State of Hawaii v. Trump

Filing 299

Consent MOTION for Leave to File Excess Pages Brad P. Rosenberg appearing for Defendants John F. Kelly, Rex Tillerson, Donald J. Trump, U.S. Department of Homeland Security, U.S. Department of State, United States of America (Attachments: #1 Proposed Order, #2 Certificate of Service)(Rosenberg, Brad)

JEFFREY B. WALL
Acting Solicitor General
CHAD A. READLER
Acting Assistant Attorney General
ELLIOT ENOKI (No. 1528)
Acting United States Attorney
EDRIC M. CHING (No. 6697)
Assistant United States Attorney
JOHN R. TYLER
Assistant Branch Director
BRAD P. ROSENBERG (DC Bar No. 467513)
MICHELLE R. BENNETT (CO Bar No. 37050)
DANIEL SCHWEI (NY Bar)
Trial Attorneys
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Avenue, N.W.
Washington, D.C. 20530
Tel: [phone]; Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF HAWAII

STATE OF HAWAI’I and
ISMAIL ELSHIKH,
Plaintiffs,
v.

No. 1:17-cv-00050-DKW-KSC
CONSENT MOTION FOR
LEAVE TO FILE EXCESS
PAGES

DONALD J. TRUMP, et al.,
Defendants.

Judge: Hon. Derrick K. Watson

CONSENT MOTION FOR LEAVE TO FILE EXCESS PAGES
Defendants, by their undersigned counsel, hereby move this Court to allow
five extra pages, for a total of twenty-five pages, for their memorandum in
opposition to Plaintiffs’ Emergency Motion to Clarify Scope of Preliminary
Injunction, ECF No. 293. Plaintiffs consent to this relief.
In support of this motion, Defendants state as follows:
1.

On June 29, 2017, shortly after Plaintiffs filed their Motion to Clarify,

the Court authorized Defendants to file a response up to twenty pages. See ECF
No. 295.
2.

On June 30, 2017, amici curiae International Refugee Assistance

Project and HIAS moved for leave to file an additional eleven-page brief and two
declarations in support of Plaintiffs’ Motion to Clarify. See ECF No. 295. The
Court granted amici’s motion for leave to file. See ECF No. 298.
3.

In order to respond to the arguments that both Plaintiffs and amici

curiae have raised in support of the Motion to Clarify, Defendants request five
additional pages for their opposition memorandum, for a total of twenty-five pages.
4.

Counsel for Plaintiffs advised undersigned counsel for Defendants

that Plaintiffs consent to this requested relief.

Dated: July 3, 2017

Respectfully submitted,
JEFFREY B. WALL
Acting Solicitor General
CHAD A. READLER
Acting Assistant Attorney General
ELLIOT ENOKI (No. 1528)
Acting United States Attorney
EDRIC M. CHING (No. 6697)
Assistant United States Attorney
JOHN R. TYLER
Assistant Director, Federal Programs Branch
/s/ Brad P. Rosenberg
BRAD P. ROSENBERG (DC Bar. No. 467513)
MICHELLE R. BENNETT (CO Bar. No. 37050)
DANIEL SCHWEI (NY Bar)
Trial Attorneys
U.S. Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Avenue, N.W.
Washington, D.C. 20530
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants

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