IN THE UNITED STATES DISTRICT COURT
                                 FOR THE DISTRICT OF COLORADO


Civil Action No. 01-B-1854


LAWRENCE GOLAN, et. al.

                 Plaintiffs,

v.

JOHN ASHCROFT, in his official
capacity as Attorney General of the
United States

                 Defendant.

                                DEFENDANT'S MOTION TO DISMISS

       Pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure, defendant John

Ashcroft, Attorney General of the United States, respectfully moves this Court for judgment in

favor of defendant on the ground that the Complaint fails to state a claim upon which relief can

be granted.  The grounds in support of this motion are more fully set out in the attached

memorandum.

                                                     Respectfully submitted,

                                                     ROBERT D. McCALLUM, JR. 
                                                     Assistant Attorney General

                                                     JOHN W. SUTHERS
                                                     United States Attorney

                                                     VINCENT M. GARVEY
                                                     Deputy Branch Director

                                                     _________________________
                                                     JOSHUA Z. RABINOVITZ
                                                     Attorneys for Defendant



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