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No. 04-15736
In the United States Court of Appeals for the Ninth Circuit
JOHN GILMORE,
Plaintiff-Appellant,
v.
JOHN ASHCROFT, et al.,
Defendants-Appellees.
On Appeal from the United States District Court for the
Northern District of California
Brief of Amicus Curiae Electronic Privacy Information Center in Support of
Plaintiff-Appellant, John Gilmore, Urging Reversal.
MARC ROTENBERG
MARCIA HOFMANN
ELECTRONIC PRIVACY
INFORMATION CENTER
1718 Connecticut Ave., NW
Suite 200
Washington, DC 20009
(202) 483-1140
Counsel for Amicus Curiae
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IN THE UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
)
JOHN GILMORE,
)
)
Plaintiff-Appellant,
)
No. 04-15736
)
v.
)
)
JOHN ASHCROFT, et al.,
)
)
Defendants-Appellees.
)
)
MOTION OF AMICUS CURIAE ELECTRONIC PRIVACY
INFORMATION CENTER FOR LEAVE TO FILE ACCOMPANYING
AMICUS BRIEF
Pursuant to Federal Rule of Appellate Procedure Rule 29(b), amicus curiae
Electronic Privacy Information Center (“EPIC”) requests leave to file the
accompanying amicus brief in support of Plaintiff-Appellant John Gilmore. This
brief urges reversal of the district court’s decision. All parties to this case have
consented to the filing of this brief.
EPIC is a public interest research center in Washington, D.C. that was
established to focus public attention on emerging civil liberties issues and to
protect privacy, the First Amendment, and other constitutional values. EPIC has
participated as amicus curiae in numerous privacy cases, including Hiibel v. Sixth
Judicial District Court of Nevada, 124 S. Ct. 2451 (2004), Doe v. Chao, 124 S. Ct.
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1204 (2004), Smith v. Doe, 538 U.S. 84 (2003), Department of Justice v. City of
Chicago, 537 U.S. 1229 (2003), Watchtower Bible and Tract Society of New York,
Inc., v. Village of Stratton, 536 U.S. 150 (2002), and Reno v. Condon, 528 U.S.
141 (2000).
In this case, EPIC argues that secret laws mandating compulsory
identification raise important constitutional questions. Furthermore, because of the
unique role of identity, such laws require meaningful judi