International Refugee Assistance Project et al v. Trump et al

Filing 6

NOTICE by Jane Doe 1, John Doe1-4 re 5 MOTION for Other Relief for Leave to Proceed Under Pseudonyms (Cox, Justin)

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Case 8:17-cv-00361-TDC Document 6 Filed 02/08/17 Page 1 of 3 February 8, 2017 Honorable Theodore D. Chuang United States District Court District of Maryland Re: International Refugee Assistance Project v. Trump, No. 8:17-cv-00361 (TDC) Dear Judge Chuang: We represent the Plaintiffs in the above-referenced matter and we write to correct our error in filing Plaintiffs’ Motion for Leave to Proceed under Pseudonyms (Doc. No. 5) (“Motion”), filed without observance of the proper procedures under this Court’s Case Management Order (Doc. No. 4). In keeping with the Case Management Order, Section II.A., we write to request a pre-motion conference to seek leave to file this Motion. The proposed Motion requests that five individual Plaintiffs in this action – John Does #1-4 and Jane Doe – be permitted to proceed under pseudonyms. All five Doe Plaintiffs would be at risk of great harm if their identities were revealed and the balance of equities tips strongly in favor of permitting them to proceed anonymously. The Doe Plaintiffs reasonably fear that public disclosure of their identities could subject them and/or their family members to retaliatory action by federal government officials. Further, given the current heated debate over immigration generally and the Executive Order which is the subject of this action, revealing Plaintiffs’ true identities and personal stories could subject them and/or their family members to harassment and even physical harm. Permitting these Doe Plaintiffs to proceed anonymously would not materially harm the public interest; nor would it prejudice Defendants. We therefore respectfully request leave to file the Motion, which relies on the standards established in Doe v. Public Citizen, 749 F.3d 246, 274 (4th Cir. 2014), and explains in greater detail the various grounds supporting Plaintiffs’ request to proceed anonymously in this action. // // // // Case 8:17-cv-00361-TDC Document 6 Filed 02/08/17 Page 2 of 3 We would be happy to take any steps necessary to withdraw the filed Motion for Leave under Pseudonyms until such time that the Court can schedule a pre-motion conference on this motion. Thank you for your consideration of this request. Very Truly Yours, /s/ Justin B. Cox Justin B. Cox (Bar No. 17550) National Immigration Law Center 1989 College Ave. NE Atlanta, GA 30317 Tel: (678) 404-9119 Fax: (213) 639-3911 Karen C. Tumlin† Nicholas Espíritu† Melissa S. Keaney† Esther Sung† National Immigration Law Center 3435 Wilshire Boulevard, Suite 1600 Los Angeles, CA 90010 Tel: (213) 639-3900 Fax: (213) 639-3911 Omar C. Jadwat† Lee Gelernt† Hina Shamsi† Hugh Handeyside† Sarah L. Mehta† American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel: (212) 549-2600 Fax: (212) 549-2654 Cecillia D. Wang† Cody H. Wofsy† American Civil Liberties Union Foundation 39 Drumm Street San Francisco, CA 94111 Tel: (415) 343-0770 Fax: (415) 395-0950 David Cole† Daniel Mach† Heather L. Weaver† American Civil Liberties Union Foundation 915 15th Street NW Washington, DC 20005 Case 8:17-cv-00361-TDC Document 6 Filed 02/08/17 Page 3 of 3 Tel: (202) 675-2330 Fax: (202) 457-0805 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: (410) 889-8555 Fax: (410) 366-7838 †Pro Hac Vice Applications Forthcoming Counsel for Plaintiffs

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