Intl. Refugee Assistance v. Donald J. Trump
Filing
152
MOTION by Potential Amicus Curiae Massachusetts Technology Leadership Counsel, Inc. in 17-2231, 17-2232, 17-2233 file addendum/attachment to Amicus Brief.. Date and method of service: 11/28/2017 ecf. [1000199531] [17-2231, 17-2232, 17-2233, 17-2240] Gare Smith [Entered: 11/28/2017 05:50 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 AN ADDENDUM TO ITS
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 Local Rule 28(b) and this Court’s November 22, 2017 Order,
Massachusetts Technology Leadership Council, Inc., (MassTLC) respectfully
moves this Court for leave to file an addendum to its proposed amicus curiae brief
in support of the Plaintiffs.
On November 17, 2017, MassTLC previously requested leave to file a
proposed amicus curiae brief which included the attached addendum, but the Court
subsequently requested that MassTLC specifically request leave to file the attached
as an addendum.
Appellees have consented to the filing of this document. 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.
The addendum is a report created by MassTLC in July 2017 to present an
analysis of voluminous information relating to the importance of immigration to
the technology sector. The proposed amicus curiae brief substantially refers to the
data in this report. MassTLC accordingly seeks to file this report as an addendum
for this Court’s convenience and reference.
MassTLC further submits its amicus brief 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 both its proposed amicus brief and its report 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 the addendum to 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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