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AGREED MOTION TO DEEM AMICUS
BRIEF FILED - NO. 3:18-CV-06810
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ATTORNEY GENERAL OF WASHINGTON
Complex Litigation Division
800 Fifth Avenue, Suite 2000
Seattle, WA 98104
(206) 464-7744
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Megan D. Lin, SBN # 298267
Laura K. Clinton, WSBA #29846
Colleen M. Melody, WSBA #42275
Kristin Beneski, WSBA #45478
Assistant Attorneys General
Office of the Attorney General
800 Fifth Avenue, Suite 2000
Seattle, WA 98104
(206) 464-5342
The Honorable Jon S. Tigar
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
East Bay Sanctuary Covenant; Al Otro
Lado; Innovation Law Lab; and Central
American Resource Center in Los
Angeles,
Plaintiffs,
v.
Donald J. Trump, President of the United
States, in his official capacity; Matthew
G. Whitaker, Acting Attorney General, in
his official capacity; U.S. Department of
Justice; James McHenry, Director of the
Executive Office for Immigration
Review, in his official capacity; the
Executive Office for Immigration
Review; Kirstjen M. Nielsen, Secretary of
Homeland Security, in her official
capacity; U.S. Department of Homeland
Security; Lee Francis Cissna, Director of
the U.S. Citizenship and Immigration
Case No. 3:18-cv-06810
AGREED MOTION TO DEEM THE
AMICUS CURIAE BRIEF AT DKT.
19-1 FILED
Hearing Date: November 19, 2018,
9:30AM
Case 4:18-cv-06810-JST Document 42 Filed 11/19/18 Page 1 of 3
AGREED MOTION TO DEEM AMICUS
BRIEF FILED - NO. 3:18-CV-06810
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ATTORNEY GENERAL OF WASHINGTON
Complex Litigation Division
800 Fifth Avenue, Suite 2000
Seattle, WA 98104
(206) 464-7744
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Services, in his official capacity; U.S.
Citizenship and Immigration Services;
Kevin K. McAleenan, Commissioner of
U.S. Customs and Border Protection, in
his official capacity; U.S. Customs and
Border Protection; Ronald D. Vitiello,
Acting Director of Immigration and
Customs Enforcement, in his official
capacity; Immigration and Customs
Enforcement,
Defendants.
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE THAT the States of Washington, Massachusetts, New York,
and California (States) respectfully move the Court to deem their amicus curiae brief, in the
record at Dkt. 19-1, filed on November 14, 2018. No party will be prejudiced and the Court has
already granted the motion for the States to participate as amici and for leave to file the brief
(Dkt. 20). Counsel for the parties have consented to this filing.
I.
BACKGROUND AND ARGUMENT
On November 14, 2018—with permission from both parties—the States filed an
unopposed motion to file an amicus brief in support of Plaintiffs’ motion for temporary
restraining order (Dkt. 19) and attached the proposed amicus brief (Dkt. 19-1). The Court
promptly granted the motion, allowing the States to formally file their amicus brief (Dkt. 20).
Due to illness, the States’ counsel overlooked notice of that order on the docket, but all parties
were aware of the amicus filing and had the opportunity to respond prior to today’s hearing on
Plaintiffs’ motion for temporary restraining order. Thus, no party is prejudiced by the States’
request.
Case 4:18-cv-06810-JST Document 42 Filed 11/19/18 Page 2 of 3
AGREED MOTION TO DEEM AMICUS
BRIEF FILED - NO. 3:18-CV-06810
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ATTORNEY GENERAL OF WASHINGTON
Complex Litigation Division
800 Fifth Avenue, Suite 2000
Seattle, WA 98104
(206) 464-7744
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II.
CONCLUSION
Counsel for Defendants and Plaintiffs are aware of this motion and have no objections.
For the foregoing reasons, the amici States respectfully request that the amicus curiae brief at
Dkt. 19-1 be deemed filed on November 14, 2018.
Respectfully submitted this 19th day of November, 2018.
ROBERT W. FERGUSON
Washington State Attorney General
/s/ Megan D. Lin
MEGAN D. LIN, SNB # 298267
COLLEEN M. MELODY, WSBA #42275
Civil Rights Division Chief
LAURA K. CLINTON, WSBA #29846
KRISTIN BENESKI, WSBA #45478
Assistant Attorneys General
Office of the Attorney General
800 Fifth Avenue, Suite 2000
Seattle, WA 98104
Tel: (206) 464-5342
MeganL@atg.wa.gov
ColleenM1@atg.wa.gov
LauraC5@atg.wa.gov
KristinB1@atg.wa.gov
Attorneys for the State of Washington
Case 4:18-cv-06810-JST Document 42 Filed 11/19/18 Page 3 of 3