Freedom of Conscience Defense Fund Inc

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“- Beginning $0 - Ending $0”

“FCDFs Bylaws were amended to reflect that effective July 15, 2020, the Directors of FCDF would be elected by Thomas More Society, whose purposes are similar to those of FCDF and that is also exempt from federal income tax under Section 501(c)(3).”

“PART III, LINE 28Freedom of Conscience Defense FundDefending Religious Freedom and the American ConstitutionCases for the Year Ending 06-30-21National Abortion Federation v. Center for Medical Progress, et al.In July 2015, the Center for Medical Progress began releasing the results of its 30-month investigative journalism study, the Human Capital Project, which documented abuses and illegalities in the fetal tissue procurement industry. The Human Capital Projects findings spurred numerous state and federal investigations into fetal tissue procurement companies and abortion providers. It also caused over a dozen states and the United States Congress to vote to withdraw taxpayer funding from the abortion provider Planned Parenthood. In that same month, the National Abortion Federation (NAF) filed suit against the Center for Medical Progress, David Daleiden, BioMax Procurement Services, LLC and Troy Newmana former board member. FCDF is not representing Mr. Newman who retained separate counsel and has since been dismissed from the case. NAF is a trade group for abortion providers. It successfully sought a preliminary injunction preventing the Center for Medical Progress from releasing videos regarding NAF conferences. FCDF appealed the order granting that preliminary injunction, which was upheld at the Ninth Circuit. FCDF petitioned for certiorari at the United States Supreme Court, but that petition was denied. When the mandate issued from the Ninth Circuit, FCDF began preparing to respond to the complaint. NAF requested that the District Court permit it to file an early motion for summary judgment solely with respect to its contract claim (upon which the preliminary injunction is predicated), but that request was denied. In response, NAF dismissed the majority of its claims, leaving only a few state-law tort claims. FCDF responded to the complaint by filing an anti-SLAPP motion. At the same time, FCDF filed a motion to dismiss the complaint, including for lack of diversity jurisdiction. FCDF further filed a motion to dissolve the preliminary injunction on the basis of changed facts. Those facts include that several Congressional investigations concluded that numerous NAF members were selling fetal tissue for profit, multiple tissue procurements companies have been successfully prosecuted, and the new criminal prosecution of Mr. Daleiden. Those motions were denied, and FCDF appealed the denial to the Ninth Circuit. That appeal resulted in an affirmance of the District Court, and the case was sent back down.The parties then engaged in briefing regarding the proper scope of any discovery. The District Court instructed NAF to file its motion for summary judgment and entry of a permanent injunction, with FCDF instructed to then file a letter outlying what discovery is needed. Ultimately, the District Court declined to permit FCDF to engage in any meaningful discoveryonly depositions of two declarants whose declarations NAF submitted with its motion for summary judgment. In the spring of 2021, FCDF took those declarants depositions. In April and May 2021, the District Court granted NAFs motion for summary judgment and entered a permanent injunction. FCDF has appealed the final judgment to the Ninth Circuit. FCDFs opening brief on appeal is due in September 2021.The public interest is being served by protecting freedom of conscience.Planned Parenthood Federation of America, et al. v. Center for Medical Progress, et al.Planned Parenthood Federation of America, its seven California affiliates, one Colorado affiliate, and two Texas affiliates, waited until January 2016 to file suit against the Center for Medical Progress, David Daleiden, BioMax Procurement Services, LLC, Gerardo Adrian Lopezan investigative journalist and actorand numerous other parties represented by separate counsel. This suit was filed soon after Congress voted to withdraw federal funding from Planned Parenthood as a result of the Human Capital Project. In response to”

“PART III, LINE 28Freedom of Conscience Defense FundDefending Religious Freedom and the American ConstitutionCases for the Year Ending 06-30-21 (continued)Department of Fair Employment & Housing v. Catharine Miller and Tastries BakeryOn August 26, 2017, Catharine Miller welcomed Mireya and Eileen Rodriguez-Del Rio into her bakery, Tastries. She soon discovered, however, that the Rodriguez-Del Rios were seeking to commission her to create a custom-wedding cake to celebrate and promote a same-sex marriage. As a result, she informed them that she could not create the custom art, and that instead she would be referring their requested commission to another cake artist. That same day, the Rodriguez-Del Rios began publicizing the encounter on social media, and it garnered widespread media attentionincluding with the offer from other wedding professionals to provide services free of charge. As a result, the Department of Fair Employment and Housing (DFEH) began investigating Ms. Miller and brought an action against her on December 14, 2017.On February 5, 2018, the Court denied the DFEHs request for a preliminary injunction, and later entered a final judgment in Ms. Millers favor on May 1, 2018. The DFEH then argued that its request for a preliminary injunction was a unique special proceeding, and so it was not bound by the Courts order, and retained the ability to investigate Ms. Miller in an administrative proceeding. FCDF filed a motion to enforce the judgment by limiting the DFEHs investigation. That motion was granted, but then stayed following a petition for writ of mandate to Californias Fifth District Court of Appeal. In October 2018, the DFEH began a new action that FCDF is defending. In June 2020, the trial court ordered the DFEH to produce its communications with the Rodriguez-Del Rios after concluding that the DFEH could not serve as their legal counsel. This ruling, despite following a binding opinion from the Fourth Appellate District, was then stayed by the Fifth Appellate District.In September 2020, the Fifth District Court of Appeal reversed the trial courts order enforcing its judgment, and affirmed the propriety of a second action. Depositions are scheduled for July and August 2021; trial is set for December 2021.The public interest is being served by protecting freedom of conscience.Skyline Wesleyan Church v. California Department of Managed HealthcareIn August 2014, the California Department of Managed Healthcare (CDMH) issued a mandate requiring all group health insurance plans in California to provide coverage for all legal abortions, including voluntary and elective abortions. Previously, organizations that did not want to provide insurance coverage for voluntary abortions could simply purchase health insurance that did not provide for it. This included numerous churches, non-profits, and other organizations of conscience.Through its new mandate, however, the CDMH unilaterally changed all of the contracts between churches and health insurance providers, and inserted coverage for voluntary abortions. The CDMH even tried to prevent health insurance providers from informing churches about the new coverage. Because the Federal Affordable Care Act requires employers to provide health insurance coverage, the California mandate now forces churches to pay for insurance that includes elective abortions. FCDF is representing Skyline Wesleyan Church in La Mesa, California in litigation challenging the CDMH regulations. In February 2018, the Court granted summary judgment in favor of the CDMH on the basis that Skyline did not exhaust its administrative remedies by seeking an exemption from the regulation prior to filing suit. In May 2020, the Ninth Circuit reversed and remanded, ordering the District Court to adjudicate the case on the merits, including Skyline Wesleyans First Amendment rights. The case is now proceeding on the merits.The public interest is being served by protecting freedom of conscience.South Bay United P”

“PART III, LINE 28Freedom of Conscience Defense FundDefending Religious Freedom and the American ConstitutionCases for the Year Ending 06-30-21 (continued)Grace Community Church of the Valley v. County of Los Angeles, et al.On Thursday, July 23, 2020, the Board of Elders of a famous, and very large Christian church in Los Angeles County, called Grace Community Church, voted unanimously to reopen its campus and church, and ignore Governor Newsoms and Los Angeles Countys orders to remain closed. The next Wednesday, July 29, 2020, the County of Los Angeles sent Grace Community Church a cease and desist letter, ordering it to close back down, and threatening it with legal action. That weekend, outside counsel for President Trump, Jenna Ellis, reached out to FCDF to see if we would represent the Church in bringing a lawsuit against Governor Newsom and Los Angeles County. On August 12, 2020, FCDF filed a civil rights action in the North Central District of Los Angeles County Superior Court. In response to the Churchs lawsuit, on August 14, 2020, Los Angeles County filed its own lawsuit in the Central District of Los Angeles County Superior Court. That same day, the County asked for an emergency order from the Court preventing the Church from holding worship services. The trial court (Judge Chalfant) refused to grant the County all of the relief it requested. The trial court ordered the Church to have its congregants practice social distancing and wear masks, but he refused to order the Church to not hold worship services inside the church building. But the next day, Saturday, August 15, 2020, Californias Second Appellate District overruled him. In the meantime, FCDF sought but was denied discovery to oppose the Countys OSC re: Preliminary Injunction. On August 28, the County issued a notice of eviction to Grace Community Church, providing thirty days notice that it was terminating its rental agreement for the churchs parking lot. On Thursday, September 10, 2020, the trial court (Judge Beckloff) granted the County of Los Angeles requested preliminary injunction. FCDF immediately appealed. Since the TRO Was entered on August 15, the Church had continued holding worship services. Thus, the County began attempting to have the Church held in contempt of court. On September 18, 2020, the County applied ex parte for an Order to Show Cause re: Contempt of Court and for Sanctions for violating the Courts Preliminary Injunction. That matter was initially heard by the all-purpose judge (Judge Alarcon), who ultimately referred it back to the writ judge (Judge Beckloff), who repeatedly put it off. On September 25, 2020, FCDF filed a First Amended Complaint in its action. That amended complaint maintained the claims previously asserted, but also added a claim for breach of the covenant of quiet enjoyment as a result of the Countys retaliatory eviction. On December 15, 2020, in light of a new watershed case from the Supreme Court, titled Roman Catholic Diocese of Brooklyn v. Cuomo, the County of Los Angeles and Grace Community Church entered into a stipulation whereby the County would not seek to enforce its preliminary injunction against Grace Community Church, the parties would continue the contempt hearing to a later date, and the parties would agree to a briefing schedule regarding vacatur of the preliminary injunction and the order to show cause re: contempt.On February 18, 2021, Grace Community Church filed before a motion to dissolve the preliminary injunction in light of Diocese of Brooklyn. While that motion was pending, the parties agreed to settle their lawsuits. Approval of that settlement agreement is now pending before the Los Angeles County Board of Supervisors.The public interest is being served by protecting freedom of conscience.Father Trevor Burfitt v. Governor Gavin Newsom, et al.In August 2020, Attorney Chris Ferrara reached out to FCDF about his interest in filing a new lawsuit challenging Governor Newsoms COVID-19 restriction”

“PART III, LINE 28Freedom of Conscience Defense FundDefending Religious Freedom and the American ConstitutionCases for the Year Ending 06-30-21 (continued)Charles Cox, et al., v. Erica Renfree, et al.Following widespread violent protests over the summer of 2020, which resulted in vandalism to numerous Catholic churches, shrines, and statutes, some extreme groups began calling for the removal of all references to the Apostle to California, St. Junpero Serra. In San Diego, the policies of the San Diego Unified School District provided that the names of its schools are permanent and cannot be changed. Nevertheless, sometime in the Fall of 2020 or Spring of 2021, the SDUSD Board of Trustees changed this policy, and then in March 2021, voted to change the name of Junipero Serra High School to Canyon Hills High School.In July 2021, FCDF brought suit on behalf of a group of concerned local residents, arguing that the name changewhich was rushed through with no local community inputviolated the procedural due process and establishment of religion guarantees of the federal and California constitutions. FCDF intends to immediately move for a preliminary injunction. The public interest is being served by protecting freedom of conscience.Citizens v. California Department of EducationEthnic studies are an interdisciplinary and comparative study of race and ethnicity with special focus on four historically defined racialized core groups: Native Americans, African Americans, Asian Americans, and Latina and Latino Americans. (Cal. Ed. Code, 89032 [AB 1460 (2020) legislative findings].) In March 2021, the California Department of Education promulgated a Model Curriculum on Ethnic Studies for various school districts to adopt. That model contains educational material of supposed interest to Latino Americans, including the In Lak Ech Affirmation. That affirmation is a chant requesting that traditional Aztec deities help the students grow in knowledge and self-awareness. FCDF intends to file a lawsuit challenging the inclusion of that affirmation in model materials as a violation of the prohibition on prayer in public schools. FCDF is still researching the issue.The public interest is being served by protecting freedom of conscience.”