In the face of our country’s history of racism, its pervasive structural discrimination, and the pernicious effects of both, Plaintiff attempts to upend the spirit and the purpose of § 1981 to further entrench the status quo of inequitable market access.

The inability to build wealth or own property forced Black people into sharecropping, where landowners subjected them to debt when the growing season closed, with no hope of recourse against the ever-present manipulation of the ledger.

The reason is straightforward: Congress never intended to undermine remedial efforts that empower Black citizens to gain greater economic power and contract rights than they could achieve or exercise as a result of anti-Black discrimination.

In Setser v. Novack Investment Co., the court held, “[i]t would indeed be ... ironic if the Civil Rights Act of 1866 was used now to prohibit” § 1981, “the only effective remedy for past discriminatory employment practices against blacks and other minorities[.

It found that Kamehameha Schools’ program was “a remedial policy[,]” not a “straightforward case of discrimination,” that considered students’ race to address manifest imbalances between educational outcomes for Native Hawaiian students and their counterparts.

FEARLESS FUND II, LP; and

This matter having come before the Court by motion of proposed amicus curiae Lawyers’ Committee for Civil Rights Under Law, seeking leave to file an amicus brief in the above captioned matter, and the Court having reviewed the file and pleadings herein, and being otherwise fully advised in the matter, hereby finds good cause to allow amicus participation.

The Motion for Leave to File Amicus Curiae Brief by Lawyers’ Committee for Civil Rights Under Law in Support of Defendants’ Opposition to Plaintiff’s Emergency Motion for Temporary Restraining Order and Preliminary Injunction is hereby GRANTED.

IT IS SO ORDERED this ___ day of ___________, 2023.

04/21) The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court.

This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet.

410 Antitrust 430 Banks and Banking 820 Copyrights 450 Commerce 830 Patent 460 Deportation 835 Patent - Abbreviated 470 Racketeer Influenced and New Drug Application Corrupt Organizations 840 Trademark 480 Consumer Credit 880 Defend Trade Secrets (15 USC 1681 or 1692) Act of 2016 485 Telephone Consumer Protection Act 490 Cable/Sat TV 850 Securities/Commodities/ Exchange 890 Other Statutory Actions 891 Agricultural Acts 893 Environmental Matters 895 Freedom of Information Act 896 Arbitration 899 Administrative Procedure Act/Review or Appeal of Agency Decision 950 Constitutionality of State Statutes

110 Insurance 120 Marine 310 Airplane 365 Personal Injury - 130 Miller Act 315 Airplane Product Product Liability 140 Negotiable Instrument Liability 367 Health Care/ 150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical & Enforcement of Judgment Slander Personal Injury 151 Medicare Act 330 Federal Employers’ Product Liability 152 Recovery of Defaulted Liability 368 Asbestos Personal Student Loans 340 Marine Injury Product (Excludes Veterans) 345 Marine Product Liability

Habeas Corpus: 463 Alien Detainee 510 Motions to Vacate Sentence 530 General 535 Death Penalty Other: 540 Mandamus & Other 550 Civil Rights 555 Prison Condition 560 Civil Detainee - Conditions of Confinement V. ORIGIN (Place an “X” in One Box Only) 1 Original 2 Removed from Proceeding State Court 5 Transferred from Another District (specify) Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity): 42 USC Section 1981 Brief description of cause: Claim for racial discrimination in making contracts in violation of Section 1981

2023 Fearless Strivers Grant Contest - Fearless Fund Log In 2023 Fearless Strivers Grant Contest Opens Feb 6 2023 12:00 AM (EST) Deadline Aug 31 2023 11:59 PM (EDT) Description Black women-owned businesses are vital to our economy yet receive less than one percent of venture capital funding.

With Mastercard prizing, we’ll be awarding four lucky small businesses across the country with $20,000 grants, digital tools to help them grow their business online, and mentorship so they can continue to bolster their business.

Don’t miss your opportunity, simply complete the entry form for your chance to win.

Open to black women who are legal U.S. residents (including DC), 18+ and the principal owner of a U.S.- based small business.

Program Eligibility •Business must be at least 51% black woman owned •Revenue generating (Minimum annual revenue of $50,000 strongly preferred) •Formed under United States law and operating in the United States The Grant Contest (there will be one winner selected per entry period) •Grantees will receive $20,000 in grants to go towards business growth; •Digital tools to help them grow their business online; and •Mentorship Entry Period Dates (there will be one winner selected per entry period) •2/1/23 – 2/22/23 •4/1/23 – 4/30/23 •6/1/23 – 6/30/23 •8/1/23 – 8/31/23