United States of America v. State of California et al

Filing 174

NOTICE of Request to Seal Document(s) pursuant to L.R. 141 by United States of America. (Genova, Francesca)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

CHAD A. READLER
Acting Assistant Attorney General
MCGREGOR SCOTT
United States Attorney
AUGUST FLENTJE
Special Counsel
WILLIAM C. PEACHEY
Director
EREZ REUVENI
Assistant Director
DAVID SHELLEDY
Civil Chief, Assistant United States Attorney
LAUREN C. BINGHAM
JOSEPH A. DARROW
KATHRYNE M. GRAY
JOSHUA S. PRESS
Trial Attorneys
FRANCESCA GENOVA
Office of Immigration Litigation
U.S. Department of Justice, Civil Division
450 5th Street NW
Washington, DC 20530
Tel. [phone]
[e-mail]
Attorneys for the United States

16

UNITED STATES DISTRICT COURT

17

EASTERN DISTRICT OF CALIFORNIA

18

THE UNITED STATES OF AMERICA,

19
20
21
22
23
24
25
26
27
28

Plaintiff,
v.
THE STATE OF CALIFORNIA;
EDMUND GERALD BROWN JR.,
Governor of California, in his Official
Capacity; and XAVIER BECERRA,
Attorney General of California, in his
Official Capacity,
Defendants.

Case No. 2:18-cv-490-JAM-KJN
NOTICE OF REQUEST TO SEAL
DOCUMENT IN SUPPORT OF
PLAINTIFF’S REPLY TO DEFENDANTS’
OPPOSTION TO PLAINTIFF’S MOTION
FOR PRELIMINARY INJUNCTION
Date: June 20, 2018
Time: 10:00 a.m.
Courtroom: 6
Judge: The Honorable John A. Mendez
Action Filed: March 6, 2018

1

TO ALL PARTIES AND THEIR COUNSEL OF RECORD:

2

PLEASE TAKE NOTICE THAT Plaintiff the United States of America hereby requests

3

this Court to seal a document submitted in support of Plaintiff’s Reply to Defendant’s Opposition to

4

Plaintiff’s Motion for Preliminary Injunction (ECF 171), pursuant to Local Rule 141 and the Court’s

5

Protective Order (ECF 53). The document that forms the basis of this request is an unredacted version

6

of Exhibit P, Deposition of Joe Dominic, the redacted version of which was filed with the Reply, and

7

which Defendants have designated as confidential, including sensitive law enforcement information.

8

The Request to Seal Document, proposed order, and the unredacted version of Exhibit P have been

9

emailed to this Court’s proposed orders email box in accordance with Local Rule 141(b) and have

10
11
12

been served on all parties.
DATED: June 8, 2018

Respectfully Submitted,
CHAD A. READLER
Acting Assistant Attorney General

13
14

MCGREGOR SCOTT
United States Attorney

15
16

AUGUST FLENTJE
Special Counsel

17

WILLIAM C. PEACHEY
Director

18
19

EREZ REUVENI
Assistant Director

20
21

DAVID SHELLEDY
Civil Chief, Assistant United States Attorney

22

/s/ Francesca Genova
FRANCESCA GENOVA
LAUREN C. BINGHAM
JOSEPH A. DARROW
KATHRYNE M. GRAY
JOSHUA S. PRESS
Trial Attorneys
U.S. Department of Justice, Civil Division

23
24
25
26
27
28
-1-

Office of Immigration Litigation
450 5th St NW
Washington, DC 20530
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]

1
2
3
4

Attorneys for Plaintiff

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-2-