Case 1:17-cv-00353-TCB Document 5 Filed 02/01/17 Page 1 of 5

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
MOHAMMED ABDULLAH
TAWFEEQ,
Plaintiff.
v.
U.S. DEPARTMENT OF HOMELAND
SECURITY (“DHS”); JOHN F. KELLY,
Secretary of DHS; U.S. CUSTOMS AND
BORDER PROTECTION (“CBP”);
KEVIN K. MCALEENAN, Acting
Commissioner of CBP; CAREY DAVIS,
Port Director, CBP ; ANDY PRYOR,
Manager, CBP; SHANA WELLS,
Manager, CBP; U.S. DEPARTMENT
OF STATE (“Department of State”);
THOMAS A. SHANNON, JR., Acting
Secretary of State, Department of State.
Defendants.

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Case No. 1:17-cv-353

EMERGENCY MOTION
TO EXPEDITE
PROCEEDINGS

PLAINTIFF’S EMERGENCY MOTION TO EXPEDITE PROCEEDINGS
By and through undersigned counsel, Plaintiff moves for expedited
consideration of this matter pursuant to 28 U.S.C. § 1657 and Local Rule 65.2,
because the issues raised in the complaint rely on Plaintiff’s rights under the U.S.
Constitution and federal immigration law that are of immediate importance and
that could evade review if the regular briefing schedule is not significantly
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 Case 1:17-cv-00353-TCB Document 5 Filed 02/01/17 Page 2 of 5

accelerated to reflect the expedited timetable set forth in the proposed order. For
the reasons outlined in the accompanying Memorandum of Law in support of the
Motion, Plaintiff requests that the Court order Defendants to respond to his
Complaint no later than 10 days after any order granting this motion, and that the
Court set a summary judgment briefing schedule that will end no later than 20 days
thereafter. Plaintiff further requests that Defendants be required to promptly
respond to this Motion.
DATED February 1, 2017

Respectfully submitted,

/s/ Theresia Moser
Theresia M. Moser
Georgia Bar No. 526514
Moser Law Co.
112 Krog Street N.E., Suite 26
Atlanta, GA 30307
Phone: (404) 537-5339
Fax: (404) 537-5340
tmoser@moserlawco.com
Carl W. Hampe (pro hac vice)
Daniel P. Pierce (pro hac vice)
Fragomen, Del Rey, Bernsen & Loewy LLP
1101 15th St. NW, Suite 700
Washington, DC 20005
Phone: (202) 223-5515
Fax: (202) 371-2898
champe@fragomen.com
dpierce@fragomen.com
Attorneys for Plaintiff
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 Case 1:17-cv-00353-TCB Document 5 Filed 02/01/17 Page 3 of 5

CERTIFICATE OF FONT AND POINT SELECTION
Undersigned counsel hereby certifies, pursuant to L.R. 7.1(D), N.D. Ga., that
the foregoing PLAINTIFF’S EMERGENCY MOTION TO EXPEDITE
PROCEEDINGS AND SUPPORTING MEMORANDUM AND PROPOSED
ORDERS were prepared in Times New Roman, 14 point font, which is one of the
font and point selections approved in L.R. 5.1, N.D. Ga.

/s/ Theresia Moser
Theresia M. Moser

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CERTIFICATE OF SERVICE

I hereby certify that I have this day mailed a true and correct copy of the
within and foregoing PLAINTIFF’S EMERGENCY MOTION TO EXPEDITE
PROCEEDINGS AND SUPPORTING MEMORANDUM AND PROPOSED
ORDERS by overnight Federal Express to each of the following:
The Honorable John F. Kelly,
Secretary of Homeland Security
U.S. Department of Homeland Security
245 Murray Lane, SW
Mail Stop 0485
Washington, DC 20528-0485
Kevin K. McAleenan, Acting Commissioner
U.S. Customs and Border Protection
1300 Pennsylvania Ave. NW
Washington, DC 20229
Carey Davis, Port Director,
Andy Pryor, Manager,
Shanna Wells, Manager,
U.S. Customs and Border Protection,
Atlanta Hartsfield/Jackson Int’l Airport
157 Tradeport Drive
Atlanta, GA 30354
Thomas A. Shannon, Acting Secretary of State
U.S. Department of State
2201 C St. NW
Washington, DC 20520

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Courtesy copies of the above documents were sent via electronic mail to the
following individuals with whom Plaintiff has made initial contact on behalf of the
government:
Lori Beranek
Assistant United States Attorney
Northern District of Georgia
U.S. Department of Justice
Lori.Beranek@usdoj.gov
Sheetul S. Wall
Office of Immigration Litigation
U.S. Department of Justice
Sheetul.S.Wall2@usdoj.gov
This 1st day of February 2017.

/s/ Theresia Moser
Theresia M. Moser

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