International Refugee Assistance Project v. Trump

Filing 208

Corrected MOTION by Amicus Supporting Appellee Massachusetts Technology Leadership Council leave to file Amicus Brief Motion for leave to file [168]. Date and method of service: 04/21/2017 ecf. [1000066448] [17-1351] Gare Smith

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17-1351 __________________________________________________________________ IN THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT __________________________________________________________________ INTERNATIONAL REFUGEE ASSISTANCE PROJECT, et al. Plaintiffs-Appellees, v. DONALD TRUMP, et al. Defendants-Appellants _________________________________ On Appeal from the United States District Court for the District of Maryland ________________________________ CORRECTED MOTION FOR LEAVE OF MASSACHUSETTS TECHNOLOGY LEADERSHIP COUNCIL, INC., TO FILE AMICUS BRIEF IN SUPPORT OF PLAINTIFFS-APPELLEES’ RESPONSE BRIEF Gare A. Smith Michael B. Keating Kristyn M. DeFilipp Christopher E. Hart Daniel L. McFadden FOLEY HOAG LLP 1717 K Street NW Washington, D.C. 20006 Attorneys for Amicus Curiae MASSACHUSETTS TECHNOLOGY LEADERSHIP COUNCIL, INC. B4676294.1 Massachusetts Technology Leadership Council, Inc., (MassTLC), respectfully moves this Court for leave to file its proposed amicus curiae brief, attached hereto as Exhibit A, in support of the Plaintiffs’ motion for a temporary restraining order in the above-captioned matter. The Parties have not consented to the filing of this amicus brief. In support of this motion, MassTLC states that it is an association of companies that collectively employ more than 170,000 people in the Massachusetts technology industry. MassTLC represents a vibrant and growing community of innovators in fields including the software, computers, robotics, and security products. MassTLC therefore closely follows issues—including immigration policy—that may affect the ability of its members to build value, attract talent, and compete in the diverse global marketplace. MassTLC filed a brief addressing these issues in the challenge brought in the District of Hawaii. Brief of Amici Curiae Massachusetts Technology Leadership Council, Inc., Hawai’I v. Trump, No. 17cv-00050 (D. Haw. Mar. 15, 2017). MassTLC submits this amicus in order to explain that the President’s revised travel ban is not only unlawful, but also harmful to the technology sector generally and in Massachusetts specifically, and that restraint of that travel ban is therefore in the public interest. MassTLC respectfully submits that its proposed amicus brief contains argument and analysis that will assist in a case of general public interest B4676294.1 and supplement the efforts of counsel, and that the Court should therefore exercise its discretion to allow the proposed brief to be filed. Accordingly, for the foregoing reasons, MassTLC respectfully requests that the Court grant this Motion and accept the amicus curiae brief attached hereto as Exhibit A and filed as Docket 197. Dated: Washington, D.C., April 21, 2017 /s/__Gare A. Smith_________ GARE SMITH MICHAEL B. KEATING KRISTYN DeFILIPP CHRISTOPHER E. HART DANIEL L. McFADDEN FOLEY HOAG LLP 1717 K Street NW Washington, D.C. 20006 Attorneys for Amicus Curiae MASSACHUSETTS TECHNOLOGY LEADERSHIP COUNCIL, INC. B4676294.1

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