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Notice of motion requesting leave to file memorandum of Law as Amicus Curiae

NOTICE OF MOTION REQUESTING LEAVE TO FILE

MEMORANDUM OF LAW AS AMICUS CURIAE

 

SUPREME COURT OF THE STATE OF NEW YORK

APPELLATE DIVISION: FIRST DEPARTMENT

-----------------------------------------------------------------------X

THE PEOPLE OF THE STATE OF NEW YORK, Indictment No.

Plaintiff-Respondent, 10938/

-against-

 

OLIVER JOVANOVIC,

Defendant-Appellant.

-----------------------------------------------------------------------X

 

NOTICE OF MOTION REQUESTING LEAVE TO FILE

MEMORANDUM OF LAW AS AMICUS CURIAE

 

Please take notice that,

Upon the annexed Affirmation of Michael Thomas Fois, and all the pleadings and papers had herein, the undersigned, counsel for the National Coalition for Sexual Freedom, respectfully moves this Court for leave to file the accompanying draft Memorandum of Law as amicus curiae.

Dated: New York, New York

January __, 1999

 

Respectfully submitted,

 

 

MICHAEL THOMAS FOIS
Attorney for Amicus Curiae
National Coalition for Sexual Freedom
381 Manhattan Ave.
Brooklyn, New York 11211
(212) 353-8984

cc: DIARMUID M. WHITE
Attorney for Defendant-Appellant
148 East 78th Street
New York, New York 10021
ROBERT MORGENTHAU
District Attorney for the
County of New York
attn: Mark Dwyer
Assistant District Attorney
Appeals Bureau
One Hogan Place
New York, New York 10013

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Why You Should Care

Because your sexual expression...
  • Can result in discrimination, prosecution, and even violence against you
  • Can cause you to lose your children
  • Can cause you to lose your job or your income
  • Can lead you into a maze of antiquated laws and regulations you never even knew existed
  • Is arbitrarily criminalized by state and local authorities
  • Is used by the radical right to marginalize minority groups
  • Can result in the invasion of your privacy by the government, both within your own home or in educational, social and group environments 

How You Can Help

    • Work to change antiquated laws
    • Work to change the social climate about sexual issues
    • Promote acceptance of safe, sane, and consensual alternative sexual practices among consenting adults
    • Oppose censorship of consensual sexual expression
    • Fight for freedom of academic expression about sexual issues
    • Help communities and individuals facing the threat of prosecution or legal action
    • Support the right of adults to express their sexuality, gender identity and orientation freely and openly without fear
    • Learn more about NCSF