Form990EZ
Click to see list of attachments
Click to see list of attachments
Click to see list of attachments
Department of the Treasury
Internal Revenue Service
Short Form
Return of Organization Exempt From Income Tax
Under section 501(c), 527, or 4947(a)(1) of the Internal Revenue Code (except private foundations)
bullet Do not enter social security numbers on this form as it may be made public.


bullet Go to www.irs.gov/Form990EZ for instructions and the latest information.
OMB No. 1545-0047
2021
Open to Public
Inspection
A
For the 2021 calendar year, or tax year beginning 07-01-2021, and ending 06-30-2022
B
Check if applicable:
C Name of organization
FREEDOM OF CONSCIENCE DEFENSE FUND INC
 
Number and street (or P. O. box, if mail is not delivered to street address)309 W WASHINGTON STREET SUITE 1250
 
Room/suite
City or town, state or province, country, and ZIP or foreign postal code CHICAGO, IL60606
D Employer identification number

30-0741605
E Telephone number

(858) 759-9948
F Group Exemption
Numberbullet  
G Accounting Method: Other (specify) bullet   H Check bulletI Website:bulletWWW.CONSCIENCEDEFENSE.ORGJ Tax-exempt status (check only one) - Click to see attachment(   ) bullet (insert no.) or
K Form of organization:  
L Add lines 5b, 6c, and 7b to line 9 to determine gross receipts. If gross receipts are $200,000 or more, or if total assets (Part II, column (B) below) are $500,000 or more, file Form 990 instead of Form 990-EZ ...........................bullet $ 50,238
Part
Revenue, Expenses, and Changes in Net Assets or Fund Balances (see the instructions for Part I) Check if the organization used Schedule O to respond to any question in this Part I.....................
VerticalRevenue 1 Contributions, gifts, grants, and similar amounts received .................... 1 50,238
2 Program service revenue including government fees and contracts ................ 2  
3 Membership dues and assessments ............................. 3  
4 Investment income .................................... 4  
5a Gross amount from sale of assets other than inventory ....... 5a  
b Less: cost or other basis and sales expenses ............ 5b 0
c Gain or (loss) from sale of assets other than inventory (Subtract line 5b from line 5a) ...... 5c  
6 Gaming and fundraising events
a Gross income from gaming (attach Schedule G if greater than $15,000) 6a  
b Gross income from fundraising events (not including $   of contributions from fundraising events reported on line 1) (attach Schedule G if the sum of such gross income and contributions exceeds $15,000) ..6b 0
c Less: direct expenses from gaming and fundraising events ... 6c 0
d Net income or (loss) from gaming and fundraising events (add lines 6a and 6b and subtract line 6c) 6d  
7a Gross sales of inventory, less returns and allowances ...... 7a  
b Less: cost of goods sold ............. 7b 0
c Gross profit or (loss) from sales of inventory (Subtract line 7b from line 7a) ......... 7c  
8 Other revenue (describe in Schedule O) .................... 8  
9 Total revenue. Add lines 1, 2, 3, 4, 5c, 6d, 7c, and 8 .............. Bullet 9 50,238
.
VerticalExpenses 10 Grants and similar amounts paid (list in Schedule O) ................ 10 76,927
11 Benefits paid to or for members ...................... 11  
12 Salaries, other compensation, and employee benefits ................ 12  
13 Professional fees and other payments to independent contractors ............ 13 5,289
14 Occupancy, rent, utilities, and maintenance ................... 14  
15 Printing, publications, postage, and shipping ................... 15  
16 Other expenses (describe in Schedule O) ................... 16 10,834
17 Total expenses. Add lines 10 through 16 ................. Bullet 17 93,050
VerticalNetAssets 18 Excess or (deficit) for the year (Subtract line 17 from line 9) ............ 18 -42,812
19 Net assets or fund balances at beginning of year (from line 27, column (A)) (must agree with
end-of-year figure reported on prior year’s return) ................. 19 42,812
20 Other changes in net assets or fund balances (explain in Schedule O) ........... 20  
21 Net assets or fund balances at end of year. Combine lines 18 through 20 .......... 21  
For Paperwork Reduction Act Notice, see the separate instructions.
Cat. No. 10642I Form 990-EZ (2021)
Form 990-EZ (2021)
Page 2
Part Balance Sheets (see the instructions for Part II)Check if the organization used Schedule O to respond to any question in this Part II.................

(A) Beginning of year(B) End of year
22Cash, savings, and investments................
42,812
22
 
23Land and buildings....................
 
23
 
24Other assets (describe in Schedule O) ..........
 
24
 
25Total assets......................
42,812
25
0
26
Total liabilities (describe in Schedule O) .............
 
26
 
27Net assets or fund balances (line 27 of column (B) must agree with line 21)
42,812
27
0
Part Statement of Program Service Accomplishments (see the instructions for Part III) Check if the organization used Schedule O to respond to any question in this Part III . . Expenses
(Required for section 501(c)(3) and 501(c)(4) organizations; optional for others.)
What is the organization's primary exempt purpose? Provide grants for legal services to persons and organizations whose religious liberty and free speech rights have been violated
Describe the organization’s program service accomplishments for each of its three largest program services, as measured by expenses. In a clear and concise manner, describe the services provided, the number of persons benefited, and other relevant information for each program title.
28 Provide grants for legal services to persons and organizations whose religious liberty and free speech rights have been violated
(Grants $ 76,927) If this amount includes foreign grants, check here ...MediumBullet
28a 82,780
29
(Grants $   ) If this amount includes foreign grants, check here ...MediumBullet
29a
30
(Grants $   ) If this amount includes foreign grants, check here ...MediumBullet
30a
31 Other program services (describe in Schedule O) ................
(Grants $   ) If this amount includes foreign grants, check here...MediumBullet
31a
32 Total program service expenses (add lines 28a through 31a).......... bullet 32 82,780
Part
List of Officers, Directors, Trustees, and Key Employees (list each one even if not compensated ; see the instructions for Part IV)Check if the organization used Schedule O to respond to any question in this Part IV............
(a) Name and title (b) Average
hours per week
devoted to position
(c) Reportable compensation
(Forms W-2/1099-MISC) (if not paid, enter -0-)
(d) Health benefits, contributions to employee benefit plans, and
deferred compensation
(e) Estimated amount
of other compensation
THOMAS BREJCHA  
 
President
1.00 0    
THOMAS OLP  
 
Treasurer
1.00 0    
ANDY BATH  
 
VP/Secretary
1.00 0    
Form 990-EZ (2021)
Form 990-EZ (2021)
Page 3
Part
Other Information
(Note the Schedule A and personal benefit contract statement requirements in the
instructions for Part V.) Check if the organization used Schedule O to respond to any question in this Part V.......
Yes
No
33
Did the organization engage in any significant activity not previously reported to the IRS? If "Yes," provide a detailed description of each activity in Schedule O ...................
33
 
No
34
Were any significant changes made to the organizing or governing documents? If "Yes," attach a conformed copy of the amended documents if they reflect a change to the organization’s name. Otherwise, explain the changeon Schedule O. See instructions. ..........................
34
 
No
35a
Did the organization have unrelated business gross income of $1,000 or more during the year from business activities (such as those reported on lines 2, 6a, and 7a, among others)? ............
35a
 
No
b
If "Yes," to line 35a, has the organization filed a Form 990-T for the year? If "No," provide an explanation in Schedule O
35b
 
 
c
Was the organization a section 501(c)(4), 501(c)(5), or 501(c)(6) organization subject to section 6033(e) notice, reporting, and proxy tax requirements during the year? If "Yes," complete Schedule C, Part III
35c
 
No
36
Did the organization undergo a liquidation, dissolution, termination, or significant disposition of net assets during the year? If “Yes," complete applicable parts of Schedule N Click to see attachment................
36
Yes
 
37a
Enter amount of political expenditures, direct or indirect, as described in the instructions. bullet
37a
 
b
Did the organization file Form 1120-POL for this year?...................
37b
 
No
38a
Did the organization borrow from, or make any loans to, any officer, director, trustee, or key employee or were
any such loans made in a prior year and still outstanding at the end of the tax year covered by this return?..
38a
 
No
b
If “Yes," complete Schedule L, Part II and enter the total amount involved .
38b
 
39
Section 501(c)(7) organizations. Enter:
a
Initiation fees and capital contributions included on line 9.......
39a
 
b
Gross receipts, included on line 9, for public use of club facilities.....
39b
 
40a
Section 501(c)(3) organizations. Enter amount of tax imposed on the organization during the year under:
section 4911 bullet0 ; section 4912 bullet0 ; section 4955 bullet0
b
Section 501(c)(3), 501(c)(4), and 501(c)(29) organizations. Did the organization engage in any section 4958 excess benefit transaction during the year, or did it engage in an excess benefit transaction in a prior year that has not been reported on any of its prior Forms 990 or 990-EZ? If “Yes," complete Schedule L, Part I
40b
 
No
c
Section 501(c)(3), 501(c)(4), and 501(c)(29) organizations. Enter amount of tax imposed on organization managers or disqualified persons during the year under sections 4912, 4955, and 4958bullet0
d
Section 501(c)(3), 501(c)(4), and 501(c)(29) organizations. Enter amount of tax on line 40c reimbursed by the organizationbullet0
e
All organizations. At any time during the tax year, was the organization a party to a prohibited tax shelter transaction? If "Yes," complete Form 8886-T ................
40e
 
No
41List the states with which a copy of this return is filed. bulletCA
42a The organization's books are in care of bulletLAURA WRIGHT CPA
Telephone no.bullet (619) 993-0527


Located at bulletC/O TMS 309 W WASHINGTON ST STE 125CHICAGO, IL ZIP + 4 bullet60606
Yes
No
b
At any time during the calendar year, did the organization have an interest in or a signature or other authority over a financial account in a foreign country (such as a bank account, securities account, or other financial account)? . .
42b
 
No
If “Yes," enter the name of the foreign country: bullet
See the instructions for exceptions and filing requirements for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
c
At any time during the calendar year, did the organization maintain an office outside the U.S.? . . .
42c
 
No
If “Yes," enter the name of the foreign country: bullet
43...... bullet
and enter the amount of tax-exempt interest received or accrued during the tax year ....bullet43
 
Yes
No
44a
Did the organization maintain any donor advised funds during the year? If "Yes," Form 990 must be completed insteadof Form 990-EZ.............................
44a
 
No
b
Did the organization operate one or more hospital facilities during the year? If "Yes," Form 990 must be completedinstead of Form 990-EZ.............................
44b
 
No
c
Did the organization receive any payments for indoor tanning services during the year? .........
44c
 
No
d
If "Yes," to line 44c, has the organization filed a Form 720 to report these payments? If "No," provide an
explanation in Schedule O ............................
44d
 
 
45a
Did the organization have a controlled entity within the meaning of section 512(b)(13)?.........
45a
 
No
45b
Did the organization receive any payment from or engage in any transaction with a controlled entity within the meaning of section 512(b)(13)? If "Yes," Form 990 and Schedule R may need to be completed instead of Form 990-EZ (see instructions)......................
45b
 
No
Form 990-EZ (2021)
Form 990-EZ (2021)
Page 4
Yes
No
46
Did the organization engage, directly or indirectly, in political campaign activities on behalf of or in opposition to candidates for public office? If “Yes," complete Schedule C, Part I. ...........
46
 
No
Part
Section 501(c)(3) Organizations Only All section 501(c)(3) organizations must answer questions 47- 49b and 52, and complete the tables for lines 50 and 51. Check if the organization used Schedule O to respond to any question in this Part VI ..................
Yes
No
47
Did the organization engage in lobbying activities or have a section 501(h) election in effect during the tax year? If "Yes," complete Schedule C, Part II .......................
47
 
No
48
Is the organization a school as described in section 170(b)(1)(A)(ii)? If "Yes," complete Schedule E ..
48
 
No
49a
Did the organization make any transfers to an exempt non-charitable related organization?......
49a
 
No
b
If "Yes," was the related organization a section 527 organization?................
49b
 
 
50
Complete this table for the organization's five highest compensated employees (other than officers, directors, trustees and key employees) who each received more than $100,000 of compensation from the organization. If there is none, enter "None."
(a) Name and title of each employee (b) Average
hours per week
devoted to position
(c) Reportable compensation
(Forms W-2/1099-MISC)
(d) Health benefits, contributions to employee benefit plans, and deferred compensation (e) Estimated amount of other compensation
NONE
f
Total number of other employees paid over $100,000 .............bullet  

51
Complete this table for the organization's five highest compensated independent contractors who each received more than $100,000 of compensation from the organization. If there is none, enter "None."
(a) Name and business address of each independent contractor (b) Type of service (c) Compensation
NONE
d
Total number of other independent contractors each receiving over $100,000..........bullet  


52
Did the organization complete Schedule A? NOTE. All section 501(c)(3) organizations must attach a
completed Schedule A ........................................bullet

Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer (other than officer) is based on all information of which preparer has any knowledge.
Sign Here
JumboBullet
Signature of officer Date
JumboBullet
Type or print name and title
Paid Preparer Use Only
Print/Type preparer's name
Preparer's signature
Date
PTIN
Firm's name bullet

Firm's EIN bullet
Firm's address bullet



Phone no.
May the IRS discuss this return with the preparer shown above? See instructions .........bullet
Form 990-EZ (2021)

Additional Data


Software ID: 21013475
Software Version: 2021v4.1

Form 990-EZ, Special Condition Description:
Special Condition Description

SCHEDULE A
(Form 990)

Department of the Treasury
Internal Revenue Service
Public Charity Status and Public Support
Complete if the organization is a section 501(c)(3) organization or a section 4947(a)(1) nonexempt charitable trust.
right arrow Attach to Form 990 or Form 990-EZ.
right arrow Go to www.irs.gov/Form990 for instructions and the latest information.
OMB No. 1545-0047
2021
Open to Public
Inspection
Name of the organization
FREEDOM OF CONSCIENCE DEFENSE FUND INC
 
Employer identification number

30-0741605
Part I
Reason for Public Charity Status (All organizations must complete this part.) See instructions.
The organization is not a private foundation because it is: (For lines 1 through 12, check only one box.)
1
2
3
4
5
6
7
8
9
10
11
12
a
b
c
d
e
f
Enter the number of supported organizations ...............................  
g
Provide the following information about the supported organization(s).
(i) Name of supported organization (ii) EIN (iii) Type of organization (described on lines 1- 10 above (see instructions)) (iv) Is the organization listed in your governing document? (v) Amount of monetary support (see instructions) (vi) Amount of other support (see instructions)
Yes No
Total
 
   
For Paperwork Reduction Act Notice, see the Instructions for
Form 990 or 990-EZ.
Cat. No. 11285F
Schedule A (Form 990) 2021

Schedule A (Form 990) 2021
Page 2
Part II
Support Schedule for Organizations Described in Sections 170(b)(1)(A)(iv) and 170(b)(1)(A)(vi)
(Complete only if you checked the box on line 5, 7, or 8 of Part I or if the organization failed to qualify under Part III. If the organization failed to qualify under the tests listed below, please complete Part III.)
Section A. Public Support
Calendar year (or fiscal year beginning in) right arrow (a) 2017 (b) 2018 (c) 2019 (d) 2020 (e) 2021 (f) Total
1 Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grant.") .. 823,586 1,596,614 1,332,469 153,166 50,238 3,956,073
2 Tax revenues levied for the organization's benefit and either paid to or expended on its behalf....           0
3 The value of services or facilities furnished by a governmental unit to the organization without charge..           0
4 Total. Add lines 1 through 3 823,586 1,596,614 1,332,469 153,166 50,238 3,956,073
5 The portion of total contributions by each person (other than a governmental unit or publicly supported organization) included on line 1 that exceeds 2% of the amount shown on line 11, column (f) .. 450,234
6 Public support. Subtract line 5 from line 4. 3,505,839
Section B. Total Support
Calendar year (or fiscal year beginning in) right arrow (a) 2017 (b) 2018 (c) 2019 (d) 2020 (e) 2021 (f) Total
7 Amounts from line 4.. 823,586 1,596,614 1,332,469 153,166 50,238 3,956,073
8 Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources...           0
9 Net income from unrelated business activities, whether or not the business is regularly carried on..           0
10 Other income. Do not include gain or loss from the sale of capital assets (Explain in Part VI.)..           0
11 Total support. Add lines 7 through 10 3,956,073
12
12
 
13
First 5 years. If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a section 501(c)(3) organization, check this box and stop here ........................................right arrow
Section C. Computation of Public Support Percentage
14
14
88.620 %
15
15
89.110 %
16a
b
17a
b
18
Private foundation. If the organization did not check a box on line 13, 16a, 16b, 17a, or 17b, check this box and see
instructions ..................................................... right arrow
Schedule A (Form 990) 2021

Schedule A (Form 990) 2021
Page 3
Part III
Support Schedule for Organizations Described in Section 509(a)(2)
(Complete only if you checked the box on line 10 of Part I or if the organization failed to qualify under Part II. If the organization fails to qualify under the tests listed below, please complete Part II.)
Section A. Public Support
Calendar year (or fiscal year beginning in) right arrow (a) 2017 (b) 2018 (c) 2019 (d) 2020 (e) 2021 (f) Total
1 Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") .            
2 Gross receipts from admissions, merchandise sold or services performed, or facilities furnished in any activity that is related to the organization's tax-exempt purpose            
3 Gross receipts from activities that are not an unrelated trade or business under section 513 .....            
4 Tax revenues levied for the organization's benefit and either paid to or expended on its behalf...            
5 The value of services or facilities furnished by a governmental unit to the organization without charge            
6 Total. Add lines 1 through 5            
7a Amounts included on lines 1, 2, and 3 received from disqualified persons            
b Amounts included on lines 2 and 3 received from other than disqualified persons that exceed the greater of $5,000 or 1% of the amount on line 13 for the year.            
c Add lines 7a and 7b..            
8 Public support. (Subtract line 7c from line 6.)  
Section B. Total Support
Calendar year (or fiscal year beginning in) right arrow (a) 2017 (b) 2018 (c) 2019 (d) 2020 (e) 2021 (f) Total
9 Amounts from line 6...            
10a Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..            
b Unrelated business taxable income (less section 511 taxes) from businesses acquired after June 30, 1975.            
c Add lines 10a and 10b.            
11 Net income from unrelated business activities not included on line 10b, whether or not the business is regularly carried on.            
12 Other income. Do not include gain or loss from the sale of capital assets (Explain in Part VI.) ..            
13 Total support. (Add lines 9, 10c, 11, and 12.)..            
14
Section C. Computation of Public Support Percentage
15
15
 
16
16
 
Section D. Computation of Investment Income Percentage
17
17
 
18
18
 
19a
b
20
Schedule A (Form 990) 2021

Schedule A (Form 990) 2021
Page 4
Part IV
Supporting Organizations
(Complete only if you checked a box on line 12 of Part I. If you checked box 12a, of Part I, complete Sections A and B. If you checked box 12b, of Part I, complete Sections A and C. If you checked box 12c, of Part I, complete Sections A, D, and E. If you checked box12d, of Part I, complete Sections A and D, and complete Part V.)
Section A. All Supporting Organizations
Yes
No
1
Are all of the organization’s supported organizations listed by name in the organization’s governing documents?
If "No," describe in Part VI how the supported organizations are designated. If designated by class or purpose,
describe the designation. If historic and continuing relationship, explain.
1
 
 
2
Did the organization have any supported organization that does not have an IRS determination of status under section 509(a)(1) or (2)? If "Yes," explain in Part VI how the organization determined that the supported organization was described in section 509(a)(1) or (2).
2
 
 
3a
Did the organization have a supported organization described in section 501(c)(4), (5), or (6)? If "Yes," answer lines 3b and 3c below.
3a
 
 
b
Did the organization confirm that each supported organization qualified under section 501(c)(4), (5), or (6) and satisfied the public support tests under section 509(a)(2)? If "Yes," describe in Part VI when and how the organization made the determination.
3b
 
 
c
Did the organization ensure that all support to such organizations was used exclusively for section 170(c)(2)(B) purposes? If "Yes," explain in Part VI what controls the organization put in place to ensure such use.
3c
 
 
4a
Was any supported organization not organized in the United States ("foreign supported organization")? If “Yes” and if you checked box 12a or 12b in Part I, answer lines 4b and 4c below.
4a
 
 
b
Did the organization have ultimate control and discretion in deciding whether to make grants to the foreign supported organization? If “Yes,” describe in Part VI how the organization had such control and discretion despite being controlled or supervised by or in connection with its supported organizations.
4b
 
 
c
Did the organization support any foreign supported organization that does not have an IRS determination under sections 501(c)(3) and 509(a)(1) or (2)? If “Yes,” explain in Part VI what controls the organization used to ensure that all support to the foreign supported organization was used exclusively for section 170(c)(2)(B) purposes.
4c
 
 
5a
Did the organization add, substitute, or remove any supported organizations during the tax year? If “Yes,” answer lines 5b and 5c below (if applicable). Also, provide detail in Part VI, including (i) the names and EIN numbers of the supported organizations added, substituted, or removed; (ii) the reasons for each such action; (iii) the authority under the organization's organizing document authorizing such action; and (iv) how the action was accomplished (such as by amendment to the organizing document).
5a
 
 
b
Type I or Type II only. Was any added or substituted supported organization part of a class already designated in the organization's organizing document?
5b
 
 
c
Substitutions only. Was the substitution the result of an event beyond the organization's control?
5c
 
 
6
Did the organization provide support (whether in the form of grants or the provision of services or facilities) to anyone other than (i) its supported organizations, (ii) individuals that are part of the charitable class benefited by one or more of its supported organizations, or (iii) other supporting organizations that also support or benefit one or more of the filing organization’s supported organizations? If “Yes,” provide detail in Part VI.
6
 
 
7
Did the organization provide a grant, loan, compensation, or other similar payment to a substantial contributor (defined in section 4958(c)(3)(C)), a family member of a substantial contributor, or a 35% controlled entity with regard to a substantial contributor? If “Yes,” complete Part I of Schedule L (Form 990) .
7
 
 
8
Did the organization make a loan to a disqualified person (as defined in section 4958) not described on line 7? If “Yes,” complete Part I of Schedule L (Form 990).
8
 
 
9a
Was the organization controlled directly or indirectly at any time during the tax year by one or more disqualified persons, as defined in section 4946 (other than foundation managers and organizations described in section 509(a)(1) or (2))? If “Yes,” provide detail in Part VI.
9a
 
 
b
Did one or more disqualified persons (as defined on line 9a) hold a controlling interest in any entity in which the supporting organization had an interest? If “Yes,” provide detail in Part VI.
9b
 
 
c
Did a disqualified person (as defined on line 9a) have an ownership interest in, or derive any personal benefit from, assets in which the supporting organization also had an interest? If “Yes,” provide detail in Part VI.
9c
 
 
10a
Was the organization subject to the excess business holdings rules of section 4943 because of section 4943(f) (regarding certain Type II supporting organizations, and all Type III non-functionally integrated supporting organizations)? If “Yes,” answer line 10b below.
10a
 
 
b
Did the organization have any excess business holdings in the tax year? (Use Schedule C, Form 4720, to determine whether the organization had excess business holdings).
10b
 
 
Schedule A (Form 990) 2021

Schedule A (Form 990) 2021
Page 5
Part IV
Supporting Organizations (continued)
Yes
No
11
Has the organization accepted a gift or contribution from any of the following persons?
a
A person who directly or indirectly controls, either alone or together with persons described on lines 11b and 11c below, the governing body of a supported organization?
11a
 
 
b
A family member of a person described on 11a above?
11b
 
 
c
A 35% controlled entity of a person described on line 11a or 11b above? If “Yes” to 11a, 11b, or 11c, provide detail in Part VI.
11c
 
 
Section B. Type I Supporting Organizations
Yes
No
1
Did the officers, directors, trustees, or membership of one or more supported organizations have the power to regularly appoint or elect at least a majority of the organization’s directors or trustees at all times during the tax year? If “No,” describe in Part VI how the supported organization(s) effectively operated, supervised, or controlled the organization’s activities. If the organization had more than one supported organization, describe how the powers to appoint and/or remove directors or trustees were allocated among the supported organizations and what conditions or restrictions, if any, applied to such powers during the tax year.
1
 
 
2
Did the organization operate for the benefit of any supported organization other than the supported organization(s) that operated, supervised, or controlled the supporting organization? If “Yes,” explain in Part VI how providing such benefit carried out the purposes of the supported organization(s) that operated, supervised or controlled the supporting organization.
2
 
 
Section C. Type II Supporting Organizations
Yes
No
1
Were a majority of the organization’s directors or trustees during the tax year also a majority of the directors or trustees of each of the organization’s supported organization(s)? If “No,” describe in Part VI how control or management of the supporting organization was vested in the same persons that controlled or managed the supported organization(s).
1
 
 
Section D. All Type III Supporting Organizations
Yes
No
1
Did the organization provide to each of its supported organizations, by the last day of the fifth month of the organization’s tax year, (i) a written notice describing the type and amount of support provided during the prior tax year, (ii) a copy of the Form 990 that was most recently filed as of the date of notification, and (iii) copies of the organization’s governing documents in effect on the date of notification, to the extent not previously provided?
1
 
 
2
Were any of the organization’s officers, directors, or trustees either (i) appointed or elected by the supported organization(s) or (ii) serving on the governing body of a supported organization? If "No," explain in Part VI how the organization maintained a close and continuous working relationship with the supported organization(s).
2
 
 
3
By reason of the relationship described in line 2 above, did the organization’s supported organizations have a significant voice in the organization’s investment policies and in directing the use of the organization’s income or assets at all times during the tax year? If "Yes," describe in Part VI the role the organization’s supported organizations played in this regard.
3
 
 
Section E. Type III Functionally-Integrated Supporting Organizations
1
Check the box next to the method that the organization used to satisfy the Integral Part Test during the year (see instructions):
a
b
c
2
Activities Test. Answer lines 2a and 2b below.
Yes
No
a
Did substantially all of the organization’s activities during the tax year directly further the exempt purposes of the supported organization(s) to which the organization was responsive? If "Yes," then in Part VI identify those supported organizations and explain how these activities directly furthered their exempt purposes, how the organization was responsive to those supported organizations, and how the organization determined that these activities constituted substantially all of its activities.
2a
 
 
b
Did the activities described on line 2a, above constitute activities that, but for the organization’s involvement, one or more of the organization’s supported organization(s) would have been engaged in? If "Yes," explain in Part VI the reasons for the organization’s position that its supported organization(s) would have engaged in these activities but for the organization’s involvement.
2b
 
 
3
Parent of Supported Organizations. Answer lines 3a and 3b below.
a
Did the organization have the power to regularly appoint or elect a majority of the officers, directors, or trustees of each of the supported organizations?If "Yes" or "No", provide details in Part VI.
3a
 
 
b
Did the organization exercise a substantial degree of direction over the policies, programs and activities of each of its supported organizations? If "Yes," describe in Part VI. the role played by the organization in this regard.
3b
 
 
Schedule A (Form 990) 2021

Schedule A (Form 990) 2021
Page 6
Part V
Type III Non-Functionally Integrated 509(a)(3) Supporting Organizations
1
Section A - Adjusted Net Income (A) Prior Year (B) Current Year
(optional)
1 Net short-term capital gain 1    
2 Recoveries of prior-year distributions 2    
3 Other gross income (see instructions) 3    
4 Add lines 1 through 3 4    
5 Depreciation and depletion 5    
6 Portion of operating expenses paid or incurred for production or collection of gross income or for management, conservation, or maintenance of property held for production of income (see instructions) 6    
7 Other expenses (see instructions) 7    
8 Adjusted Net Income (subtract lines 5, 6 and 7 from line 4) 8    
Section B - Minimum Asset Amount (A) Prior Year (B) Current Year
(optional)
1 Aggregate fair market value of all non-exempt-use assets (see instructions for short tax year or assets held for part of year): 1
a Average monthly value of securities 1a    
b Average monthly cash balances 1b    
c Fair market value of other non-exempt-use assets 1c    
d Total (add lines 1a, 1b, and 1c) 1d    
e Discount claimed for blockage or other factors
(explain in detail in Part VI):  
2 Acquisition indebtedness applicable to non-exempt use assets 2    
3 Subtract line 2 from line 1d 3    
4 Cash deemed held for exempt use. Enter 0.015 of line 3 (for greater amount, see instructions). 4    
5 Net value of non-exempt-use assets (subtract line 4 from line 3) 5    
6 Multiply line 5 by 0.035 6    
7 Recoveries of prior-year distributions 7    
8 Minimum Asset Amount (add line 7 to line 6) 8    
Section C - Distributable Amount Current Year
1 Adjusted net income for prior year (from Section A, line 8, Column A) 1  
2 Enter 85% of line 1 2  
3 Minimum asset amount for prior year (from Section B, line 8, Column A) 3  
4 Enter greater of line 2 or line 3 4  
5 Income tax imposed in prior year 5  
6 Distributable Amount. Subtract line 5 from line 4, unless subject to emergency temporary reduction (see instructions) 6  
7
Schedule A (Form 990) 2021

Schedule A (Form 990) 2021
Page 7
Part V
Type III Non-Functionally Integrated 509(a)(3) Supporting Organizations(continued)
Section D - Distributions Current Year
1 Amounts paid to supported organizations to accomplish exempt purposes 1  
2 Amounts paid to perform activity that directly furthers exempt purposes of supported organizations, in
excess of income from activity
2  
3 Administrative expenses paid to accomplish exempt purposes of supported organizations 3  
4 Amounts paid to acquire exempt-use assets 4  
5 Qualified set-aside amounts (prior IRS approval required - provide details in Part VI) 5  
6 Other distributions (describe in Part VI). See instructions 6  
7Total annual distributions. Add lines 1 through 6. 7  
8 Distributions to attentive supported organizations to which the organization is responsive (provide
details in Part VI
). See instructions
8  
9 Distributable amount for 2021 from Section C, line 6 9  
10 Line 8 amount divided by Line 9 amount 10  
Section E - Distribution Allocations (see instructions) (i)
Excess Distributions
(ii)
Underdistributions
Pre-2021
(iii)
Distributable
Amount for 2021
1 Distributable amount for 2021 from Section C, line 6  
2 Underdistributions, if any, for years prior to 2021 (reasonable cause required-- explain in Part VI).
See instructions.
 
3 Excess distributions carryover, if any, to 2021:
a From 2016.......  
b From 2017.......  
c From 2018.......  
d From 2019.......  
e From 2020.......  
fTotal of lines 3a through e  
g Applied to underdistributions of prior years  
h Applied to 2021 distributable amount  
i Carryover from 2016 not applied (see
instructions)
 
j Remainder. Subtract lines 3g, 3h, and 3i from line 3f.  
4Distributions for 2021 from Section D, line 7:
$  
a Applied to underdistributions of prior years  
b Applied to 2021 distributable amount  
c Remainder. Subtract lines 4a and 4b from line 4.  
5 Remaining underdistributions for years prior to
2021, if any. Subtract lines 3g and 4a from line 2.
If the amount is greater than zero, explain in Part VI.
See instructions.
 
6 Remaining underdistributions for 2021. Subtract
lines 3h and 4b from line 1. If the amount is greater
than zero, explain in Part VI. See instructions.
 
7 Excess distributions carryover to 2022. Add lines
3j and 4c.
 
8 Breakdown of line 7:
a Excess from 2017.....  
b Excess from 2018.....  
c Excess from 2019.....  
d Excess from 2020.....  
e Excess from 2021.....  
Schedule A (Form 990) (2021)

Schedule A (Form 990) 2021
Page 8
Part VI
Supplemental Information. Provide the explanations required by Part II, line 10; Part II, line 17a or 17b; Part III, line 12; Part IV, Section A, lines 1, 2, 3b, 3c, 4b, 4c, 5a, 6, 9a, 9b, 9c, 11a, 11b, and 11c; Part IV, Section B, lines 1 and 2; Part IV, Section C, line 1; Part IV, Section D, lines 2 and 3; Part IV, Section E, lines 1c, 2a, 2b, 3a and 3b; Part V, line 1; Part V, Section B, line 1e; Part V Section D, lines 5, 6, and 8; and Part V, Section E, lines 2, 5, and 6. Also complete this part for any additional information. (See instructions).
Facts And Circumstances Test
 
Return Reference Explanation
Schedule A (Form 990) 2021


Additional Data


Software ID: 21013475
Software Version: 2021v4.1
Schedule B
(Form 990)
Department of the Treasury
Internal Revenue Service
Schedule of Contributors

Arrow Bullet Attach to Form 990, 990-EZ, or 990-PF.
Arrow Bullet Go to www.irs.gov/Form990 for the latest information.
OMB No. 1545-0047
2021
Name of the organization
FREEDOM OF CONSCIENCE DEFENSE FUND INC
 
Employer identification number

30-0741605
Organization type (check one):
Filers of:
Section:
Form 990 or 990-EZ






Form 990-PF




Check if your organization is covered by the General Rule or a Special Rule.  
Note: Only a section 501(c)(7), (8), or (10) organization can check boxes for both the General Rule and a Special Rule. See instructions.
General Rule
Special Rules
......... Arrow Bullet $  
Caution: An organization that isn't covered by the General Rule and/or the Special Rules doesn't file Schedule B (Form 990,
990-EZ, or 990-PF), but it must answer “No” on Part IV, line 2, of its Form 990; or check the box on line H of its Form 990-EZ
or on its Form 990PF, Part I, line 2, to certify that it doesn't meet the filing requirements of Schedule B (Form 990,
990-EZ, or 990-PF).
For Paperwork Reduction Act Notice, see the Instructions
for Form 990, 990-EZ, or 990-PF.
Cat. No. 30613XSchedule B (Form 990) (2021)
Schedule B (Form 990) (2021) Page 2
Name of organization
FREEDOM OF CONSCIENCE DEFENSE FUND INC
 
Employer identification number
30-0741605
Part I
Contributors
Contributors (see instructions). Use duplicate copies of Part I if additional space is needed.
(a)
No.
(b)
Name, address, and ZIP + 4
(c)
Total contributions
(d)
Type of contribution
RESTRICTED
 
 
 
 
  ,    

$ RESTRICTED


(Complete Part II for noncash contributions.)
(a)
No.
(b)
Name, address, and ZIP + 4
(c)
Total contributions
(d)
Type of contribution
 
 
 
 

$  


(Complete Part II for noncash contributions.)
(a)
No.
(b)
Name, address, and ZIP + 4
(c)
Total contributions
(d)
Type of contribution
 
 
 
 

$  


(Complete Part II for noncash contributions.)
(a)
No.
(b)
Name, address, and ZIP + 4
(c)
Total contributions
(d)
Type of contribution
 
 
 
 

$  


(Complete Part II for noncash contributions.)
(a)
No.
(b)
Name, address, and ZIP + 4
(c)
Total contributions
(d)
Type of contribution
 
 
 
 

$  


(Complete Part II for noncash contributions.)
(a)
No.
(b)
Name, address, and ZIP + 4
(c)
Total contributions
(d)
Type of contribution
 
 
 
 

$  


(Complete Part II for noncash contributions.)
Schedule B (Form 990) (2021)
Schedule B (Form 990) (2021)
Page 3
Name of organization
FREEDOM OF CONSCIENCE DEFENSE FUND INC
 
Employer identification number

30-0741605
Part II
Noncash Property (see instructions). Use duplicate copies of Part II if additional space is needed.
(a)
No. from Part I
(b)
Description of noncash property given
(c)
FMV (or estimate)
(See instructions)
(d)
Date received
 
$    
(a)
No. from Part I
(b)
Description of noncash property given
(c)
FMV (or estimate)
(See instructions)
(d)
Date received
 
$    
(a)
No. from Part I
(b)
Description of noncash property given
(c)
FMV (or estimate)
(See instructions)
(d)
Date received
 
$    
(a)
No. from Part I
(b)
Description of noncash property given
(c)
FMV (or estimate)
(See instructions)
(d)
Date received
 
$    
(a)
No. from Part I
(b)
Description of noncash property given
(c)
FMV (or estimate)
(See instructions)
(d)
Date received
 
$    
(a)
No. from Part I
(b)
Description of noncash property given
(c)
FMV (or estimate)
(See instructions)
(d)
Date received
 
$    
Schedule B (Form 990) (2021)
Schedule B (Form 990) (2021)
Page 4
Name of organization
FREEDOM OF CONSCIENCE DEFENSE FUND INC
 
Employer identification number

30-0741605
Part III
Exclusively religious, charitable, etc., contributions to organizations described in section 501(c)(7), (8), or (10) that total more than $1,000 for the year from any one contributor. Complete columns (a) through (e) and the following line entry. For organizations completing Part III, enter the total of exclusively religious, charitable, etc., contributions of $1,000 or less for the year. (Enter this information once. See instructions.) Arrow Bullet$  
Use duplicate copies of Part III if additional space is needed.
(a)
No. from Part I
(b) Purpose of gift (c) Use of gift (d) Description of how gift is held
 
(e) Transfer of gift
Transferee's name, address, and ZIP 4 Relationship of transferor to transferee
 
 
     
 
(a)
No. from Part I
(b) Purpose of gift (c) Use of gift (d) Description of how gift is held
 
(e) Transfer of gift
Transferee's name, address, and ZIP 4 Relationship of transferor to transferee
 
 
     
 
(a)
No. from Part I
(b) Purpose of gift (c) Use of gift (d) Description of how gift is held
 
(e) Transfer of gift
Transferee's name, address, and ZIP 4 Relationship of transferor to transferee
 
 
     
 
(a)
No. from Part I
(b) Purpose of gift (c) Use of gift (d) Description of how gift is held
 
(e) Transfer of gift
Transferee's name, address, and ZIP 4 Relationship of transferor to transferee
 
 
     
 
Schedule B (Form 990) (2021)
Additional Data


Software ID: 21013475
Software Version: 2021v4.1

Note: To capture the full content of this document, please select landscape mode (11" x 8.5") when printing.

SCHEDULE N
(Form 990)

Department of the Treasury
Internal Revenue Service
Liquidation, Termination, Dissolution, or Significant Disposition of Assets
bullet Complete if the organization answered "Yes" on Form 990, Part IV, lines 31 or 32; or Form 990-EZ, line 36.
bullet Attach certified copies of any articles of dissolution, resolutions, or plans.
bullet Attach to Form 990 or 990-EZ.
bullet Go to www.irs.gov/Form990 for the latest information.
OMB No. 1545-0047
2021
Open to Public
Inspection
Name of the organization
FREEDOM OF CONSCIENCE DEFENSE FUND INC
 
Employer identification number
30-0741605
Part I
Liquidation, Termination, or Dissolution. Complete this part if the organization answered "Yes" on Form 990, Part IV, line 31, or Form 990-EZ, line 36. Part I can be duplicated if additional space is needed.
1(a) Description of asset(s)
distributed or transaction
expenses paid
(b) Date of
distribution
(c) Fair market value of
asset(s) distributed or
amount of transaction
expenses
(d) Method of
determining FMV for
asset(s) distributed or
transaction expenses
(e) EIN of recipient (f) Name and address of recipient (g) IRC section
of recipient(s) (if
tax-exempt) or type
of entity
CASH 06-30-2022 66,040 CASH 36-4270023  
 
309 W WASHINGTON ST STE 1250
CHICAGO,IL60606
501(c)(3)
Yes
No
2
Did or will any officer, director, trustee, or key employee of the organization:
a
Become a director or trustee of a successor or transferee organization? ...........................
2a
 
No
b
Become an employee of, or independent contractor for, a successor or transferee organization? .....................
2b
 
No
c
Become a direct or indirect owner of a successor or transferee organization? .....................
2c
 
No
d
Receive, or become entitled to, compensation or other similar payments as a result of the organization's liquidation, termination, or dissolution? ........
2d
 
No
e
If the organization answered "Yes" to any of the questions on lines 2a through 2d, provide the name of the person involved and explain in Part III. bullet
For Paperwork Reduction Act Notice, see the Instructions for Form 990.
Cat. No. 50087Z
Schedule N (Form 990) (2021)

Schedule N (Form 990) (2021)
Page 2
Part I
Liquidation, Termination, or Dissolution (continued)
Note. If the organization distributed all of its assets during the tax year, then Form 990, Part X, column (B), line 16 (Total assets), and line 26 (Total liabilities), should equal -0-.
Yes
No
3
Did the organization distribute its assets in accordance with its governing instrument(s)? If "No," describe in Part III .............
3
Yes
 
4a
Is the organization required to notify the attorney general or other appropriate state official of its intent to dissolve, liquidate, or terminate? ......
4a
 
No
b
If "Yes," did the organization provide such notice? .....................
4b
 
No
5
Did the organization discharge or pay all of its liabilities in accordance with state laws? .....................
5
Yes
 
6a
Did the organization have any tax-exempt bonds outstanding during the year? .....................
6a
 
No
b
If "Yes" on line 6a, did the organization discharge or defease all of its tax-exempt bond liabilities during the tax year in accordance with the Internal Revenue Code and state laws?
6b
 
No
c
If "Yes" on line 6b, describe in Part III how the organization defeased or otherwise settled these liabilities. If "No" on line 6b, explain in Part III.

Part II
Sale, Exchange, Disposition, or Other Transfer of More Than 25% of the Organization's Assets. Complete this part if the organization answered "Yes" on Form 990, Part IV, line 32, or Form 990-EZ, line 36. Part II can be duplicated if additional space is needed.
1(a) Description of asset(s)
distributed or transaction
expenses paid
(b) Date of
distribution
(c) Fair market value of
asset(s) distributed or
amount of transaction
expenses
(d) Method of
determining FMV for
asset(s) distributed or
transaction expenses
(e) EIN of recipient (f) Name and address of recipient (g) IRC section
of recipient(s) (if
tax-exempt) or type
of entity
Yes
No
2
Did or will any officer, director, trustee, or key employee of the organization:
a
Become a director or trustee of a successor or transferee organization? .........................
2a
 
No
b
Become an employee of, or independent contractor for, a successor or transferee organization? .....................
2b
 
No
c
Become a direct or indirect owner of a successor or transferee organization? .....................
2c
 
No
d
Receive, or become entitled to, compensation or other similar payments as a result of the organization's significant disposition of assets? ........
2d
 
No
e
If the organization answered "Yes" to any of the questions on lines 2a through 2d, provide the name of the person involved and explain in Part III. bullet
For Paperwork Reduction Act Notice, see the Instructions for Form 990.
Cat. No. 50087Z
Schedule N (Form 990) (2021)

Schedule N (Form 990) (2021)
Page 3
Part III
Supplemental Information. Provide the information required by Part I, lines 2e and 6c, and Part II, line 2e. Also complete this part to provide any additional information.
Return Reference Explanation
Sch N, Part III, Additional Information FREEDOM OF CONSCIENCE DEFENSE FUND, INC. WILL MERGE WITH THE THOMAS MORE SOCIETY 10/1/22 (MERGER DOCUMENTS ATTACHED). THE TRANSFER OF ASSETS LISTED IN PART 1 OF SCHEDULE N WAS DONE AS PART OF THIS MERGE AND DATED 6/30/22. FREEDOM OF CONSCIENCE DEFENSE FUND, INC. WILL FILE A FINAL RETURN FOR THE SHORT PERIOD ENDING 10/1/22.
Schedule N (Form 990) (2021)



Additional Data


Software ID: 21013475
Software Version: 2021v4.1


SCHEDULE O
(Form 990)

Department of the Treasury
Internal Revenue Service
Supplemental Information to Form 990 or 990-EZ

Complete to provide information for responses to specific questions on
Form 990 or 990-EZ or to provide any additional information.
MediumBullet Attach to Form 990 or 990-EZ.
MediumBullet Go to www.irs.gov/Form990 for the latest information.
OMB No. 1545-0047
2021
Open to Public
Inspection
Name of the organization
FREEDOM OF CONSCIENCE DEFENSE FUND INC
 
Employer identification number

30-0741605
Return Reference Explanation
Grants and Similar Amounts Paid In Excess of $5,000.5 Class of Activity: grants for legal services | Donee's Name: GRANTS BELOW THRESHOLD | Donee's Address: c/o fcdf PO BOX 9520 RANCHO SANTA FE CA 92067 | Relationship of Donee: N/A | Cash Amount Given: $10887
Grants and Similar Amounts Paid In Excess of $5,000.6 | Donee's Name: THE THOMAS MORE SOCIETY | Donee's Address: 309 W. Washington St., STE 1250 CHICAGO IL 60606 | Relationship of Donee: NONE | Cash Amount Given: $66040
Other Expenses.1002 Office Expenses $651
Other Expenses.1012 Insurance $4512
Other Expenses.1 FUNDRAISING COSTS $4329
Other Expenses.2 MEETING COSTS $1342
Cases Year End 06-30-22- form 990EZ pg 2 prt III line 28 PART III, LINE 28Freedom of Conscience Defense FundDefending Religious Freedom and the American ConstitutionCases for the Year Ending 06-30-22Nelli Parisenkova v. Bright Horizons Family Solutions LLC & Katy CallasNot Yet Filed: Estimate 08/2022Nelli Parisenkova is a Ukrainian immigrant and now a U.S. Citizen. She is a devout Christian with traditional views on sexuality and marriage. She has worked in the childcare and teaching profession for many years. Most recently, for four years she was employed with a childcare facility owned by Bright Horizons Family Solutions and located in Los Angeles County. At that location, Ms. Parisenkova duties involved daily care of children ages 1-5, including feeding them, changing their diaper, putting them to sleep, and age-appropriate educational activities.When Ms. Parisenkova was first employed by Bright Horizons, she discovered that the infant room where she worked had various books promoting content that violated her faith (childrens books concerning same-sex marital relationships and parenting). Although Ms. Parisenkova is loving, tolerant, and kind to individuals regardless of their personal circumstances, she believes that it would be sinful for her to personally promote intimate relationships and choices that are contrary to the teachings of her faith. At the time she was initially employed, Ms. Parisenkova requested permission to not read those books to the children, and have another childcare worker read them if a child requested one of them. This was deemed acceptable for four years.However, on April 7, 2022, a colleague told Ms. Parisenkovas current supervisor that she had requested that the books be moved out of the room during one of her shifts, which led her supervisor, Ms. Katy Callas, to become irate. Ms. Callas had Ms. Parisenkova immediately placed on administrative leave and escorted off the property. Ms. Parisenkova was then summarily fired.TMS West Coast has prepared an employment discrimination complaint against Bright Horizons for discriminating against Ms. Parisenkova on the basis of her religion, and for failing to accommodate her religious beliefs.-Kenneth T. Simeone v. The Walt Disney CompanyInitiated: 07/08/2022The Walt Disney Company is a media and entertainment corporation with an emphasis on providing safe and wholesome entertainment for families of all ages through animated and live action films and television programs and theme parks.Over the past several decades, and with a greater emphasis in the last few years, Disney Directors and Officers have attacked their core business by pursuing personal political goals instead of rational business decisions. This includes by promoting LGBT content and woke content, including polyamorous relationships, in their media programing. Disney also lobbied against a parental rights bill in Florida.As a result of this, the Disney share price has significantly fallen, and the State of Florida has taken action against it by withdrawing a self-governance provision for the Walt Disney World theme park. There is also discussion in Congress of withdrawing Disneys copyright for certain older characters. Without special consideration, many of those characters would have since entered the public domain.Mr. Ken Simeone is a shareholder of the Walt Disney Company. He is upset about the loss of value in his shares. On his behalf, in July 2022, TMS West Coast initiated a books and records request of the Walt Disney Company, to review the participation of the Disney Directors and Officers in the above negligent or intentional attack on Disneys core business. If warranted, TMS West Coast will file a derivative action on behalf of the Walt Disney Company against those Directors and Officers who prioritize their own personal political goals ahead of the interests of the company.-Bernard Gallo v. Washington NationalsFiled: 04/20/2022Bernard Gallo, a resident of San Diego County, was a scout for the Washington Nationals baseball organization who recovered from COVID and sought an exemption from the Nationals vaccine mandate for religious and medical/disability reasons. Most of his work was outdoors and distanced and therefore his non-vaccinated status could have been accommodated. But the Nationals refused and terminated his contract early. TMS West Coast, working with local counsel, administratively exhausted Mr. Gallos discrimination claims through the EEOC, which issued a right-to-sue letter. TMS West Coast, in partnership with attorney Rachel Rodriguez of Vires Law Group PLLC, then filed a complaint in the U.S. District Court for the District of D.C. against the Nationals organization, raising claims for religious and perceived disability discrimination under District of Columbia law and federal law (Title VII), retaliation, and coercion.The Nationals organization filed a motion to dismiss the perceived disability discrimination claims and retaliation claims. TMS West Coast, with Vires Law Group, filed an opposition to that motion. The Nationals have not yet filed their reply brief, and no hearing is yet set.-Air Force Officer v. AustinFiled: 01/06/2022In August 2021, Secretary of Defense Austin issued a COVID-19 vaccine mandate for all military servicemembers. TMS attorneys filed suit in the Middle District of Georgia seeking an exemption for their client, a pseudonymous Air Force Officer, under the Religious Freedom Restoration Act and the Free Exercise Clause and arguing that the mandate violated the federal Administrative Procedure Act.On February 15, 2021, the district court granted a preliminary injunction to Air Force Officer, the first in the nation, but did not extend this injunction nationwide.Later in February, TMS West Coast joined the case as class action counsel, and TMS attorneys filed an amended complaint, adding more plaintiffs, and a motion for class certification. The judge in this case has never ruled on the motion.Instead, a judge in a separate case in Ohio, Doster v. Kendall, granted a nationwide preliminary injunction that protects Air Force Officer and his co-plaintiffs. The judge in this case then placed an administrative stay in the case pending resolution of the Doster case, including any appeal to the Sixth Circuit.-Doe Family, Roe Family, & Poe Family v. San Diego Unified School DistrictFiled: 10/22/2021Originally, on behalf of the Doe Family, TMS West Coast brought a challenge to the San Diego Unified School Districts mandate requiring COVID-19 vaccination for all students over age 16. The Doe Family sought a religious exemption for their daughter, Jill Doe.On Saturday, December 4, 2021, the emergency motions panel of the Ninth Circuit denied the Doe Family an injunction. On January 14, eleven Ninth Circuit judges dissented from the denial of rehearing en banc. In December, a California Superior Court judge ruled in a separate case (Let Them Choose v. San Diego Unified School District), that the vaccine mandate violated state law and thus could not be enforced. The School District appealed and on February 1, 2022, the California Fourth District Court of Appeal granted a stay of enforcement of the order. Nevertheless, on February 8, 2022, the School District decided to delay its vaccine mandate to the Fall 2022 semester.TMS West Coast briefed an emergency application to the U.S. Supreme Court. On February 18, 2022, the High Court denied the application noting that the vaccine mandate had been delayed and inviting the Doe Family to reapply if it were reinstated.On May 24, 2022, the School District decided to delay its vaccine mandate to no earlier than July 2023. The parties agreed to dismiss the current appeal. TMS West Coast has filed a First Amended Complaint that adds the Roe and Poe families. The parties are preparing for an Early Neutral Evaluation conference and Case Management conference at which point a discovery schedule will be negotiated and set for resolution of this case on the merits.-Joseph Nicolosi Jr. v. David Kinitz & Travis SalwayFiled: 07/20/2021Dr. Joseph Nicolosi Jr. is a preeminent therapist helping people with discomfort with their sexual orientation.In an academic journal article, a pair of researchers in Canada falsely labelled his specific brand of therapy, Reintegrative Therapy, criminal, dangerous and destructive conversion therapy.On his behalf, TMS West Coast filed a federal libel lawsuit in the Southern District of California. There has been a significant delay due to the nature of serving international defendants through the Hague Convention.Presently, both defendants have filed motions to dismiss, that are both fully briefed; and a ruling from the Judge is forthcoming.
Cases Year End 06-30-22- form 990EZ pg 2 prt III line 28 (cont.) PART III, LINE 28Freedom of Conscience Defense FundDefending Religious Freedom and the American ConstitutionCases for the Year Ending 06-30-22 (continued)Charles Cox v. Principal Erica Renfree, San Diego Unified School District, et al.Filed: 07/14/2021San Diego Unified School District illegally changed the name of one of its high schools from Junipero Serra High School to Canyon Hills High School. Junipero Serra is a Catholic missionary and Saint, revered by Californians as the States Founding Father, and by Christians as the Apostle of California.The schools principal, Erica Renfree, was the prime mover behind the change. Through public records requests and discovery, it was uncovered that she falsified community polling data to convince the School Districts Board of Trustees to approve the name change.TMS West Coast brought litigation in July 2021 on behalf of a group of concerned local residents. The lawsuit claims violations of the School Districts procedures, fraud, and violation of the Establishment Clause of the U.S. Constitution and California Constitution through governmental official expression of hostility to religion.In advance of the Fall 2021 semester, the trial court denied TMS West Coasts motion for a preliminary injunction, and the Fourth District Court of Appeal denied an emergency application for a stay pending appeal. That appeal has since been dismissed.In early 2022, the trial court sustained the School Districts demurrer to the complaint, leading TMS West Coast to file an amended complaint. The School District has filed a renewed demurrer to that complaint, which is set for hearing on December 2, 2022. In the meantime, the parties are currently engaging in discovery.-Father Josiah Trenham, et al. v. Peter J. Sanfilippo, et al.Filed: 02/05/2021A crazy internet blogger, Mr. Sanfilippo has been accusing Orthodox priest Father Trenham of egregious conduct online, including sexual abusing his own children. On behalf of Father Trenham, TMS West Coast filed a federal defamation lawsuit against Mr. Sanfilippo in the Central District of California. After Mr. Sanfilippo did not respond, TMS West Coast obtained a default judgment against him, which has been finalized.TMS West Coast is in the process of using that default judgment to have the defamatory and harassing blog posts removed by Mr. Sanfilippos internet hosting providers.-COVID-19 Vaccine Mandate AssistanceInitiated: 12/11/2020With Emergency Use Authorization approved for the first COVID-10 vaccine in December 2020, various employers or governmental bodies imposed COVID-19 vaccine mandates for healthcare workers, students, and other employees.TMS West Coast has been fielding numerous calls and assisting individuals behind the scenes in obtaining religious exemptions. This includes a medical student with the University of Colorado and numerous federal government employees. TMS West Coast has also been engaging in education, speaking to numerous groups about the parameters of the law and the requirement that employers engage in an interactive process with the employee to come up with a religious accommodation.-Jason Hill v. DePaul UniversityFiled: 04/20/2020Philosophy Professor Jason Hill, who is of Caribe-African descent and homosexual, published a scholarly article on February 11, 2020 which supported Israels right to defend itself against Palestinian attacks. Prof. Hills employer, DePaul University, acting through its faculty president Scot Paeth and provost Salma Ghanem, published a defamatory response hit-piece framed as a faculty council resolution. This defamatory resolution was then published in DePauls on-campus newspaper, DePaulia, and DePaul encouraged students to boycott Professor Hills classes, hosted a dinner entitled Come Celebrate the Censure of Professor Hill, and allowed students and off-campus groups to hold demonstrations against him.Professor Hill filed suit in Illinois State Court against DePaul University, Scot Paeth, and Salma Ghanem, alleging defamation, breach of contract, tortious interference with prospective economic advantage, and Violation of the Illinois Human Rights Act. Following challenges to it, the propriety of Professor Hills Third Amended Complaint was upheld and discovery is proceeding.-Craig Harrison v. Ryan GilliganFiled: 09/11/2019Craig Harrison is a former Roman Catholic Priest. For twenty years, he served as pastor of St. Francis Catholic Church in Bakersfield. Throughout his entire priestly career, he has been the subject of various accusations of sexual or financial impropriety, which have been swept under the rug.In 2019, however, the Roman Catholic Diocese of Fresnowhich covers Bakersfieldbelieved they had solid and credible evidence of sexual abuse committed by Harrison. An individual reported to the Diocese that in one conversation, an individual told him and a then-Benedictine novice, Ryan Gilligan, that Harrison had sexually abused him. When Mr. Gilligan confirmed that individuals recounting of the conversation, the Diocese asked him to meet with the victim, which he did. The victim then recounted the story again. The Diocese immediately placed Craig Harrison on administrative leave and reported him to the police. After multiple police investigations, it was determined that the accusations were credible, but that no criminal charges could be brought against Harrison due to the statute of limitations.In an effort to clear his name and prevent his laicization from the Catholic priesthood, Harrison sued Mr. Gilligan for defamation (along with the Diocese itself and a Catholic investigative watchdog group). TMS West Coast defended Mr. Gilligan and filed an anti-SLAPP motion to strike Harrisons complaint. Amazingly, 23 judges recused themselves from the case. The trial court denied the anti-SLAPP motion, leading to an appeal.On July 22, 2022, the Fifth Appellate District reversed with instructions to the trial court to grant the anti-SLAPP motion and strike the complaint. In the meantime, Pope Francis laicized Harrison from the Catholic priesthood.Plaintiff Harrison is now seeking further appellate relief. Once that fails, TMS West Coast will seek its attorneys fees.-California DFEH v. Cathy Miller & Tastries BakeryAdministrative Investigation Initiated: 10/18/2017Civil Lawsuit Filed: 10/17/2018Tastries Bakery is a small bakery 100% owned by Catharine (Cathy) Miller, a devout Christian. When a lesbian couple came in seeking a wedding cake for their same-sex wedding, Cathy politely declined to use her artistic abilities to celebrate a same-sex wedding ceremony, and instead offered to connect them with a rival bakery. The couple then filed a complaint with Californias Department of Fair Employment and Housing (DFEH), the agency that enforces the state anti-discrimination law, which brought a lawsuit.In October 2017, the DFEH initiated an administrative investigation against Tastries Bakery and Cathy Miller, and petitioned for a preliminary injunction ordering them to either cease making wedding cakes altogether, or to make wedding cake for both same-sex and opposite-sex couples. TMS West Coast is defending Tastries Bakery and Cathy Miller.In a first-in-the-nation ruling, the trial court denied the motion on the basis that the First Amendment protects Cathys rights to only make wedding cakes for opposite-sex weddings.In October 2018, having completed its administrative investigation, the DFEH brought a civil lawsuit against Tastries Bakery and Cathy Miller. Following discovery, and failed preliminary motions, the case proceeded to trial in July 2022.The parties proceeded to a bench trial that lasted a week, from Friday, July 22 to Friday, July 29, 2022. The parties expect a ruling in approximately a month.-Skyline Wesleyan Church v. California DMHCFiled: 02/26/2016Since 1975, California law has required that all health insurance plans cover all basic health care services. In 2014, in reviewing this act, the California Department of Managed Health Care (DMHC) determined that it had erroneously allowed various health insurance companies to offer insurance plans that do not cover elective abortion. Those companies offered those plans in case their customers, for example, religious organizations wanted insurance that did not cover elective abortion.In August 2014, the DMHC informed those insurance companies that their insurance plans were no longer approved to the extent that they failed to cover elective abortion, and the companies then amended the plans to cover abortion. This change was not broadcast to anybody.When Skyline Wesleyan Church discovered that its health insurance plan covered elective abortion, it sought an exemption. When an exemption was denied, in February 2016, the church brought a lawsuit.TMS West Coast partnered with Alliance Defending Freedom based in Arizona to bring that lawsuit, alleging that the regulations violated Skyline Wesleyan Churchs constitutional rights. The district court dismissed t
Cases Year End 06-30-22- form 990EZ pg 2 prt III line 28 (cont.) PART III, LINE 28Freedom of Conscience Defense FundDefending Religious Freedom and the American ConstitutionCases for the Year Ending 06-30-22 (continued)David Daleiden and the Center for Medical ProgressFirst Case Filed: 07/27/2015Mr. Daleiden is a pro-life investigative journalist. Between 2013 and 2015, he engaged in a 30 month long undercover investigation into the fetal tissue procurement industry. That industry obtains fetal tissue, primarily from elective abortion, and then provides that tissue to scientific researchers. During his investigation, Mr. Daleiden uncovered significant wrongdoing, including a black market in fetal tissue, and various crimes committed during the tissue procurement process. Mr. Daleidens investigation led to Congressional investigations by both Houses, multiple civil prosecutions, and the exclusion of Planned Parenthood from Medicaid in Texas. However, the investigation has also led to numerous lawsuits filed against Mr. Daleiden, as well as a criminal prosecution. TMS West Coast, alongside TMS attorneys nationwide, have been defending Mr. Daleiden.-STEMEXPRESS LLC V. CENTER FOR MEDICAL PROGRESSFiled: 07/27/2015StemExpress LLC is a fetal tissue procurement company that has made millions of dollars re-selling improperly obtained fetal tissue at great profit margins. In July 2015, they sued hoping to obtain an injunction against CMP disclosing information about them, including a video of a lunch meeting between Daleiden and StemExpress personnel.TMS West Coast defeated the effort to enjoin that information, which was released in August 2015.TMS West Coast filed an anti-SLAPP motion to strike the complaint. The trial court denied it, and it was appealed. During that appeal, the parties agreed to settle the case through a mutual walk-away.-NATIONAL ABORTION FEDERATION V. CENTER FOR MEDICAL PROGRESSFiled: 07/31/2015The National Abortion Federation is a trade association for abortion providers. In July 2015, it also sued, seeking to obtain an injunction against CMP disclosing information learned while attending two of their industry-wide tradeshows. TMS West Coast has been defending CMP but this injunction was granted. Unfortunately, the district court judge presiding over the case is a political supporter of abortion rights. He was appointed to the bench because he was a bundler for President Obama, and he served on the board of a nonprofit that housed a Planned Parenthood clinic, for free, in its headquarters. TMS West Coast moved to have the judge recuse himself, but its motion was denied.In April and May 2021, the federal district court granted summary judgment to NAF and entered a permanent injunction. TMS West Coast appealed, and the Ninth Circuit heard oral argument on August 9, 2022.The district court also awarded NAF approximately $6.4 million in attorneys fees and costs. That order has been appealed but has been stayed pending the merits appeal.-PLANNED PARENTHOOD V. CENTER FOR MEDICAL PROGRESSFiled: 01/14/2016Planned Parenthood is a franchise-based network of abortion providers. Providing approximately 50% of all abortions nationwide, the network is the largest abortion provider in the nation.Upon seeing NAFs success, Planned Parenthood also brought a lawsuit, allegedly solely seeking damages flowing from CMPs investigative methods, not the publication of the results of its investigation. Planned Parenthood successfully filed a motion to have its case sent to the same judge as in the NAF litigation.Following a six-week jury trial in October and November 2019, the jury awarded Planned Parenthood approximately $2.4 million in damages (following trebling and imposition of punitive damages). The court then also awarded Planned Parenthood approximately $13.7 million in attorneys fees and costs. This result was appealed and oral argument at the Ninth Circuit occurred on April 21, 2022.The fees appeal has been stayed pending the merits appeal.-CALIFORNIA V. DALEIDENInvestigation Initiated: 04/05/2016Action Filed: 05/03/2017In an effort to impugn the credibility of the results of CMPs investigation, Planned Parenthood and NAF filed criminal complaints against Daleiden with the police in various counties. When those police or district attorneys refused to investigate or prosecute, finding the complaints frivolous on their face, Planned Parenthood instead lobbied the California Attorney General, Kamala Harris, to bring a prosecution. That prosecution began with a raid on Mr. Daleidens home in April 2016 and then a criminal complaint filed against him in May 2017.Through pre-trial proceedings, TMS West Coast has been able to have many of the criminal felony counts dismissed, but Daleiden still faces many criminal felony counts.The parties are ramping up for trial, with a trial setting conference set for late August 2022.-JANE AND JOHN DOES 1-10 V. UNIVERSITY OF WASH. & CMPFiled: 08/03/2016As part of its investigative efforts, CMP has filed public records requests with governmental organizations across the nation.In August 2016, a group of anonymous abortion providers and others sued the University of Washington to stop it from releasing records of fetal tissue sales to Daleiden.The Doe Plaintiffs obtained a preliminary injunction that has been upheld by the Ninth Circuit multiple times.
Cases Year End 06-30-22- form 990EZ pg 2 prt III line 28 (cont.) PART III, LINE 28Freedom of Conscience Defense FundDefending Religious Freedom and the American ConstitutionCases for the Year Ending 06-30-22 (continued)CENTER FOR MEDICAL PROGRESS V. ATTORNEY GENERAL ROB BONTA, ET AL.Filed: 05/12/2020During the criminal prosecution of Mr. Daleiden, the Cal. Attorney General struggled to find a non-political explanation for why it had chosen to prosecute Mr. Daleiden. In briefing, it settled upon the concept that the content of CMPs reporting was particularly egregious. Although prosecutors have discretion in which cases to bring, it is an unconstitutional motivation to prosecute somebody based on the content of their speech.Therefore, TMS West Coast filed a federal civil rights lawsuit in federal court seeking an injunction stopping the Cal. Attorney General from continuing with its prosecution.However, the lawsuit was transferred to the Judge in the PPFA and NAF cases, who put an indefinite stay on it until after the criminal case ends.
For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.
Cat. No. 51056K
Schedule O (Form 990) 2021


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Software ID: 21013475
Software Version: 2021v4.1