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

Filing 59

MOTION for Leave to File Excess Pages by Mike Beatty, Nathan Deal, Samuel S. Olens, Clyde L. Reese, III. (Attachments: # 1 Text of Proposed Order Proposed Order)(Orland, Devon)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
GEORGIA LATINO ALLIANCE *
FOR HUMAN RIGHTS, et al.,
*
*
Plaintiffs ,
*
*
V.
*
*
NATHAN DEAL, Governor of the *
State of Georgia, et al.,
*
*
Defendants.

1:11-CV-1804-TWT

MOTION TO EXCEED TWENTY-FIVE PAGE LIMIT
Defendants Nathan Deal; Samuel S. Olens, Clyde L. Reese, III, and Mike
Beatty respectfully request leave to file their Brief in support of their Motion to
Dismiss which exceeds the twenty-five page limit for Briefs under Local Rule 7.1.
Defendants show that it is necessary for Defendants to exceed the usual page limit
in order to fully respond to Plaintiff’s complaint.
Plaintiffs have filed an 80-page, 195-paragraph Complaint, enumerating six
counts on behalf of 21 Plaintiffs.

The Plaintiffs pose a facial constitutional

challenge to a state statue and seek to enjoin its effect. Plaintiffs have filed a Brief
in Support of their Motion for Preliminary Injunction which is 60 pages in length.
Defendants need the additional pages to fully brief the pending motion seeking

preliminary injunctive relief. Defendants believe that the additional pages are
required to adequately address the issues involved.
For the foregoing reasons, Defendants Nathan Deal, Samuel S. Olens, Clyde
L. Reese, III, and Mike Beatty respectfully request that this Court grant their
Motion to Exceed Twenty-Five Page Limit and allow them to file a brief that is no
longer than 30 pages in length.
This 16th day of June, 2011.
Respectfully submitted,
SAMUEL S. OLENS
Attorney General

551540

KATHLEEN PACIOUS
Deputy Attorney General

558555

/s/ Devon Orland
DEVON ORLAND
554301
Sr. Assistant Attorney General
Please Address All
Communications To:
Devon Orland
40 Capitol Square, S.W.
Atlanta, GA 30334-1300
[phone] / Fax: [phone]

CERTIFICATE OF COMPLIANCE

Pursuant to Local Rule 7.1(D), I hereby certify that the foregoing has been
prepared in compliance with Local Rule 5.1(B) in 14-point New Times Roman
type face.
This the 16th day of June, 2011.

/s/ Devon Orland
DEVON ORLAND
554301
Sr. Assistant Attorney General

40 Capitol Square, S.W.
Atlanta, GA 30334-1300
[phone] (Telephone)
[phone] (Fax)
Email: [e-mail]

CERTIFICATE OF SERVICE
I hereby certify that on this date I electronically filed the foregoing
MOTION TO EXCEED PAGE LIMIT, and Draft order with the Clerk
of Court using the CM/ECF system which will automatically send email
notification of such filing to the following attorneys of record:

Andrew H. Turner
Chara Fisher Jackson
Charles H. Kuck
Daniel Werner
Danielle M. Conley
Georgia Brian Spears
Mary C. Bauer
Michelle R. Lapointe
Naomi Ruth Tsu
Robert Keegan Federal, Jr.
Samuel Brooke

I further certify that I have served, by U.S. mail, first class postage
prepaid, the following non-CM/ECF participants:

Andre I. Segura
Omar C. Jadwat
American Civil Liberties Union Foundation – NY
125 Broad Street, 18th Floor
New York, NY 10004
Azadeh N. Shahshahani
ACLU of Georgia
Building 400, Suite 425
1900 The Exchange, SE
Atlanta, GA 30339
Cecillia D. Wang
Katherine Desormeau
ACLU Immigrant’s Rights Project
39 Drumm Street
San Francisco, CA 94111
Elora Mukherjee
ACLU Racial Justice Program
18th Floor, 125 Broad Street
New York, NY 10004
Jonathan Blazer
Karen C. Tumlin
Linton Joaquin
Melissa S. Keaney
Nora Preciado
Tanya Broder
National Immigration Law Center
3435 Wilshire Blvd, Suite 2850
Los Angles, CA 90010

Sin Yen Ling
Asian Law Caucus
55 Columbus Avenue
San Fancisco, CA 94111

This 16th day of June, 2011.

s/ Devon Orland
State Law Department
40 Capitol Square SW
Atlanta, GA 30334
Tel: [phone]
Fax: [phone]
Email: [e-mail]