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JOHN K. VINCENT United States Attorney KRISTIN S. DOOR, SBN 84307 Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, CA 95814 Tel: (916)554-2741 Fax: (916)554-2900
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[.'A.' " •-. 2001
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..CALIFORNIA

Attorneys for George W. Bush President of the United States
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
REV. DR. MICHAEL A. NEWDOW,   )    CIV. No. S-01-0218 LKK/GGH PS
) Plaintiff,     )    BRIEF IN SUPPORT OF MOTION
)    TO DISMISS WITH PREJUDICE v.                       )
) GEORGE W. BUSH, PRESIDENT OF  ) THE UNITED STATES,            )
)    DATE:     June 14, 2001 Defendant.     )    TIME:     10:00 a.m. )    COURTROOM:#24
I. INTRODUCTION
Plaintiff Michael Newdow has brought this action against George W. Bush, President of the United States.  Newdow seeks a declaration that President Bush violated the Establishment Clause of the First Amendment when he permitted the Reverend Franklin Graham to say a prayer at the inauguration on January 20, 2001. Newdow also seeks to enjoin the President from repeating this "or engaging in similar religious acts" and seeks to recover his costs, expert witness fees, and attorney fees.  Newdow does not seek to recover any damages.
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