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

Filing 4

MOTION for Leave to Exceed Page Limits for Memorandum in Support of Plaintiffs' Motion for Preliminary Injunction by Plaintiffs. (Attachments: # 1 Text of Proposed Order) (jtj)

JUN 0 2 2011
.IAC,::::; ii, >''1 11611, CLERK

UNITED STATES DISTRICT COURT
By,
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
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Georgia Latino Alliance for Human
Rights, et aI.,
Plaintiffs,

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Case No.

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Governor Nathan Deal, et aI.,
Defendants.

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PLAINTIFFS' MOTION FOR LEAVE TO EXCEED PAGE LIMITS FOR

MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR

PRELIMINARY INJUNCTION

Pursuant to L.R. 7.1 D, Plaintiffs, by and through counsel, respectfully move
the Court for leave to exceed the page limit for their Memorandum of Law
("Memorandum") in support of Plaintiffs' Motion for Preliminary Injunction.
Plaintiffs anticipate that they will file their Motion for Preliminary Injunction
within seven days, i.e., on or before June 9, 2011.
Plaintiffs are unable to comply with the 25-page limit set forth in L.R. 7.1 D
because: (i) Plaintiffs challenge on myriad grounds the constitutionality of
Georgia's expansive new state immigration system, as established by HB 87

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(signed by Governor Nathan Deal on May 13,2011); (ii) Plaintiffs' Memorandum
addresses the many ways in which HB 87 violates the Supremacy Clause of the
United States Constitution, the Fourth Amendment right to be free from
unreasonable searches and seizures, and the Right to Travel; and (iii) Plaintiffs'
Memorandum demonstrates that the harms that would result to Plaintiffs (which
includes ten organizations and eleven individuals) and the public ifHB 87 were
permitted to go into effect are so substantial and irreparable that the Court should
preliminarily enjoin its enforcement.
Although Plaintiffs have attempted to address all ofthese issues within the
standard 25-page limit, they have been unable to do so given the complexity ofHB
87 and the various claims of unconstitutionality that Plaintiffs raise. Permission to
file a brief in excess of the page limit will provide Plaintiffs with sufficient
opportunity to explain the facts and the law and aid this Court in its review of the
arguments in support of their motion. Plaintiffs respectfully request that the Court
allow them to file a fifty (50 page memorandum in support of their Motion for a
Preliminary Injunction.

Respectfully submitted, 1

Dated: June 2, 2011

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Counsel certifies this document has been prepared in accordance with L.R. 5.1.
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On behalfofAttorneys for Plaintiffs
Omar C. Jadwat*

Andre Segura*

Elora Mukherjee*

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]

Linton Joaquin*

Karen C. Tumlin*

Nora A. Preciado*

Melissa S. Keaney*

NATIONAL IMMIGRATION LAW

CENTER

3435 Wilshire Boulevard, Suite 2850

Los Angeles, California 900 I 0

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]
daniel. [e-mail]
Mary Bauer (GSB No. 142213)

Andrew H. Turner*

Samuel Brooke*

SOUTHERN POVERTY LAW CENTER

400 Washington Ave.

Montgomery, Alabama 36104

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Cecillia D. Wang*

Katherine Desormeau*

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]

T: [phone]
F: [phone]
mary. [e-mail]
andrew. [e-mail]
[e-mail]

G. Brian Spears (GSB No. 670112)
1126 Ponce de Leon Ave., N.E.
Atlanta, Georgia 30306
T: [phone]
F: [phone]
[e-mail]

Tanya Broder*
Jonathan Blazer*
NATIONAL IMMIGRATION LA W
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]
Charles H. Kuck (GSB No. 429940)
Danielle M. Conley (GSB No. 222292)
KUCK IMMIGRATION PARTNERS
LLC
80 I0 Roswel1 Road, Suite 300
Atlanta, Georgia 30350
T: [phone]
F: [phone]
[e-mail]
[e-mail]

Sin Yen Ling*
ASIAN LAW CAUCUS
55 Columbus Avenue
San Francisco, California 94111
T:[phone] x110
F:[phone]
[e-mail]

Attorneys for Plaintiffi
*Application for admission pro hac vice forthcoming

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