United States of America v. State of California et al

Filing 2

MOTION for PRELIMINARY INJUNCTION by United States of America. (Attachments: # 1 Memorandum, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Proposed Order)(Reuveni, Erez)

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CHAD A. READLER
Acting Assistant Attorney General
MCGREGOR SCOTT
United States Attorney
AUGUST FLENTJE
Special Counsel
WILLIAM C. PEACHEY
Director
EREZ REUVENI
Assistant Director, Office of Immigration Litigation
U.S. Department of Justice, Civil Division
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Tel. [phone]
[e-mail]
DAVID SHELLEDY
Civil Chief, Assistant United States Attorney
LAUREN C. BINGHAM
JOSEPH A.DARROW
JOSHUA S. PRESS
Trial Attorneys
Attorneys for the United States

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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THE UNITED STATES OF AMERICA,

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Plaintiff,

No. 18-264

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.

NOTICE OF MOTION AND MOTION
FOR PRELIMINARY INJUNCTION

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NOTICE

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Notice is hereby given that the United States of America makes the following motion,

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which it proposes to notice for a hearing on April 5, 2018 at a as of yet to be determined

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courtroom.

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MOTION
The United States hereby moves for a preliminary injunction enjoining enforcement of

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certain provisions of California law enacted through Assembly Bill 450 (“AB 450”), Assembly

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Bill 103 (“AB 103”), and Senate Bill 54 (“SB 54”). As detailed in the accompanying proposed

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order, the United States respectfully requests that this Court preliminarily enjoin Sections 7285.1,

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7285.2, 7284.6(a)(1)(C) & (D), 7284.6(a)(4), and 12532 of the California Government Code, and
Sections 90.2 and 1019.2 of the California Labor Code.
This motion is based on the memorandum and exhibits filed herewith, and the pleadings

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on file.
DATED: March 6, 2018

CHAD A. READLER
Acting Assistant Attorney General

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MCGREGOR SCOTT
United States Attorney

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AUGUST FLENTJE
Special Counsel

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WILLIAM C. PEACHEY
Director

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/s/ Erez Reuveni
EREZ REUVENI
Assistant Director
U.S. Department of Justice, Civil Division
Office of Immigration Litigation
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]

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Notice of Motion and Motion

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DAVID SHELLEDY
Civil Chief, Assistant United States
Attorney

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LAUREN BINGHAM
JOSEPH A. DARROW
JOSHUA S. PRESS
Trial Attorneys

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Attorneys for Plaintiff

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Notice of Motion and Motion

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