Order - East Bay Sanctuary v. Trump, (2018-11-29)

Source document: Order - East Bay Sanctuary v. Trump, (2018-11-29); document type: Notice of Filing of the Administrative Record.

Full text

NOTICE OF FILING OF THE ADMINISTRATIVE RECORD
East Bay Sanctuary v. Trump,

Case No. 3:18-cv-06810-JST

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JOSEPH H. HUNT
Assistant Attorney General
SCOTT G. STEWART
Deputy Assistant Attorney General
AUGUST E. FLENTJE
Special Counsel
WILLIAM C. PEACHEY
Director
EREZ REUVENI
Assistant Director
CHRISTINA P. GREER
Trial Attorney
Office of Immigration Litigation
U.S. Department of Justice, Civil Division
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Tel: (202) 598-8770
Email: Christina.P.Greer@usdoj.gov
PATRICK GLEN
Senior Litigation Counsel
JOSEPH DARROW
FRANCESCA GENOVA
Trial Attorneys

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

)
East Bay Sanctuary Covenant, et al.,
)
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Plaintiffs,

)
)
v.
)
NOTICE OF FILING OF THE

)
ADMINISTRATIVE RECORD

)
Civil Action No. 3:18-cv-06810-JST
)
Donald J. Trump, President of the United    )
States, et al.,
)

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Defendants.

)

)

Case 3:18-cv-06810-JST   Document 60   Filed 11/29/18   Page 1 of 4

NOTICE OF FILING OF THE ADMINISTRATIVE RECORD
East Bay Sanctuary v. Trump,

Case No. 3:18-cv-06810-JST

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Defendants, by and through undersigned counsel, today served on Plaintiffs the
administrative record for purposes of this lawsuit.  That record, certified by relevant officials at
the Departments of Homeland Security and Justice, contains all materials—to the best of the
certifiers’ knowledge, information, and belief—considered by the Departments in promulgating
the interim final rule titled “Aliens Subject to a Bar on Entry Under Certain Presidential
Proclamations; Procedures for Protection Claims,” and issued November 9, 2018.  See 83 Fed.
Reg. 55934.  Defendants have served the record via email, and are sending a copy separately via
U.S. mail.  Defendants today are also providing the court with a paper copy of the record.

Defendants also respectfully note that they reserve the right to supplement the record if
they identify additional materials that were part of the record subsequent to this filing.  The interim
final rule is premised on significant factual material contained in myriad documents held between
two agencies and their subcomponents. Complex coordination between these agencies is required
to produce a full and complete record, as recognized by this Court’s Local Rule providing the
Government 90 days following the summons to compile and certify a record in the normal course.
See Local Rule 16-5.  The Departments have been working diligently to compile the administrative
record since before this Court’s scheduling order (ECF No. 50), but given the extremely truncated
time in which the Defendants have been required to produce a record, it remains possible that
supplementation may be warranted.
//
//

Case 3:18-cv-06810-JST   Document 60   Filed 11/29/18   Page 2 of 4

NOTICE OF FILING OF THE ADMINISTRATIVE RECORD
East Bay Sanctuary v. Trump,

Case No. 3:18-cv-06810-JST

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Respectfully submitted,

JOSEPH H. HUNT
Assistant Attorney General

SCOTT G. STEWART
Deputy Assistant Attorney General

AUGUST E. FLENTJE
Special Counsel

WILLIAM C. PEACHEY
Director

EREZ REUVENI
Assistant Director

      By: /s/ Christina P. Greer
CHRISTINA P. GREER
Trial Attorney
Office of Immigration Litigation
U.S. Department of Justice, Civil Division
450 5th Street NW
Washington, DC 20530
Tel: (202) 598-8770
Email: Christina.P.Greer@usdoj.gov

EREZ REUVENI
Assistant Director

PATRICK GLEN
Senior Litigation Counsel

JOSEPH DARROW
FRANCESCA GENOVA
Trial Attorneys

Dated: November 29, 2018

Attorneys for Defendants

Case 3:18-cv-06810-JST   Document 60   Filed 11/29/18   Page 3 of 4

NOTICE OF FILING OF THE ADMINISTRATIVE RECORD
East Bay Sanctuary v. Trump,

Case No. 3:18-cv-06810-JST

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CERTIFICATE OF SERVICE

I hereby certify that on November 29, 2018, I electronically filed the foregoing document
with the Clerk of the Court for the United States Court of for the Northern District of California
by using the CM/ECF system. Counsel in the case are registered CM/ECF users and service will
be accomplished by the CM/ECF system.

     By:  /s/ Christina P. Greer

CHRISTINA P. GREER

Trial Attorney

United States Department of Justice

Civil Division

Case 3:18-cv-06810-JST   Document 60   Filed 11/29/18   Page 4 of 4

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