacted through the legislative process.

3.

The prospective intervenor brief is submitted by government officers who

will properly defend the Puerto Ricos marriage law.

4.

They have an interest in the case.

5. Appellant-Plainffs challenge Puerto Ricos marriage law (Article 68) on

constitutional equal-protection grounds. The challenged law defines

marriage and limits recognition of marriage within the State to the union of

one man and one woman.

6. The challenged law originated as legislation in the Commonwealth of Puerto

Ricos legislature.7. On October 21, 2014 the District Court dismissed Appellants claims under

FED. R. CIV. P. 12(b)(6), based onMassachusetts v. HHS, 682 F.3d 1, 8 (1st

Cir. 2012), andBaker v. Nelson, 409 U.S. 810 (1972).

8. The Governor of Puerto Rico, through its Secretary of Justice, although at

first defended Puerto Ricos marriage law before the district court, had a

change of heart and on appeal took the position that Puerto Ricos Article 68

is now unconstitutional.



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9. Movants, as duly elected officials have plenary authority to regulate the

institution of marriage in this State. From the laws perspective, the well-

being of marriage as a social institution in Puerto Rico has been uniquely

entrusted to the Legislature, which has a significant interest as the States

legislative body, and as the author of the challenged laws, to ensure that the

States marriage laws are adequately defended when challenged in court.

10.If the Prospective Interveners cannot intervene the legislatures ability to

protect its significant interests in the subject of this action will be impeded.

11.The Legislatures significant interests in the subject of this action are

inadequately represented by existing parties. In addition, the Appellant has

consented that another group of senators appear as amici in order to

advocate on their behalf as well.

12.

Appellees inaction and refusal to defend Puerto Ricos marriage laws has

the effect of undermining the legislatures interests in defending the

challenged marriage laws. In fact, the Appellee is now advocating on behalf

of the Appellant.

13. Substantial justice requires that Movants be allowed to intervene given the

Appellees refusal to defend Article 68. Allowing the Prospective

Interveners to intervene furthers substantial justice by ensuring the orderly



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and dignified resolution of a constitutional question of enormous state and

national importance.

14.Granting the Movantsmotion to intervene will not prejudice the existing

parties.

15.Movants have a cognizable interest in defending the enforceability of

statutes the legislature has passed when the Governor declines to enforce

them and Movants interests are not currently being adequately represented in

this action. Abandonment of the Executive branchs traditional role of

defending duly-enacting statutes, that decision imposes substantial burdens

on the legislature. Movants intervention is of surpassing importance to the

separation of powers.

16.--Movants have standing to intervene in this appeal to defend the

constitutionality of Article 68. Our highest court has expressed that

Congress is a proper party to defend the constitutionality of [the

challenged statute]. (citing INS v. Chadha, 462 U.S. 919, 939 (1983). By

comparison, Puerto Ricos legislature would also be a proper party to defend

the constitutionality of the challenged Article 68.

17. In the accompanying brief in support, Movants will establish, among other

things, that (1) the motion to intervene is timely; (2) they have an interest

relating to the defense of Article 68 as policymakers; (3) the disposition of



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the action threatens to create a practical impediment to the intervenors

ability to protect its interest; and (4) no existing party adequately represents

the intervenors interests.

Wherefore, the Eight (8) Senators and the Five (5) Representatives respectfully

urge this Court to grant its motion to intervene.

In Caguas, Puerto Rico this 14thday of April, 2015

Respectfully submitted,

s/EVELYN AIME DE JESSEVELYN AIME DE JESSUSCA 1st Cir. Bar No. 81601Counsel for ProspectiveIntervenorsPO Box 88Caguas, PR 00726-0088Telephone (787) [email protected]@me.com

CERTIFICATE OF SERVICE

I hereby certify that on this same date, I electronically filed the foregoing

document with the United States Court of Appeals for the First Circuit by using the

CM/ECF system. I certify that the following parties or their counsel of record are

Registered as ECF Filers and that they will be served by the CM/ECF system:

mailto:[email protected]:[email protected]:[email protected]


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Omar Gonzalez-PagnHayley GorenbergKaren L. LoewyJael Humphrey-SkomerGary W. KubekHarriet M. AntczakJing KangRyan M. KusminMark C. FlemingFelicia H. EllsworthRachel I. GurvichWilmer Cutler PickeringPaul R.Q. WolfsonAlan E. Schoenfeld

Celina Romany-SiacaCounsel for Plaintiffs-Appellants

Maritza Lpez Avils and Iris D.Rivera Rivera; Jos A. TorruellasIglesias and Thomas J. Robinson;Zulma Oliveras Vega and Yolanda

Arroyo Pizarro; Johanne VlezGarca and Faviola Melndez

Rodrguez; and Puerto Rico ParaTod@s

Ada M. Conde VidalCounsel for Plaintiff-Appellant

Ivonne lvarez VlezJos L. NietoCounsel for Plaintiff-Appellant

Ada M.Conde VidalIdza Daz-RiveraAndrs Gonzlez-BerdecaMargarita Luisa Mercado-EchegarayTanaira Padilla-RodrguezCounsel for Defendants-Appellees

By s/EVELYN AIME DE JESSUSCA 1st Cir. Bar No. 81601Counsel for ProspectiveIntervenors



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______________________14-2184_______________________

IN THE UNITED STATES COURT OF APPEALSFOR THE FIRST CIRCUIT

_____________________________________________________

ADA MERCEDES CONDE-VIDAL; MARITZA LOPEZ-AVILES; IRIS DELIARIVERARIVERA; JOSE A. TORRUELLAS-IGLESIAS; THOMAS J.

ROBINSON; ZULMA OLIVERASVEGA; YOLANDA ARROYO-PIZARRO;JOHANNE VELEZ-GARCIA; FAVIOLA MELENDEZ-RODRIGUEZ; PUERTO

RICO PARA TOD@S; IVONNE ALVAREZ-VELEZ,Plaintiffs-Appellants,

v.

DR. ANA RIUS-ARMENDARIZ, in her official capacity as Secretary of theHealth Department of the Commonwealth of Puerto Rico; WANDA LLOVET

DIAZ, in her official capacity as the Director of the Commonwealth of Puerto RicoRegistrar of Vital Records; ALEJANDRO J. GARCIA-PADILLA, in his official

capacity as Governor of the Commonwealth of Puerto Rico; JUAN C.ZARAGOSA-GOMEZ, in his official capacity as Director of the Treasury in

Puerto Rico,Defendants-Appellees

Appeal from the United States District Court from the District of Puerto Rico

Civil Case No. 14-1253 (PG)Honorable District Court Judge Juan Prez-Gimnez

BRIEF FOR EIGHT (8) NAMED SENATORS AND FIVE (5)

NAMED REPRESENTATIVES DULY ELECTED BY THE PEOPLE OF THECOMMONWEALTH OF PUERTO RICO AS INTERVENOR



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INTERVENORS BRIEF IN SUPPORT OF MOTION TO INTERVENE

Proposed Intervenor-Defendants: Honorable ngel Ramn Chayanne

Martnez-Santiago, Honorable Jos Joto" Prez-Rosa, Honorable Luis Daniel

Rivera-Filomeno, Honorable Pedro Pedrito Rodrguez-Gonzlez, Honorable

Migdalia Padilla-Alvelo, Honorable ngel Rodrguez-Otero, Honorable Ramn

Ruz-Nieves, Honorable Itzamar Pea-Ramrez, Honorable Jos A. Toni

Rodrguez-Quiles, Honorable Nardem Jaime-Espinosa, Honorable Antonio L.

Tony Soto-Torres, and Honorable Mara Milagros Tata Charbonier-Laureano,

Jos E. Quiquito Melndez Ortz,by and through counsel, respectfully submit

this Proposed Intervener Brief, in Support of Motion to Intervene.

STATEMENT OF THE CASE

Under the Commonwealth of Puerto Ricos Civil Code, Marriage is a civil

institution whereby a man and a woman mutually agree to become husband and

wife, and foreign same sex marriages are invalid. P.R. LAWS ANN. tit. 31, 221

(Article 68).

Appellant-Plaintiffs are a gay rights advocacy group and five same-sex

couples seeking the right to marry in Puerto Rico or recognition of their foreign

marriages (Plaintiffs) sued four (4) government officials (hereinafter, Puerto

Rico) to invalidate Article 68 under the Due Process and Equal Protection Clauses

of the Fourteenth Amendment. The District Court dismissed their claims under



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Fed. R. Civ. P. 12(b)(6), based on Massachusetts v. HHS, 682 F.3d 1, 8 (1st Cir.

2012), andBaker v. Nelson, 409 U.S. 810 (1972).

ARGUMENT

The Commonwealth of Puerto Rico, through the passage of Article 68 of its

Civil Code, have maintained marriage as a legal union between one man and one

woman. It specifically states the following: [m]arriage is a civil institution

whereby a man and a woman mutually agree to become husband and wife. Any

marriage between persons of the same sex or transsexuals contracted in other

jurisdictions shall not be valid. (Article 68 of the Civil Code, P.R. Laws Ann. tit.

31, 221).

Appellants-Plaintiffs are comprised of a gay rights advocacy group and five

same-sex couples seeking the right to marry in Puerto Rico or recognition of their

foreign marriages sued four government officials to invalidate Article 68 under the

Due Process and Equal Protection Clauses of the Fourteenth Amendment. After

Appellee-Defendants defended Article 68, on October 21, 2014 the District Court

dismissed Appellants claims for failing to present a substantial federal question

under Fed. R. Civ. P. 12(b)(6), based onMassachusetts v. HHS, 682 F.3d 1, 8 (1st

Cir. 2012), andBaker v. Nelson, 409 U.S. 810 (1972).

On March 20, 2015, the defendant-appellee, Commonwealth of Puerto Rico



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INTERVENTION IS APROPRIATE UNDER RULE 24(a)(2)

Federal Rule 24(a)(2) provides that:

On timely motion, the court must permit anyone to intervene who:

(2) claims an interest relating to the property or transaction that is thesubject of the action, and is so situated that disposing of the actionmay as a practical matter impair or impede the movants ability toprotect its interest, unless existing parties adequately represent thatinterest.

Under the law of this Circuit, four criteria must be satisfied before

intervention as of right under this rule will be granted:

(1) the motion to intervene must be timely;

(2) the putative intervenor must have an interest relating to the

property or transaction that forms the basis of the ongoing suit;

(3) the disposition of the action threatens to create a practical

impediment to the intervenors ability to protect its interest; and

(4) no existing party adequately represents the intervenors interests.B.

Fernandez & Hnos., Inc. v. Kellogg USA, Inc., 440 F.3d 541, 54445 (1st Cir.

2006) (citingPub. Serv. Co. of N.H. v. Patch, 136 F.3d 197, 204 (1st Cir. 1998)).

The Movants easily satisfy each of these requirements.



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1. Timeliness

First, Movants motion is timely. Appellee-Defendants, announced on

March 20, 2015 the decision to no longer defend Puerto Ricos marriage law,

(Article 68) from equal protection challenges. On that same date they filed their

appellees brief. Today, this Court ordered the parties to confer an propose a

schedule for further proceedings in view of the cases pending before the Supreme

Court of the United States such as Obergfell v. Hodges, 14-556, among others.

Second, Movants have a strong interest in defending the constitutionality of

its legislative handiwork codified in Article 68 of the Civil Code, P.R. Laws Ann.

tit. 31, 221, which states that [m]arriage is a civil institution whereby a man and

a woman mutually agree to become husband and wife. Any marriage between

persons of the same sex or transsexuals contracted in other jurisdictions shall not

be valid.

Third, appellees refusal to defend Article 68 threatens Movants ability to

protect its interest in seeing that Article 68s constitutionality is upheld because

both parties to the appeal contend that Article 68 is unconstitutional under the

equal protection component of the Fourteenth Amendment and Appellees refuse to

defend against that challenge. Therefore, unless Movants intervene, they will have

no ability to protect its constitutional interests.



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Lastly, for exactly the same reason, none of the existing parties represent

Movants interest in defending the constitutionality of Puerto Ricos marriage law

against equal protection challenges. See Chadha, 462 U.S. at 940. While there is

normally a rebuttable presumption that the government will adequately defend an

action, that presumption is overcome where, as here, there is a divergence of

interest between the governmental entity charged with defending an action (here,

Secretary of Justice and the Governor) and the intervenor (here, Legislators). See

Cotter v. Mass. Assn of Minority Law Enforcement Officers , 219 F.3d 31, 3536

(1st Cir. 2000).

In short, given appellees intent to not defend Article 68, it would be

appropriate that Movants be allowed to intervene as of right under Rule 24(a)(2).

2. Movants Have Significantly Protectable Interests in the Subject Matter

Movants have significant protectable interests in the subject matter of this

appeal. See U.S. ex rel. Frank M. Sheesley Co. v. St. Paul Fire and Marine Ins.

Co., 239 R.R.D. 404, 409 (W.D. Pa. 2006) (The interest at stake must be

significantly protectable, which binding precedent interprets to mean a legal

interest as distinguished from interests of a general and indefinite character.

Harris v. Pernsley, 820 F.2d 592, 601 (3d Cir.1987)).

Movants, as duly elected legislators, have a significantly protectable interest

in the Commonwealths laws and policy making through a democratic process.



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This includes matters of domestic relations.

The U.S. Supreme Court has expressed that domestic relations of husband

and wife and parent and child were matters reserved to the States. See Windsor,

133 S.Ct. at 269192, (citing Ohio ex rel. Popovici v. Agler, 280 U.S. 379, 383-

384 (1930)).

Puerto Ricos Article 68 is the embodiment of state regula tion of domestic

relations. The voters exercise of their reserved power must be preserved and

protected. Regulation of domestic relations is an area that has long been regarded

as a virtually exclusive province of the States. See Windsor, 133 S.Ct. 2691.

3. Absent Movants Intervention as a Party, the Courts Ruling WillImpair Their Significantly Protectable Interests

As a practical matter, the outcome of this appeal has the potential to

adversely affect Movants significantly protectable interests. The U.S. Supreme

Court previously ruled that domestic relations of husband and wife and parent and

child were matters reserved to the States. See Windsor, supra.

In harmony with Windsors ruling, the district court expressed that the

question of whether to exclude LGBT people from marriage is for the People,

acting through their elected representatives. (Conde-Vidal vs. Rius Armendariz,

14-1253-PG, D.P.R. page 21). The district court, citing Schuette, infra, went on to

emphasize the importance of the role of the people, acting through their elected

representatives to regulate marriage:



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A proposed intervenor should be treated [by this Court] as the best judge of

whether the existing parties adequately represent ... her interests, and ... any doubt

regarding adequacy of representation should be resolved in [her] favor. 6 Edward

J. Brunet,Moores FederalPractice 24.03[4][a] (3d ed. 1997).

proving that Movants interests are not adequately represented.

Thus, as Appellee-Defendants assumed the position of not defending Article

68 on appeal Movants interests are not adequately represented.

STANDING

On the matter of standing, in this Circuit an applicant who satisfies the

interest requirement of the intervention rule is almost always going to have a

sufficient stake in the controversy to satisfy Article III as well. Cotter, 219 F.3d at

34 (citing Transam. Ins. Co. v. South, 125 F.3d 392, 396 n.4 (7th Cir. 1997)); see

also Daggett v. Commn on Governmental Ethics & Election Practices, 172 F.3d

104, 110 (1st Cir. 1999) (Although the two are not identical, the interest

required under Rule 24(a) has some connection to the interest that may give the

party a sufficient stake in the outcome to support standing under Article III.). As

discussed above, Movants clearly satisfy the interest requirement of Rule 24(a)(2).

Moreover, this Court has repeatedly held that intervenors met the rather modest

requirements of Article III.Daggett172 F.3d at 109, 114 (holding that defendant-

intervenors possessed Article III standing and explaining that it was therefore



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unnecessary to decide whether an intervenor as of right must possess standing

under Art. III); see alsoMangual v. Rotger-Sabat, 317 F.3d. 45, 62 (1st Cir. 2003)

(declining to decide the complicated question of whether standing is required to

intervene if the original parties are still pursuing the case because it is clear that

[the intervenor] has sufficient standing under Article III).

II. MOVANTS ARE ENTITLED TO PERMISSIVE INTERVENTION

Movants are also entitled to intervention are also entitled to permissive

intervention. On timely motion, the court may permit a . . . governmental officer

or agency to intervene if a partys claim or defense is based on a statute. Fed. R.

Civ. P. 24(b)(2).

In this case, it is undeniable that Movants are duly elected legislators with

plenary authority to regulate the institution of marriage in this State. From the

laws perspective, the well-being of marriage as a social institution in Puerto Rico

has been uniquely entrusted to the Legislature, which has a significant interest as

the States legislative body, and as the author of the challenged laws, to ensure that

the States marriage laws are adequately defended when challenged in court.

Therefore, this Court should permit Movants to intervene in this appeal in

order to defend Article 68.

Additionally, a court may grant permissive intervention upon a timely

motion, provided that a proposed intervenor has a claim or defense that shares



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with the main action a common question of law or fact, andthat the intervention

will not unduly delay or prejudice the adjudication of the original parties rights.

Fed. R. Civ. P. 24(b). First, Movants established above that their motion is timely,

and the same argument applies with equal force here. Second, Movantsdefense

shares a common question of law with Plaintiffs claimsnamely, whether Puerto

Ricos Marriage Lawviolates the United States Constitution. Third, the litigation

will not be delayed, nor will the existing parties be unduly prejudiced by Movants

intervention in this case because they do not seek to relitigate matters before the

district court but only to defend on appeal. Thus permissive intervention is proper

here. Further, a comprehensive defense of Puerto Ricos Marriage Lawbefore the

appellate courts is desirable to ensure that the important constitutional question

raised in this case is properly refined by the crucible of appellate review. See

Hollingsworth v. Perry, 133 S. Ct. 2652, 2674 (2013) (Kennedy, J., dissenting).

The Court should therefore grant Movantsrequest for permissive

intervention.

[SPACE LEFT BLANK INTENTIONALLY]



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CONCLUSION

For the foregoing reasons, this Court should grant Movantsrequest to

intervene as an Appellee-Defendant in this case.

Respectfully submitted in Caguas, Puerto Rico this14th day of April, 2015

s/EVELYN AIME DE JESSEVELYN AIME DE JESSUSCA 1st Cir. Bar No. 81601

Counsel for ProspectiveIntervenorsPO Box 88

Caguas, PR 00726-0088

Telephone (787) 593-3055

[email protected]

[email protected] OF SERVICE

I hereby certify that on this same date, I electronically filed the foregoing

document with the United States Court of Appeals for the First Circuit by using the

CM/ECF system. I certify that the following parties or their counsel of record are

Registered as ECF Filers and that they will be served by the CM/ECF system:



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Omar Gonzalez-Pagn

Hayley Gorenberg

Karen L. Loewy

Jael Humphrey-SkomerGary W. Kubek

Harriet M. Antczak

Jing Kang

Ryan M. Kusmin

Mark C. Fleming

Felicia H. Ellsworth

Rachel I. GurvichWilmer Cutler Pickering

Paul R.Q. Wolfson

Alan E. Schoenfeld

Celina Romany-Siaca

Counsel for Plaintiffs-Appellants

Maritza Lpez Avils and Iris D.

Rivera Rivera; Jos A. TorruellasIglesias and Thomas J. Robinson;

Zulma Oliveras Vega and Yolanda

Arroyo Pizarro; Johanne VlezGarca and Faviola Melndez

Rodrguez; and Puerto Rico Para

Tod@s

Ada M. Conde Vidal

Counsel for Plaintiff-Appellant

Ivonne lvarez Vlez

Jos L. NietoCounsel for Plaintiff-Appellant

Ada M.Conde Vidal

Idza Daz-Rivera

Andrs Gonzlez-Berdeca

Margarita Luisa Mercado-Echegaray

Tanaira Padilla-Rodrguez

Counsel for Defendants-Appellees

By s/EVELYN AIME DE JESS

USCA 1st Cir. Bar No. 81601



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Counsel for ProspectiveIntervenors


moción de intervención caso matrimonio gay primer circuito 14-2184

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