Motion - East Bay Sanctuary v. Trump, (2018-12-12)

Summary

Document 88-1, a proposed order granting a motion to strike, filed December 12, 2018 with a U.S. Department of Justice, Civil Division attorney block, in East Bay Sanctuary Covenant, et al. v. Donald J. Trump, President of the United States, et al., Civil Action No. 3:18-cv-06810-JST, in the U.S. District Court for the Northern District of California. The proposed order would strike a list of declarations, identified by ECF number, and the citations to them in the plaintiffs' Motion for Temporary Restraining Order (ECF No. 8-1), reply (ECF No. 35) and Motion for Preliminary Injunction (ECF No. 71). It would also strike specified page citations to further declarations in those briefs. It would strike citations to non-record news articles and internet documents in footnotes of those filings. The two-page proposed order leaves the date and judge's signature blank.

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Full text

                 Case 4:18-cv-06810-JST Document 88-1 Filed 12/12/18 Page 1 of 2




     JOSEPH H. HUNT
 1
     Assistant Attorney General
 2   SCOTT G. STEWART
     Deputy Assistant Attorney General
 3   AUGUST E. FLENTJE
     Special Counsel
 4
     WILLIAM C. PEACHEY
 5   Director
     EREZ REUVENI
 6   Assistant Director
 7   CHRISTINA P. GREER
     Trial Attorney
 8   Office of Immigration Litigation
     U.S. Department of Justice, Civil Division
 9   P.O. Box 868, Ben Franklin Station
10   Washington, DC 20044
     Tel: (202) 598-8770
11   Email: Christina.P.Greer@usdoj.gov
     PATRICK GLEN
12   Senior Litigation Counsel
13   JOSEPH DARROW
     FRANCESCA GENOVA
14   KATHRYNE GRAY
     BENTON YORK
15   Trial Attorneys
16
17
18
                                     UNITED STATES DISTRICT COURT
19                             FOR THE NORTHERN DISTRICT OF CALIFORNIA

20
                                               )
21
      East Bay Sanctuary Covenant, et al.,     )
22                                             )
                      Plaintiffs,              )    [PROPOSED] ORDER GRANTING
23                                             )    MOTION TO STRIKE
24                                             )
      v.                                       )    Civil Action No. 3:18-cv-06810-JST
25                                             )
      Donald J. Trump, President of the United )
26    States, et al.,                          )
27                                             )
                      Defendants.              )
28                                             )


     [PROPOSED] ORDER
     East Bay Sanctuary v. Trump,
     Case No. 3:18-cv-06810-JST
                 Case 4:18-cv-06810-JST Document 88-1 Filed 12/12/18 Page 2 of 2




 1             The Court GRANTS Defendants’ Motion to Strike and hereby strikes the following:
 2        (1) Isacson Declaration (ECF No. 8-2), Goodwin-Gill Declaration (ECF No. 8-5), Chavla
 3             Declaration (ECF No. 35-1), Cutlip-Mason Declaration (ECF No. 35-2), Griffey
 4             Declaration (ECF No. 35-3), Supplemental Isacson Declaration (ECF No. 35-4), Love
 5             Declaration (ECF No. 35-5), Supplemental Manning Declaration (ECF No. 35-6), Penman
 6             Declaration (ECF No. 35-7), Rodriguez Declaration (ECF No. 35-9), Seyler Declaration
 7             (ECF No. 35-10), Former Officials’ Joint Declaration (ECF No. 71-4), Slack Declaration
 8             (ECF No. 71-5), Mitchell-Bennet Declaration (ECF No. 71-6), Brané Declaration (ECF
 9             No. 71-7), Supplemental Penman Declaration (ECF No. 71-9), and Corrected Ramos
10             Declaration (ECF 84-1) and citations thereto in Plaintiffs’ Motion for Temporary
11             Restraining Order (ECF No. 8-1), Reply in Support of Motion for Temporary Restraining
12             Order (ECF No. 35), and Motion for Preliminary Injunction (ECF No. 71);
13        (2) the citations to the Sharp Declaration (ECF No. 8-3) at page 14 of ECF No. 71; the Pinheiro
14             Declaration (ECF No. 8-4) on pages 8 and 15 of ECF No. 8-1, pages 10 and 14 (the second
15             citation) of ECF No. 35, and pages 12 and 14 of ECF No. 71; the Manning Declaration
16             (ECF No. 8-6) at page 8 of ECF No. 8-1 and page 14 of ECF No. 71; the Smith Declaration
17             (ECF No. 8-7) at page 14 of ECF No. 71; the Supplemental Pinheiro Declaration (ECF No.
18             35-8) at pages 7-8 and 14 of ECF No. 35; the Corrected Supplemental Pinheiro Declaration
19             (ECF No. 71-2) at pages 10 and 12-13 of ECF No. 71; and the Ramos Declaration (ECF
20             No. 71-8) at pages 7, 10, 12-13, and 17 of ECF No. 71; and
21        (3) the citations to non-record news articles and internet documents at page 10 n.5 of ECF No.
22             8-1; pages 4 n.3 and 9 & n.8 of ECF No. 35; and page 19 n.4 of ECF No. 71.
23
24             IT IS SO ORDERED.
25
     Issued this _____ day of __________________________, 201__.
26
27                                                                ____________________________
                                                                  United States District Judge
28



     [PROPOSED] ORDER
     East Bay Sanctuary v. Trump,
     Case No. 3:18-cv-06810-JST


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