Notice of Motion of Catholic Theologians for Leave to File Brief
COURT OF APPEALS OF THE STATE OF NEW YORK In the Matter of a Proceeding under Article 70 of the CPLR App. Div. Case No.: 2020- for a Writ of Habeas Corpus and Order to Show Cause, 02581 THE NONHUMAN RIGHTS PROJECT, INC., on behalf Index No.: 260441/2019 of HAPPY, (Bronx County) Petitioner-Appellant, NOTICE OF MOTION OF CATHOLIC -against- THEOLOGIANS FOR LEAVE TO FILE BRIEF JAMES J. BREHENY, in his official capacity as the AS AMICI CURIAE IN Executive Vice President and General Director of Zoos SUPPORT OF and Aquariums of the Wildlife Conservation Society and PETITIONER- Director of the Bronx Zoo, and WILDLIFE APPELLANT’S CONSERVATION SOCIETY, MOTION FOR PERMISSION TO Respondents-Respondents. APPEAL PLEASE TAKE NOTICE that, upon the annexed affirmation of David M. Lindsey, dated January 29, 2021, and the papers attached thereto, the undersigned will move this Court, on behalf of John Berkman, PhD (University of Toronto), Charles Camosy, PhD (Fordham University), Allison Covey, PhD (Villanova University), Celia Deane-Drummond, PhD (University of Notre Dame, University of Oxford), and Christopher Steck, SJ, PhD (Georgetown University) (hereinafter collectively referred to as “Catholic Theologians”), for an order granting the Catholic Theologians’ motion for leave to file the attached brief as Amici Curiae in support of the Petitioner-Appellant Nonhuman Rights Project, Inc. (“NhRP”) in its 1 BY REGULAR MAIL TO: Clerk of the Court of Appeals New York State Court of Appeals 20 Eagle Street Albany, New York 11207 PHILIPS LYTLE LLP Kenneth A. Manning Joanna J. Chen William V. Rossi One Canalside 125 Main Street Buffalo, New York 14203 Tel.
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