International Refugee Assistance Project et al v. Trump et al

Filing 229

NOTICE OF CROSS APPEAL as to 219 Memorandum Opinion, 220 Order on Motion for Preliminary Injunction by Arab American Association of New York, HIAS, Inc., International Refugee Assistance Project, Jane Doe # 2, John Does 1 & 3, Muhammed Meteab, Middle East Studies Association of North America, Inc., Yemeni-American Merchants Association, Mohamad Mashta, Grannaz Amirjamshidi, Fakhri Ziaolhagh, Shapour Shirani, Afsaneh Khazaeli, John Doe #5, John Doe #4. Filing fee $ 505, receipt number 0416-6957572.(Jadwat, Omar)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
SOUTHERN DIVISION
INTERNATIONAL REFUGEE ASSISTANCE
PROJECT, a project of the Urban Justice Center, Inc.,
on behalf of itself and its clients,
40 Rector St, 9th Fl
New York, NY 10006;
HIAS, Inc., on behalf of itself and its clients,
1300 Spring Street, Suite 500
Silver Spring, MD 20910;
MIDDLE EAST STUDIES ASSOCIATION of North
America, Inc., on behalf of itself and its members,
3542 N. Geronimo Avenue
Tucson, AZ 85705;

Civil Action No.: 8:17-cv-361-TDC

ARAB-AMERICAN ASSOCIATION OF NEW
YORK, on behalf of itself and its clients,
7111 5th Avenue
Brooklyn, NY 11209;
NOTICE OF CROSS-APPEAL
YEMENI-AMERICAN MERCHANTS
ASSOCIATION, on behalf of itself and its members,
33-42 9st
Long Island City, NY 11106;
JOHN DOES # 1, 3 through 5;
JANE DOE #2;
MUHAMMED METEAB;
MOHAMAD MASHTA;
GRANNAZ AMIRJAMSHIDI;
FAKHRI ZIAOLHAGH;
SHAPOUR SHIRANI; and
AFSANEH KHAZAELI,
Plaintiffs,
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v.
DONALD TRUMP, in his official capacity as
President of the United States,
1600 Pennsylvania Avenue NW
Washington, D.C. 20035;
DEPARTMENT OF HOMELAND SECURITY,
Serve on: Elaine Duke,
Acting Secretary of Homeland Security
Washington, D.C. 20528;
DEPARTMENT OF STATE,
Serve on: Rex W. Tillerson,
Secretary of State
2201 C Street NW
Washington, D.C. 20520;
OFFICE OF THE DIRECTOR OF
NATIONAL INTELLIGENCE,
Serve on: Dan Coats,
Director of National
Intelligence
Washington, D.C. 20511;
ELAINE DUKE, in her official capacity as Acting
Secretary of Homeland Security
Washington, D.C. 20528;
REX W. TILLERSON, in his official capacity as
Secretary of State
2201 C Street NW
Washington, D.C. 20520;
DAN COATS, in his official capacity as Acting
Director of National Intelligence
Washington , D.C. 20511
Defendants.

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PLEASE TAKE NOTICE that all plaintiffs hereby cross-appeal to the United States Court
of Appeals for the Fourth Circuit from the Memorandum Opinion and Order at ECF Nos. 219
and 220, both dated October 17, 2017.

Respectfully submitted,
Dated: October 23, 2017
/s/ Omar C. Jadwat
Omar C. Jadwat†
Lee Gelernt†
Hina Shamsi†
Hugh Handeyside†
Sarah L. Mehta†
David Hausman†
American Civil Liberties Union
Foundation
125 Broad Street, 18th Floor
New York, NY 10004
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Karen C. Tumlin†
Nicholas Espíritu†
Melissa S. Keaney†
Esther Sung†
National Immigration Law Center
3435 Wilshire Boulevard, Suite 1600
Los Angeles, CA 90010
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Justin B. Cox (Bar No. 17550)
National Immigration Law Center
PO Box 170208
Atlanta, GA 30317
Tel: [phone]
Fax: [phone]
[e-mail]

Cecillia D. Wang†
Cody H. Wofsy†
Spencer E. Amdur†
American Civil Liberties Union
Foundation
39 Drumm Street
San Francisco, CA 94111
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]

Kathryn Claire Meyer†
Mariko Hirose†
International Refugee Assistance Project
40 Rector Street, 9th Floor
New York, New York 10006
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]

3

David Rocah (Bar No. 27315)
Deborah A. Jeon (Bar No. 06905)
Sonia Kumar (Bar No. 07196)
Nicholas Taichi Steiner (Bar
No. 19670)
American Civil Liberties Union
Foundation of Maryland
3600 Clipper Mill Road, Suite 350
Baltimore, MD 21211
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

David Cole†
Daniel Mach†
Heather L. Weaver†
American Civil Liberties Union
Foundation
915 15th Street NW
Washington, DC 20005
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]

Counsel for Plaintiffs

†Admitted Pro Hac Vice

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CERTIFICATE OF SERVICE
I hereby certify that on this 23rd day of October, 2017, I caused a PDF version of the
foregoing document and any accompanying exhibits to be electronically transmitted to the Clerk
of the Court, using the CM/ECF System for filing and for transmittal of a Notice of Electronic
Filing to all CM/ECF registrants.

Dated: October 23, 2017

Respectfully submitted,
/s/ Omar C. Jadwat

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