International Refugee Assistance Project v. Trump

Filing 257

RESPONSE/ANSWER by Daniel R. Coats, Department of State, John F. Kelly, Office of the Director of National Intelligence, Rex Tillerson, Donald J. Trump and United States Department of Homeland Security to notice requesting response [251]. [17-1351] Sharon Swingle

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No. 17-1351 IN THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT INTERNATIONAL REFUGEE ASSISTANCE PROJECT, a project of the Urban Justice Center, Inc., on behalf of itself; HIAS, INC., on behalf of itself and its clients; MIDDLE EAST STUDIES ASSOCIATION OF NORTH AMERICA, INC., on behalf of itself and its members; MUHAMMED METEAB; PAUL HARRISON; IBRAHIM AHMED MOHOMED; JOHN DOES #1 & 3; JANE DOE #2, Plaintiffs – Appellees, v. DONALD J. TRUMP, in his official capacity as President of the United States; DEPARTMENT OF HOMELAND SECURITY; DEPARTMENT OF STATE; OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE; JOHN F. KELLY, in his official capacity as Secretary of Homeland Security; REX W. TILLERSON, in his official capacity as Secretary of State; DANIEL R. COATS, in his official capacity as Director of National Intelligence, Defendants – Appellants. On Appeal from the United States District Court for the District of Maryland (8:17-cv-00361-TDC) RESPONSE OF DEFENDANTS-APPELLANTS TO MOTIONS FOR LEAVE TO FILE AS AMICI CURIAE JEFFREY B. WALL Acting Solicitor General EDWIN S. KNEEDLER Deputy Solicitor General CHAD A. READLER Acting Assistant Attorney General ROD J. ROSENSTEIN United States Attorney AUGUST E. FLENTJE Special Counsel to the Assistant Attorney General DOUGLAS N. LETTER SHARON SWINGLE H. THOMAS BYRON III LOWELL V. STURGILL JR. Attorneys, Appellate Staff Civil Division, Room 7241 U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, DC 20530 (202) 353-2689 Defendants-appellants Donald J. Trump, et al. (collectively, the government) submit this response pursuant to the Court’s April 24, 2017 order. The government consents to all pending motions for leave to file amicus briefs. Respectfully submitted, /s/ Sharon Swingle SHARON SWINGLE (202) 353-2689 Attorney, Appellate Staff Civil Division U.S. Department of Justice 950 Pennsylvania Ave., N.W. Room 7520 Washington, D.C. 20530 APRIL 2017 CERTIFICATE OF SERVICE I hereby certify that on April 24, 2017, I electronically filed the foregoing motion for expedited briefing schedule by using the appellate CM/ECF system. I certify that the participants in the case are registered CM/ECF users and that service will be accomplished by the appellate CM/ECF system. /s/ Sharon Swingle Sharon Swingle CERTIFICATE OF COMPLIANCE Pursuant to Federal Rule of Appellate Procedure 32(g)(1), I hereby certify that the foregoing response complies with the typeface and type-style requirements of Federal Rule of Appellate Procedure 27(e)(1)(E) and the type-volume limitations of Federal Rule of Appellate Procedure 27(e)(2). The response contains 35 words as calculated by the Microsoft Word (excluding the portions of the motion excluded by Federal Rules of Appellate Procedure 27(a)(2)(B)) and 32(f)), and has been prepared in a proportionally spaced typeface using 14-point Times New Roman font. /s/ Sharon Swingle Sharon Swingle

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