International Refugee Assistance Project v. Trump

Filing 157

MOTION by leave to file amicus curiae Brief [148]. Date and method of service: 04/19/2017 ecf. [1000064885] [17-1351] Benna Solomon

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No. 17-1351 IN THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT INTERNATIONAL REFUGEE ASSISTANCE PROJECT, et al., Plaintiffs-Appellees, v. DONALD J. TRUMP, et al., Defendants-Appellants. ) ) ) ) ) ) ) ) ) ) Appeal from the United States District Court for the District of Maryland No. 8:17-cv-00361-TDC The Honorable Theodore D. Chuang, Judge Presiding MOTION FOR LEAVE TO FILE BRIEF AND APPENDIX OF CHICAGO, LOS ANGELES, NEW YORK, PHILADELPHIA, AND OTHER MAJOR CITIES AND COUNTIES AS AMICI CURIAE IN SUPPORT OF PLAINTIFFS-APPELLEES AS IS _______________________________________________________________ Chicago, Los Angeles, New York, Philadelphia, and other major U.S. cities and counties respectfully submit this motion for leave to file their brief and appendix as is as amici curiae in support of affirmance and in opposition to the motion to stay the preliminary injunction. 1. The court issued a brief correction notice on April 19, 2016 regarding the appendix included with our brief amicus curiae, and requesting that the appendix be filed under separate cover and with a motion for leave to file the separate appendix as an addendum to supplement the brief. 2. The appendix includes citations and additional data supporting arguments in our brief, and was included with our brief to document the information on which we rely for the convenience of the court. The brief and the appendix together are 6,371 words, as certified by our certificate of compliance. That is under the word limit for an amicus brief on the merits. 3. After a discussion between an attorney in my office and the Clerk’s Office of this Court, we were advised, rather than refiling the brief with a separate appendix, to file a motion for leave to file the brief and appendix as is. WHEREFORE, amici respectfully request that this Court grant them leave to file their previously tendered amicus brief and appendix as is. 2 Respectfully submitted, s/Benna Ruth Solomon RYAN P. POSCABLO BRIAN NEFF ELIBERTY LOPEZ Riley Safer Holmes & Cancila LLP 1330 Avenue of the Americas, 6th Floor New York, NY 10019 (212) 660-1030 rposcablo@rshc-law.com EDWARD N. SISKEL Corporation Counsel of the City of Chicago BENNA RUTH SOLOMON Deputy Corporation Counsel 30 N. LaSalle Street, Suite 800 Chicago, IL 60602 (312) 744-7764 benna.solomon@cityofchicago.org NICK KAHLON Riley Safer Holmes & Cancila LLP Three First National Plaza 70 W. Madison Street, Suite 2900 Chicago, IL 60602 (312) 471-8700 nkahlon@rshc-law.com Attorneys for Amicus Curiae, City of Chicago Attorneys for Amicus Curiae, City of Chicago 3 CERTIFICATE OF SERVICE I hereby certify that on April 19, 2017, I electronically filed the foregoing Motion for Leave to File Brief and Appendix of Chicago, Los Angeles, New York, Philadelphia, and Other Major Cities and Counties as Amici Curiae in Support of Plaintiffs-Appellees As Is with the Clerk of the Court for the United States Court of Appeals for the Fourth Circuit by using the appellate CM/ECF system. Participants in the case who are registered CM/ECF users will be served by the appellate CM/ECF system. s/Benna Ruth Solomon BENNA RUTH SOLOMON Deputy Corporation Counsel of the City of Chicago 30 N. LaSalle Street, Suite 800 Chicago, IL 60602 (312) 744-7764 benna.solomon@cityofchicago.org

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