Georgia Latino Alliance for Human Rights et al v. Deal et al

Filing 30

MOTION to Expedite Consideration of Motion for Preliminary Injunction and for Expedited Hearing by Alterna, Asian American Legal Advocacy Center, Paul Bridges, Coalition for the People's Agenda, Coalition of Latino Leaders, DREAM Activist.org, Jane Doe # 1, John Doe # 1, Jane Doe # 2, John Doe # 2, Paul J. Edwards, Georgia Latino Alliance for Human Rights, Sharon Gruner, Everitt Howe, Instituto de Mexico, Inc. of Atlanta, Ernesto Pinon, Service Employees International Union, Southern Regional Joint Board of Workers' United, Benjamin Speight, Task Force for the Homeless. (Lapointe, Michelle)

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
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Georgia Latino Alliance for Human
Rights, et al.,
Plaintiffs,
v.
Governor Nathan Deal, et al.,
Defendants.

Case No. 1:11-cv-01804-TWT

MOTION FOR EXPEDITED CONSIDERATION
Pursuant to LR 65.2, NDGa., Plaintiffs respectfully move the Court for
expedited consideration of the Motion for Preliminary Injunction (ECF No. 29)
and expedited scheduling of a hearing on this Motion. In support thereof, Plaintiffs
state as follows:
Plaintiffs filed the complaint (ECF No. 1) in this matter on June 2, 2011,
challenging Georgia’s comprehensive immigration bill, House Bill 87 (“HB 87”),
which was signed by Governor Deal on May 13, 2011 and is scheduled to take
effect on July 1, 2011. Plaintiffs seek declaratory and injunctive relief to block
Defendants’ enforcement of this law. On June 8, 2011, Plaintiffs filed the instant
Motion for Preliminary Injunction (ECF No. 29), alleging irreparable harm should
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HB 87 be permitted to go into effect. Given the imminent enforcement date of the
law and the significant constitutional issues raised in the complaint and motion,
Plaintiffs seek expedited consideration of the motion, including expedited
scheduling of a briefing schedule and hearing on the motion.
Counsel for Plaintiffs have been informed that the Senior Assistant Attorney
General assigned to this case will be on leave from June 22-29, but is available to
participate in a hearing on this matter the week of June 13-17, June 20, or June 21,
2011. Plaintiffs’ counsel are available to participate in a hearing on any date in
June.
Wherefore, Plaintiffs respectfully request that the Court grant the Motion for
Expedited Consideration and set a briefing schedule and a hearing date on the
Motion for Preliminary Injunction on a date convenient to the Court’s calendar that
allows consideration and resolution of the merits prior to July 1, 2011.

Respectfully submitted,1

Dated: June 8, 2011

/s/ Michelle R. Lapointe
On behalf of Attorneys for Plaintiffs
Omar C. Jadwat*
Andre Segura*
Elora Mukherjee*

Linton Joaquin (pro hac vice)
Karen C. Tumlin (pro hac vice)
1

Counsel certifies this document has been prepared in accordance with L.R. 5.1.
2

AMERICAN CIVIL LIBERTIES UNION
FOUNDATION
125 Broad Street, 18th Floor
New York, New York 10004
T: [phone]
F: [phone]
[e-mail]
[e-mail]
[e-mail]

Nora A. Preciado*
Melissa S. Keaney (pro hac vice)
NATIONAL IMMIGRATION LAW
CENTER
3435 Wilshire Boulevard, Suite 2850
Los Angeles, California 90010
T: [phone]
F: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Naomi Tsu (GSB No. 507612)
Michelle R. Lapointe (GSB No. 007080)
Daniel Werner (GSB No. 422070)
SOUTHERN POVERTY LAW CENTER
233 Peachtree St., NE, Suite 2150
Atlanta, Georgia 30303
T: [phone]
F: [phone]
[e-mail]
[e-mail]
[e-mail]
Mary Bauer (GSB No. 142213)
Andrew H. Turner*
Samuel Brooke*
SOUTHERN POVERTY LAW CENTER
400 Washington Ave.
Montgomery, Alabama 36104
T: [phone]
F: [phone]
[e-mail]
[e-mail]
[e-mail]

Cecillia D. Wang (pro hac vice)
Katherine Desormeau (pro hac vice)
AMERICAN CIVIL LIBERTIES
UNION FOUNDATION IMMIGRANTS’
RIGHTS PROJECT
39 Drumm Street
San Francisco, California 94111
T: [phone]
F: [phone]
[e-mail]
[e-mail]
Chara Fisher Jackson (GSB No. 386101)
Azadeh N. Shahshahani (GSB No.
509008)
ACLU OF GEORGIA
1900 The Exchange, Suite 425
Atlanta, Georgia 30339
T: [phone]
[e-mail]
[e-mail]

G. Brian Spears (GSB No. 670112)
1126 Ponce de Leon Ave., N.E.
Atlanta, Georgia 30306

Tanya Broder (pro hac vice)
Jonathan Blazer*
3

T: [phone]
F: [phone]
[e-mail]

NATIONAL IMMIGRATION LAW
CENTER
405 14th Street, Suite 1400
Oakland, California 94612
T: [phone]
F: [phone]
[e-mail]
[e-mail]

R. Keegan Federal, Jr. (GSB No. 257200)
FEDERAL & HASSON, LLP
Two Ravinia Drive, Ste 1776
Atlanta, Georgia 30346
T: [phone]
F: [phone]

Sin Yen Ling*
ASIAN LAW CAUCUS
55 Columbus Avenue
San Francisco, California 94111
T: [phone] x 110
F: [phone]
[e-mail]

Charles H. Kuck (GSB No. 429940)
Danielle M. Conley (GSB No. 222292)
KUCK IMMIGRATION PARTNERS
LLC
8010 Roswell Road, Suite 300
Atlanta, Georgia 30350
T: [phone]
F: [phone]
[e-mail]
[e-mail]

Attorneys for Plaintiffs
*Application for admission pro hac vice pending

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CERTIFICATE OF SERVICE
I hereby certify that I have this date electronically filed the foregoing with the
Clerk of Court using the CM/ECF system, which will automatically send e-mail
notification to the following attorney for Defendants Deal, Olens, Reese, and
Beatty, to whom a copy is also being hand-delivered today:
Devon Orland
Office of State Attorney General
40 Capitol Square, S.W.
Atlanta, GA 30334-1300
[e-mail]
Attorney for Defendants Deal, Olens, Reese and Beatty
I hereby certify that a copy of the foregoing is being hand-delivered on this date to
the following non-CM/ECF participant:
Falecia Stewart
Executive Director, Housing Authority of Fulton County
HAFC Headquarters
4273 Wendell Drive
Atlanta, GA 30336
This 8th day of June, 2011.
/s/ Michelle R. Lapointe