International Refugee Assistance Project et al v. Trump et al

Filing 116

MOTION for Leave to File Amicus Brief of the Roderick & Solange MacArthur Justice Center by Roderick & Solange MacArthur Justice Center (Attachments: # 1 Text of Proposed Order, # 2 Exhibit 1-Proposed Amicus Brief, # 3 Memorandum in Support for Motion for Leave)(Nannis, Veronica)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
(SOUTHERN DIVISION)
INTERNATIONAL REFUGEE
ASSISTANCE PROJECT, et al.,
Plaintiffs,
vs.
DONALD J. TRUMP, et al.,
Defendants.

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Civil Action No.
8:17-CV-00361-TDC

MEMORANDUM IN SUPPORT OF MOTION FOR LEAVE TO FILE
AMICUS CURIAE BRIEF OF THE
RODERICK AND SOLANGE MACARTHUR JUSTICE CENTER
IN SUPPORT OF PLAINTIFFS’ MOTION FOR
A TEMPORARY RESTRAINING ORDER
The Roderick and Solange MacArthur Justice Center respectfully requests leave to file
the attached amicus curiae brief in support of Plaintiffs’ motion for a temporary restraining
order. Plaintiffs consent to the filing of the amicus brief; the Government takes no position on
this motion.
The MacArthur Justice Center is a not-for-profit organization founded in 1985 by the
family of J. Roderick MacArthur to advocate for human rights and social justice through
litigation. The MacArthur Justice Center has represented clients facing a myriad of human rights
and civil rights injustices, including issues of discrimination, the unlawful detention of foreign
nationals, and the rights of marginalized groups in the United States’ justice system. The
MacArthur Justice Center has an interest in the independent role of the judiciary in determining
whether government officials have acted with discriminatory animus.

The MacArthur Justice Center seeks to submit its brief to inform the Court’s analysis of
animus, including through historic information that preceded the present action, and to
contextualize this dispute in the history of judicial scrutiny of discriminatory government
actions.
The Court has broad discretion to grant leave to file as amicus curiae. See Bryant v.
Better Bus. Bureau of Greater Md., Inc., 923 F. Supp. 720, 728 (D. Md. 1996). “[T]he aid of
amici curiae has been allowed at the trial level where they provide helpful analysis of the law” or
where “they have a special interest in the subject matter of the suit.” Id.; see also Washington
Gas Light Co. v. Prince George’s Cty. Council, No. DKC 08-0967, 2012 WL 832756, at *3 (D.
Md. Mar. 9, 2012).
WHEREFORE, the MacArthur Justice Center respectfully requests leave to file the
amicus brief attached as Exhibit 1 to the Motion.

Dated: March 13, 2017
Respectfully submitted,

______________/s/________________
Amir H. Ali
signed by Veronica Nannis with permission of
Amir H. Ali)
Roderick & Solange MacArthur Justice Center
718 7th St. NW
Washington D.C. 20036
P: [phone]
F: [phone]
Email: [e-mail]
(Pro Hac Vice admission pending)

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JOSEPH, GREENWALD & LAAKE, P.A.
/s/
Veronica Nannis, Bar No. 15679
[e-mail]
6404 Ivy Lane, Suite 400
Greenbelt, Maryland 20770
301.220.2200 (T) / 301.220.1214 (F)
Local Counsel for Amicus MacArthur Justice
Center

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