International Refugee Assistance Project et al v. Trump et al

Filing 77

MOTION for Leave to File Amici Curiae Memorandum in Support of Plaintiff's Motion for a Preliminary Injunction by AMERICAN JEWISH WORLD SERVICE (Attachments: # 1 Exhibit A Amicus Brief of Interfaith Group of Religious and Interreligious Orgnaizations, # 2 Text of Proposed Order)(Wine, Bradley)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
SOUTHERN DIVISION

INTERNATIONAL REFUGEE
ASSISTANCE PROJECT, et al.,
Civil Action No.: 8:17-CV-00361-TDC
Plaintiffs,
v.
DONALD TRUMP, et al.,
Defendants.

MOTION FOR LEAVE TO FILE AMICI CURIAE MEMORANDUM
IN SUPPORT OF PLAINTIFF’S MOTION FOR A PRELIMINARY INJUNCTION
Amici curiae—a group of nearly fifty interfaith religious and interreligious
congregations, associations, and organizations—seek leave to file the attached brief in support of
Plaintiff International Refugee Assistance Project’s Motion for a Preliminary Injunction of § 5(d)
of President Trump’s January 27, 2017 Executive Order. Plaintiffs consent to the filing of this
brief. Defendants do not take any position on this motion.
District courts have broad discretion whether to grant or deny motions for leave to appear
as amicus curiae. Am. Humanist Ass’n v. Maryland-Nat’l Capital Park & Planning Comm’n,
303 F.R.D. 266, 269 (D. Md. 2014); Bryant v. Better Bus. Bureau of Greater Maryland, Inc., 923
F. Supp. 720, 728 (D. Md. 1996). “The aid of amici curiae has been allowed at the trial level
where they provide helpful analysis of the law, they have a special interest in the subject matter
of the suit, or existing counsel is in need of assistance.” Bryant, 923 F. Supp. at 728 (granting
motion for leave to file a amici curiae brief where amici have “vested interest” in outcome of the
case and amici “can be useful in resolving the issues presented by the parties”) (internal citations
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omitted); see also Am. Humanist, 303 F.R.D. at 269 (allowing amici to submit memorandum
where amici “demonstrated a special interest in the outcome of the suit” and the memorandum
“provide[d] helpful information to the court”).
Amici have a vested interest in whether this Court enjoins enforcement of § 5(d) of the
Executive Order, and offer a unique perspective on the issues in this case. Religious principles
have long informed society’s understanding of moral values. Amici have a wide array of beliefs
and come from different faith traditions, but are united in their missions to aid those in need.
Amici are deeply concerned about the impact of the Executive Order on the most vulnerable
refugees. Many amici actively participate in aiding refugees, and several amici are faith-based
organizations whose mission is to assist refugees resettling in the United States. Other amici are
local congregations that have adopted refugee families, providing them housing as well as
financial, emotional, and spiritual support. The Executive Order’s drastic reduction in the
number of refugees that will be granted admission to the United States this year runs contrary to
religious and moral values common to all faiths, and it will have a profound impact on amici’s
ability to continue their faith-based missions.
Because amici have a unique perspective that can aid the Court’s resolution of this
matter, amici respectfully request leave to file the brief attached as Exhibit A to this letter.

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Dated: March 3, 2017

Respectfully submitted,
MORRISON & FOERSTER LLP
By: /s/ Bradley D. Wine
Bradley D. Wine ([e-mail]) (MD Bar # 12577)
Sandeep N. Nandivada ([e-mail])
1650 Tysons Boulevard
McLean, Virginia 22102
Telephone: [phone]
Facsimile: 703.760.7777
Marc A. Hearron ([e-mail])
2000 Pennsylvania Avenue, NW
Washington, DC 20006
Telephone: [phone]
Facsimile: 202.887.0763
Purvi G. Patel ([e-mail])
707 Wilshire Boulevard
Los Angeles, California 90017
Telephone: [phone]
Facsimile: 213.892.5454
Jennifer K. Brown ([e-mail])
Amanda Aikman ([e-mail])
250 West 55th Street
New York, New York 10019
Telephone: [phone]
Facsimile: 212.468.7900
Counsel for Amici Curiae

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CERTIFICATE OF SERVICE
I hereby certify that on this 3rd day of March 2017, I filed and served the foregoing
via the CM/ECF system on all counsel who are registered CM/ECF users.

Dated: March 3, 2017

/s/Bradley D. Wine
Morrison & Foerster LLP

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