Motion for Leave of Court to File Brief as Amicus Curiae and For Leave to Participate in Oral Argument as Amicus Curiae; Memorandum in Support of Motion for Leave of Court to File Brief as Amicus Curiae; Motion for Leave to Participate in Oral Argument by Amicus Curiae; Motion for Leave to File Brief as Amicus Curiae; Amicus Curiae Brief Submitted by Pascal F. Calogero, Jr.-