Case 1:17-cv-00243-TSC Document 17 Filed 02/06/17 Page 1 of 3 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA FARSHID M. ZADEH, et al., Plaintiffs, v. DONALD J. TRUMP, et al.; Defendants. ) ) ) ) ) Civil Action No. 17-00243-TSC ) ) ) ) ) ) RESPONSE On February 5, 2017, Defendants opposed Plaintiffs’ motion for a temporary restraining order relating to the Plaintiffs’ ability to re-enter the country. Defendants argued that there is no potential for immediate irreparable harm to occur against Plaintiffs and that the Court, therefore, should deny Plaintiffs’ motion. (See ECF No. 10). On February 5, 2017, Plaintiffs’ counsel wrote the Court that Plaintiff Abdille is now within the United States, classified as a lawful permanent resident, and that Plaintiff Raghimi was allowed to board a KLM flight and “is currently scheduled to arrive in Minneapolis on February 6, 2017, at 12:50 p.m. C[S]T.” (ECF No. 14.) Plaintiffs’ counsel further suggested “that the parties and the Court conduct a conference call [on February 6, 2017] to discuss whether the Court wants to proceed with tomorrow’s hearing.” Id. At 11:08 a.m. (EST) on February 6, 2017, the Court scheduled a conference call and set/reset a deadline for Defendants’ response. (See Docket for Case No. 1:17-cv-00243-TSC (no order entered).) Defendants respond only that Plaintiffs’ letter (ECF No. 14) confirms Defendants’ position that Plaintiffs face no imminent harm and that the Court should deny Plaintiffs’ motion for a temporary restraining order. Case 1:17-cv-00243-TSC Document 17 Filed 02/06/17 Page 2 of 3 DATED: February 6, 2017 Respectfully submitted, CHAD A. READLER Acting Assistant Attorney General Civil Division WILLIAM C. PEACHEY Director COLIN A. KISOR Deputy Director J. MAX WEINTRAUB Senior Litigation Counsel ELIANIS N. PÉREZ Senior Litigation Counsel /s/ Joshua S. Press JOSHUA S. PRESS Trial Attorney United States Department of Justice Civil Division Office of Immigration Litigation District Court Section P.O. Box 898, Ben Franklin Station Washington, DC 20044 202.305.0106 Fax: 202.305.7000 joshua.press@usdoj.gov Attorneys for Defendants 2 Case 1:17-cv-00243-TSC Document 17 Filed 02/06/17 Page 3 of 3 CERTIFICATE OF SERVICE I hereby certify that on February 6, 2017, the foregoing RESPONSE was filed with the United States District Court for the District of Columbia through the Court’s CM/ECF system on all parties and counsel registered with the Court’s CM/ECF system. /s/ Joshua S. Press JOSHUA S. PRESS Trial Attorney United States Department of Justice 3