United States of America v. State of California et al

Filing 31

MOTION for 11-DAY EXTENSION OF TIME by United States of America to Allow Amicus Filings On Plaintiff's Behalf re 17 Minute Order. (Press, Joshua) Modified on 3/26/2018 (Donati, J).

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CHAD A. READLER
Acting Assistant Attorney General
MCGREGOR SCOTT
United States Attorney
AUGUST FLENTJE
Special Counsel

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WILLIAM C. PEACHEY
Director
EREZ REUVENI
Assistant Director
DAVID SHELLEDY
Civil Chief, Assistant United States Attorney
LAUREN C. BINGHAM
JOSEPH A. DARROW
JOSHUA S. PRESS
Trial Attorneys
United States Department of Justice
Civil Division
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Telephone: [phone]
Facsimile: [phone]
e-Mail: [e-mail]

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Attorneys for the United States of America
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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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NO. 2:18–CV–00490-JAM-KJN

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UNITED STATES OF AMERICA,
Plaintiff,
v.
STATE OF CALIFORNIA, et al.,
Defendants.

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Unopposed Motion to Extend
Time For Amici Curiae Filings

UNOPPOSED MOTION
TO EXTEND TIME FOR
AMICI CURIAE FILINGS
Judge: Hon. John A. Mendez
NO HEARING NOTICED

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The United States of America hereby respectfully moves for an eleven (11) day extension

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of time, up to and including April 6, 2018, for amicus briefing in support of the Plaintiff in this

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matter. The grounds for this motion are as follows:

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1.

On March 12, 2018, the Court set a deadline of “amicus briefs in support of

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Plaintiff[’]s motion” for a preliminary injunction of March 26, 2018. ECF No. 17. The Court also

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referred expedited discovery matters to Magistrate Judge Newman. See id.

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2.

Since that time, multiple requests have been received by all parties and this Court’s

Clerk regarding the standards and timeline for amicus filings.

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3.

On March 22, 2018, Judge Newman ordered that expedited discovery

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(specifically, depositions of Plaintiff’s declarants) must conclude by April 13, 2018. See ECF No.

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28 at 2.

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4.

Judge Newman’s order has therefore extended the timeframe for this Court’s

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consideration of the United States’ Motion for a Preliminary Injunction. ECF No. 2. The United

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States therefore respectfully believes that it would be reasonable for amicus briefing to be adjusted

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accordingly.

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5.

Counsel for the United States and Defendants have conferred and agree that this

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revised timetable will assist the Court in expeditiously deciding the pending motion for a

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preliminary injunction, is not for the purpose of undue delay, and will not prejudice either party.

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CONCLUSION

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For the reasons set forth above, the United States respectfully requests the Court grant this

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unopposed motion and extend the deadline for amicus briefing on behalf of the Plaintiff by eleven

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(11) days.

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//

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//

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Unopposed Motion to Extend
Time For Amici Curiae Filings

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Respectfully submitted,
DATED: March 23, 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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EREZ REUVENI
Assistant Director

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DAVID SHELLEDY
Civil Chief, Asst. United States Attorney

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LAUREN C. BINGHAM
JOSEPH A. DARROW
Trial Attorneys

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/s/ Joshua S. Press
JOSHUA S. PRESS
Trial Attorneys
United States Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Phone: [phone]
[e-mail]

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Attorneys for the United States of America

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Unopposed Motion to Extend
Time For Amici Curiae Filings

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CERTIFICATE OF SERVICE

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I hereby certify that on March 23, 2018, I electronically transmitted the foregoing

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document to the Clerk’s Office using the U.S. District Court for the Eastern District of

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California’s Electronic Document Filing System (ECF), which will serve a copy of this document

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upon all counsel of record.

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By: /s/ Joshua S. Press
JOSHUA S. PRESS
Trial Attorney
United States Department of Justice
Civil Division

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Unopposed Motion to Extend
Time For Amici Curiae Filings

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