Intl. Refugee Assistance v. Donald J. Trump
Filing
151
MOTION by Potential Amicus Curiae Massachusetts Technology Leadership Counsel, Inc. in 17-2231, 17-2232, 17-2233 to file amicus curiae brief (FRAP 29(e)) without consent of all parties on appeal outside time allowed by FRAP 29(e).. Date and method of service: 11/28/2017 ecf. [1000199530] [17-2231, 17-2232, 17-2233, 17-2240] Gare Smith [Entered: 11/28/2017 05:48 PM]
17-2231 (L), 17-2232, 17-2233, 17-2240 (Consolidated)
__________________________________________________________________
IN THE UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
__________________________________________________________________
INTERNATIONAL REFUGEE ASSISTANCE PROJECT, et al.
Plaintiffs-Appellees,
and
ALLAN HAKKY and SAMANEH TAKALOO
Plaintiffs,
v.
DONALD TRUMP, et al.
Defendants-Appellants
_________________________________
On Appeal from the United States District Court for the District of Maryland
________________________________
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.
Pursuant to the Court’s October 31, 2017 and November 22, 2017 Orders,
Massachusetts Technology Leadership Council, Inc., (MassTLC), respectfully
moves this Court for leave to file its proposed amicus curiae brief in support of the
Plaintiffs. (On November 17, 2017, MassTLC previously requested leave to file its
proposed amicus curiae brief, but the Court subsequently requested that MassTLC
re-file its motion in order to cure a filing defect with regard to an attached
addendum.)
Appellees have consented to the filing of this amicus brief. Appellants take
no position on this motion.
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 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
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 its amicus curiae brief.
Dated: Washington, D.C., November 28, 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.
CERTIFICATE OF SERVICE
I certify that on November 28, 2017, the foregoing motion was served on all
interested parties or their counsel of record through the CM/ECF system.
/s/ Gare 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.
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