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Brief of Traditionalist Youth Network, LLC, As Amici Supporting The Appellants, Kolbe v. O'Malley (4th Cir.)
Brief of Traditionalist Youth Network, LLC, As Amici Supporting The Appellants, Kolbe v. O'Malley (4th Cir.)
14-1945
IN THE UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
STEPHEN KOLBE, et al.,
PLAINTIFFS-APPELLANTS
v.
MARTIN J. OMALLEY, et al.,
DEFENDANTS-APPELLEES
ON APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
No. 1:13-cv-02841-CCB (Hon. Catherine C. Blake)
MOTION OF TRADITIONALIST YOUTH NETWORK, LLC, FOR LEAVE
TO PARTICIPATE AS AMI CUS CURI AE
BRISTOW LAW, PLLC THE VAN DYKE LAW FIRM, PLLC
Kyle J. Bristow, Esq. Jason Van Dyke, Esq.
P.O. Box 1954 200 Chisholm Pl., #250
Clarkston, MI 48347 Plano, TX 75075
(P): (567) 694-5953 (P): (469) 964-5346
(E): [email protected] (F): (972) 421-1830
(W): www.KyleBristow.com (E): [email protected]
Ohio S. Ct. #89543 (W): www.VanDykeLawFirm.com
Mich. State Bar #P77200 Tex. State Bar #24057426
Lead Counsel for Amicus Curiae Co-Counsel for Amicus Curiae
Traditionalist Youth Network, LLC Traditionalist Youth Network, LLC
Appeal: 14-1945 Doc: 18 Filed: 09/24/2014 Pg: 1 of 40
1
I. INTRODUCTION
Pursuant to Fed. R. App. P. 29, the Traditionalist Youth Network, LLC,
hereby respectfully moves for leave to file the attached brief as amicus curiae in
support of Plaintiffs-Appellants. This motion is accompanied by the Traditionalist
Youth Network, LLCs proposed brief as is required by Fed. R. App. P. 29(b).
II. ARGUMENT
A. Traditionalist Youth Network, LLCs Interests
The Traditionalist Youth Network, LLC, is a limited liability company
existing by and through the laws of the State of Michigan, and it is nationally
recognized as a staunch advocate of traditionalism. Its members have engaged in
political discourse and have promoted traditionalism by publishing commentary on
the organizations websitewww.TradYouth.org, by organizing and
participating in public demonstrations, and by being invited to and speaking at
events organized by other similarly-minded organizations.
Even though the Traditionalist Youth Network, LLC, was only founded as
recently as July of 2013, it has quickly become one of the fiercest defenders of
traditional values in the United States of Americaits members have appeared in
televised national news stories and people throughout the country have expressed
an interest in creating chapters of the organization in their own states.
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2
In short, the Traditionalist Youth Network, LLC, is to the United States of
America what Gnration Identitaire is to France: it is an extremely active pro-
European socio-political identity movement that was founded and is controlled by
concerned and well-informed young activists.
As an organization that vigorously advocates traditionalism, the
Traditionalist Youth Network, LLC, strongly opposes any attempt by
governmental actors to infringe upon the traditional right of our people to keep and
bear arms. As such, the Traditionalist Youth Network, LLC, would like to submit
the attached amicus curiae brief to support Plaintiffs-Appellants who will argue
that Marylands ban on assault weapons by the citizenry is flagrantly
unconstitutional and that the district courts judgment should be reversed as a
matter of law.
B. Reasons Why An Amicus Curiae Brief From Traditionalist Youth
Network, LLC, Is Desirable And Relevant To The Disposition Of The Case
The Traditionalist Youth Network, LLCs amicus curiae brief is both
relevant and desirable. See Fed. R. App. P. 29(b)(2).
When it comes to the Traditionalist Youth Network, LLC, its mission is
tradition, and since the district courts opinion is an affront to the traditional right
of our people to keep and bear weapons, the Traditionalist Youth Network, LLC,
believes that it is critically important for its organization to become involved in the
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3
case by way of it submitting an amicus curiae brief to support Plaintiffs-
Appellants.
An amicus curiae brief from the Traditionalist Youth Network, LLC, is
desirable insofar as the brief argues that government enjoys not the power to
infringe upon the natural law right of our people to keep and bear arms, and the
brief delves into what constitutes arms as far as the judicial philosophies of
textualism and originalism are concerned. As was said by one learned individual,
Most contemporary scholars, whether they call themselves originalists or not,
believe that constitutional meaning should be derived, at least in part, from the
understanding of those who framed and ratified the constitutional text. David
Yaskky, The Second Amendment: Structure, History, and Constitutional Change,
99 Mich. L. Rev. 588, 593 (2000).
Although Plaintiffs-Appellants are expected to make somewhat similar
arguments in the instant appeal, the Traditionalist Youth Network, LLCs brief is
desirable and relevant to the disposition of the case insofar as it presents its
argument by extrapolating and analyzing traditional legal principles by exploring
the history of the American nation-state as it pertains to private citizens possessing
weapons of war. In short, the Traditionalist Youth Network, LLCs brief presents
an argument that could very well be omitted from the briefs of the parties to this
case since it is vogue for litigants to either be politically correct and avoid the real
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4
issues at play or invoke postmodern sentiment to usurp the rights guaranteed by the
United States Constitution.
While Plaintiffs-Appellants will likely not say it as bluntly as this, the
Culture Distorters and those who espouse their ideals flagrantly reject originalism
and often treat the United States Constitution like an accordion: they frequently
stretch it out to invent rights that do not existsuch as the right to have an
abortion or the right to engage in sodomy or the right to view pornographic
materials, and they constrict it to not mean things that it certainly doessuch as
by denying the plain language of the Second Amendment to the United States
Constitution or by postulating that the First Amendment to the United States
Constitution does not protect so-called hate speech.
In essence, the Traditionalist Youth Network, LLC, would like to submit its
amicus curiae brief because shots are being fired in Americas Culture War and the
organization has the enemy of freedomthe Culture Distorterin its sights and
wishes to shoot down unconstitutional legislation that disarms our people.
III. CONCLUSION
For the reasons set forth supra, the Traditionalist Youth Network, LLC,
respectfully requests that this Court grant its motion to file the attached amicus
curiae brief.
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5
Respectfully submitted,
/s/ Kyle J. Bristow
Kyle J. Bristow, Esq.
Bristow Law, PLLC
P.O. Box 1954
Clarkston, MI 48347
(P): (567) 694-5953
(E): [email protected]
Ohio S. Ct. #89543
Mich. State Bar #P77200
Lead Counsel for Amicus Curiae
Traditionalist Youth Network, LLC
Dated: September 24, 2014
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6
CERTIFICATE OF SERVICE
I hereby certify that on September 24, 2014, the foregoing Motion of
Traditionalist Youth Network, LLC, for Leave to Participate as Amicus Curiae was
electronically filed throughout the Courts CM/ECF system, which should be sent
to all registered parties by operation of said electronic filing system.
/s/ Kyle J. Bristow
Kyle J. Bristow, Esq.
Bristow Law, PLLC
P.O. Box 1954
Clarkston, MI 48347
(P): (567) 694-5953
(E): [email protected]
Ohio S. Ct. #89543
Mich. State Bar #P77200
Lead Counsel for Amicus Curiae
Traditionalist Youth Network, LLC
Dated: September 24, 2014
Appeal: 14-1945 Doc: 18 Filed: 09/24/2014 Pg: 7 of 40
1
No. 14-1945
IN THE UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
STEPHEN KOLBE, et al.,
PLAINTIFFS-APPELLANTS
v.
MARTIN J. OMALLEY, et al.,
DEFENDANTS-APPELLEES
ON APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
No. 1:13-cv-02841-CCB (Hon. Catherine C. Blake)
AMICUS CURIAE BRIEF OF TRADITIONALIST YOUTH NETWORK,
LLC, IN SUPPORT OF APPELLANTS AND URGING REVERSAL
BRISTOW LAW, PLLC THE VAN DYKE LAW FIRM, PLLC
Kyle J. Bristow, Esq. Jason Van Dyke, Esq.
P.O. Box 1954 200 Chisholm Pl., #250
Clarkston, MI 48347 Plano, TX 75075
(P): (567) 694-5953 (P): (469) 964-5346
(E): [email protected] (F): (972) 421-1830
(W): www.KyleBristow.com (E): [email protected]
Ohio S. Ct. #89543 (W): www.VanDykeLawFirm.com
Mich. State Bar #P77200 Tex. State Bar #24057426
Lead Counsel for Amicus Curiae Co-Counsel for Amicus Curiae
Traditionalist Youth Network, LLC Traditionalist Youth Network, LLC
Appeal: 14-1945 Doc: 18 Filed: 09/24/2014 Pg: 8 of 40
10/28/2013 SCC - 1 -
UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
DISCLOSURE OF CORPORATE AFFILIATIONS AND OTHER INTERESTS
Disclosures must be filed on behalf of all parties to a civil, agency, bankruptcy or mandamus
case, except that a disclosure statement is not required from the United States, from an indigent
party, or from a state or local government in a pro se case. In mandamus cases arising from a
civil or bankruptcy action, all parties to the action in the district court are considered parties to
the mandamus case.
Corporate defendants in a criminal or post-conviction case and corporate amici curiae are
required to file disclosure statements.
If counsel is not a registered ECF filer and does not intend to file documents other than the
required disclosure statement, counsel may file the disclosure statement in paper rather than
electronic form. Counsel has a continuing duty to update this information.
No. __________ Caption: __________________________________________________
Pursuant to FRAP 26.1 and Local Rule 26.1,
______________________________________________________________________________
(name of party/amicus)
______________________________________________________________________________
who is _______________________, makes the following disclosure:
(appellant/appellee/petitioner/respondent/amicus/intervenor)
1. Is party/amicus a publicly held corporation or other publicly held entity? YES NO
2. Does party/amicus have any parent corporations? YES NO
If yes, identify all parent corporations, including grandparent and great-grandparent
corporations:
3. Is 10% or more of the stock of a party/amicus owned by a publicly held corporation or
other publicly held entity? YES NO
If yes, identify all such owners:
14-1945 Stephen Kolbe v. Martin J. O'Malley
Traditionalist Youth Network, LLC
amicus