Strang JF, Janssen A, Tishelman A, Leibowitz SF, Kenworthy L, McGuire JK, Edwards-Leeper L, Mazefsky CA, Rofey D, Bascom J, Caplan R, Gomez- Lobo V, Berg D, Zaks Z, Wallace GL, Wimms H, Pine-Twaddell E, Shumer DE, Register-Brown K, Sadikova E, Anthony LG: Revisiting the Link: Evidence of the Rates of Autism in Studies of Gender Diverse Individuals, Journal of the American Academy of Child and Adolescent Psychiatry.57(11): 885-887, 11/2018.

Adkins V, Masters E, Shumer D, Selkie E: Exploring Transgender Adolescents Use of Social Media for Support and Health Information Seeking (Poster Presentation), Pediatric Research Symposium, Ann Arbor, MI, 2017 Exhibit B Bibliography

Coleman, E., Radix, A. E., Bouman, W. P., Brown, G. R., de Vries, A. L. C., Deutsch, M. B., Ettner, R., Fraser, L., Goodman, M., Green, J., Hancock, A. B., Johnson, T. W., Karasic, D. H., Knudson, G. A., Leibowitz, S. F., Meyer- Bahlburg, H. F. L., Monstrey, S. J., Motmans, J., Nahata, L., Nieder, T. O., … Arcelus, J.

de Block, C.J.M., Wiepjes, C.M., Nota, N.M., van Engelen, K., Adank, M.A., Dreijerink, K.M.A., Barbé, E., Konings, I.R.H.M., den Heijer, M. (2019), Breast Cancer Risk in Transgender People Receiving Hormone Treatment: Nationwide Cohort Study in the Netherlands, BMJ, 2019;365:l1652.

Manieri, C., Castellano, E., Crespi, C., Di Bisceglie, C., Dell’Aquila, C., Gualerzi, A., & Molo, M. (2014) Medical Treatment of Subjects with Gender Identity Disorder: The Experience in an Italian Public Health Center, International Journal of Transgenderism, 15:2, 53–65.

Many other medications (such as beta blockers or birth control pills) can also affect mood, but none are subject to a similar requirement that an adult patient be under the care of a licensed mental health professional for that reason.

Plaintiffs Kai Pope, Lucien Hamel, Olivia Noel and Rebecca Cruz Evia (collectively, “Adult Plaintiffs”) have moved this Court for a preliminary injunction pursuant to Rule 65(a)(1) of the Federal Rules of Civil Procedure, seeking to block enforcement of the targeted restrictions on medical care for adult transgender people in Florida Senate Bill 254, an “act relating to treatments for sex reassignment .

SB 254 imposes arbitrary, harmful, and medically unjustified requirements on the provision of transition-related care for transgender people, including requiring physicians to be physically present in the same room with a transgender patient when obtaining consent, requiring providers to provide transgender patients with a mandatory consent form that includes false and misleading information, requiring providers to deny care to transgender patients unless they undergo extremely burdensome and unnecessary mental health evaluations and counseling, and providing that only a licensed physician (i.e., a licensed medical doctor (an “MD”) or licensed doctor of osteopathic medicine (a “DO”) can provide transition-related medical care.

The Court, having considered the pleadings, legal authority, and argument presented in support of Plaintiffs’ Motion, as well as all declarations and other evidence submitted in support of Plaintiffs’ prior Motion for a preliminary injunction, has found and concluded for the specific reasons required under Federal Rule of Civil Procedure 65 that Plaintiffs have demonstrated: (1) a likelihood of success on the merits, (2) irreparable harm in the absence of preliminary relief, (3) the equities weigh in favor of the Plaintiffs, and (4) that granting preliminary relief is in the public interest.

Plaintiffs have demonstrated that, absent a preliminary order preventing SB 254 from taking effect, they will be denied medical care and suffer irreparable constitutional, physical, emotional, psychological, and other harms for which there is no adequate remedy at law.

The provisions of SB 254, if permitted to go into effect, will prevent Plaintiffs from obtaining the essential medical care they need.

Notice is hereby given that Plaintiffs in the above-captioned case appeal to the United States Court of Appeals for the First Circuit from this Court’s December 14, 2022, Order granting Defendants’ Motion to Dismiss [Doc. 51].

Respectfully submitted,

Fee: Paid?

Yes ____ No ____ Government filer ____ In Forma Pauperis Yes ____ No ____ Motions Pending If yes, document # Yes ____ No ____

Transcripts If yes, document # Yes ____ No ____ Notice of Appeal filed by: Plaintiff/Petitioner ____ Defendant/Respondent ____ Other: ____ Appeal from: #51 Order on Motion to Dismiss Other information: I, Robert M. Farrell, Clerk of the United States District Court for the District of Massachusetts, do hereby certify that the annexed electronic documents: #51 and #52 with the electronic docket sheet, constitute the abbreviated record on appeal in the above entitled case for the Notice of Appeal # ________ filed on__________________.

January 11, 2023 January 11, 2023 In testimony whereof, I hereunto set my hand and affix the seal of this Court on _____________.

Nonetheless, defendants will waive service of process in the event that the instant motion is allowed.

Motion for Admission Pro Hac Vice of Mary E. McAlister Pursuant to L.R.D.

83.5.3, attorney Andrew Beckwith, a member in good standing of the Bar of the Commonwealth of Massachusetts and the United States District Court for the District of Massachusetts, who has filed an appearance in this case on behalf of Plaintiffs, respectfully moves this Court to admit attorney Mary E. McAlister to appear and practice in this Court in the above-styled case.

As set forth in her Declaration, attached hereto as Exhibit A: (1) Ms. McAlister is a member of the bar in good standing in every jurisdiction in which she has been admitted to practice; (2) Ms. McAlister is not the subject of disciplinary proceedings pending in any jurisdiction in which she is a member of the bar; (3) Ms. McAlister has not previously had a pro hac vice admission to this court (or other admission for a limited purpose under L.R.D.

83.5.3, and for good cause shown, the undersigned counsel respectfully requests that this motion be granted, and that Mary E. McAlister be permitted to appear and practice in this Court as co-counsel for Plaintiffs in the above-styled case.

I am Senior Litigation Counsel for Child & Parental Rights Campaign at 5805 State Bridge Rd., Suite G310 Johns Creek, GA 30097.

Motion for Admission Pro Hac Vice of Vernadette R. Broyles Pursuant to L.R.D.

83.5.3, attorney Andrew Beckwith, a member in good standing of the Bar of the Commonwealth of Massachusetts and the United States District Court for the District of Massachusetts, who has filed an appearance in this case on behalf of Plaintiffs, respectfully moves this Court to admit attorney Vernadette R. Broyles to appear and practice in this Court in the above-styled case.

As set forth in her Declaration, attached hereto as Exhibit A: (1) Ms. Broyles is a member of the bar in good standing in every jurisdiction in which she has been admitted to practice; (2) Ms. Broyles is not the subject of disciplinary proceedings pending in any jurisdiction in which she is a member of the bar; (3) Ms. Broyles has not previously had a pro hac vice admission to this court (or other admission for a limited purpose under L.R.D.

83.5.3, and for good cause shown, the undersigned counsel respectfully requests that this motion be granted, and that Vernadette R. Broyles be permitted to appear and practice in this Court as co-counsel for Plaintiffs in the above-styled case.

I am President and General Counsel for Child & Parental Rights Campaign, Inc. at 5805 State Bridge Rd., Suite G310 Johns Creek, GA 30097.

Plaintiffs Foote and Silvestri are informed and believe and based thereon allege that during the planning meeting on March 10, 2021 Defendant Foley told the teachers present that the law says that school staff do not have to tell parents about their children’s requests to change their name or otherwise socially affirm a student’s asserted transgender identity.

Plaintiffs Foote and Silvestri are informed and believe and based thereon allege that on March 11, 2021, Defendant Foley told B.F. in an online chat that B.F. was “brave and awesome” for telling her teachers and guidance counselor that she was “genderqueer” and wanted to be referred to by the name “R.” 68.

As to Plaintiffs Feliciano and Salmeron, Defendants’ conduct also infringes on their sincerely held religious beliefs which include respect for parental authority, truthfulness, and adherence to a Biblical understanding of male and female and standards of behavior.

Defendants have explicitly evidenced their hostility and intent to infringe upon family privacy through public statements that Defendants’ schools are the only safe space for many children and that parental concerns about children’s assertions of discordant gender identities are rooted in bigotry.

Defendants cannot assert a compelling state interest for recklessly disregarding Plaintiffs’ constitutional rights to familial privacy, and Defendants’ prohibitions against parental notification and involvement in children’s mental health decisions related to gender identity are not narrowly tailored.

Plaintiffs Foote and Silvestri are informed and believe and based thereon allege that during the planning meeting on March 10, 2021 Defendant Foley told the teachers present that the law says that school staff do not have to tell parents about their children’s requests to change their name or otherwise socially affirm a student’s asserted transgender identity.

Plaintiffs Foote and Silvestri are informed and believe and based thereon allege that on March 11, 2021, Defendant Foley told B.F. in an online chat that B.F. was “brave and awesome” for telling her teachers and guidance counselor that she was “genderqueer” and wanted to be referred to by the name “R.” 68.

As to Plaintiffs Feliciano and Salmeron, Defendants’ conduct also infringes on their sincerely held religious beliefs which include respect for parental authority, truthfulness, and adherence to a Biblical understanding of male and female and standards of behavior.

Defendants have explicitly evidenced their hostility and intent to infringe upon family privacy through public statements that Defendants’ schools are the only safe space for many children and that parental concerns about children’s assertions of discordant gender identities are rooted in bigotry.

Defendants cannot assert a compelling state interest for recklessly disregarding Plaintiffs’ constitutional rights to familial privacy, and Defendants’ prohibitions against parental notification and involvement in children’s mental health decisions related to gender identity are not narrowly tailored.

Plaintiffs, by and through their counsel of record, submit this notice to alert the Court of the following decision that bears on Defendants’ Motion to Dismiss the First Amended Complaint, Tatel v. Mt.

Lebanon School District, W.D.

of Pennsylvania Case No. 2:22-cv-00837-JFC Opinion on Motion to Dismiss, Document 38, filed 10/27/22, attached hereto as Exhibit 1.

Dated: November 7, 2022.

of Sci., Eng’g, & Med., Understanding the Well-Being of LGBTQI+ Populations, at 2-7 (2020), available at http:nap.edu/25877 and Stephen T. Russell et al., Chosen Name Use is Linked to Reduced Depressive Symptoms, Suicidal Ideation and Behavior Among Transgender Youth, 63 J. Adolescent Health 503, 504 (2018).

If for no other reason, this Court should allow Plaintiffs’ claims to proceed beyond the motion to dismiss stage to allow Plaintiffs to further develop through mental health experts the potential detrimental effects of social transitioning minor children.

13 Quoting Stephen T. Russell et al., Chosen Name Use is Linked to Reduced Depressive Symptoms, Suicidal Ideation and Behavior Among Transgender Youth, 63 J. Adolescent Health 503, 504 (2018).

In most cases involving a claim that a state actor violated a plaintiff’s substantive due process rights, the shock-the-conscience standard requires a plaintiff to show that the defendant’s actions amounted to “a brutal and inhumane abuse of official power literally shocking to the conscience.” Gonzalez-Fuentes v. Molina, 607 F.3d 864, 881 (1st Cir. 2010).

At the school committee meeting on June 8, 2021, superintendent Gazda stated, “Right now we have a situation where intolerance, prejudice and bigotry against LGBTQ individuals by members of our community is being thinly veiled behind a camouflage of what is being asserted as ‘parental rights.’” Def’s Reply Mem.

Please take notice and enter the appearance of Carl F. Schmitt, as counsel for amicus curiae, Family Institute of Connecticut.

Please enter the appearance of Gary D. Buseck as counsel for amici curiae, GLBTQ Legal Advocates & Defenders and the Massachusetts Association of School Superintendents.

Please enter the appearance of Mary L. Bonauto as counsel for amici curiae, GLBTQ Legal Advocates & Defenders and the Massachusetts Association of School Superintendents.