Case 1:17-cv-00353-TCB Document 27 Filed 03/09/17 Page 1 of 6

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.

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

Case No. 1:17-cv-353

JOINT MOTION
TO RESET DEADLINES

By and through undersigned counsel, the parties jointly request that the
Court delay the following upcoming events in this matter pursuant to Fed. R. Civ.
Pro. 6(b): (1) Defendants’ deadline for a Reply Concerning their Motion to
Dismiss, ECF No. 19, currently due on March 13, 2017; (2) the parties’ obligation
to exchange initial disclosures, L.R. 26.1; Fed. R. Civ. Pro. 26(a)(1), currently due

-1-

 Case 1:17-cv-00353-TCB Document 27 Filed 03/09/17 Page 2 of 6

on March 9, 2017; and (3) the parties’ obligation file a joint preliminary report and
discovery plan, L.R. 16.2, currently due on March 9, 2017.
Good cause exists to grant the Motion for the reasons stated in the
accompanying memorandum. In short, the President has issued a new Executive
Order that revokes the Executive Order central to Plaintiff’s Complaint. The
Parties request time to assess the new Executive Order’s implementation and its
impacts on how to proceed with this Matter.
By e-mail dated March 9, 2017, counsel for Plaintiff consented to the filing
of this Motion.
//
//
//

-2-

 Case 1:17-cv-00353-TCB Document 27 Filed 03/09/17 Page 3 of 6

DATED March 9, 2017

Respectfully submitted,
CHAD A. READLER
Acting Assistant Attorney General
Civil Division
WILLIAM C. PEACHEY
Director
Office of Immigration Litigation
District Court Section
GISELA A. WESTWATER
Assistant Director
Office of Immigration Litigation
District Court Section
EREZ REUVENI
Senior Litigation Counsel
By: s/ Sheetul S. Wall
SHEETUL S. WALL
Trial Attorney
United States Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044
Tel.: (202) 598-2668
Fax: (202) 305-7000
Email: Sheetul.S.Wall2@usdoj.gov
Counsel for Defendants

Theresia M. Moser
Georgia Bar No. 526514
Moser Law Co.
112 Krog Street N.E., Suite 26
Atlanta, GA 30307
-3-

 Case 1:17-cv-00353-TCB Document 27 Filed 03/09/17 Page 4 of 6

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
Counsel for Plaintiff

-4-

 Case 1:17-cv-00353-TCB Document 27 Filed 03/09/17 Page 5 of 6

CERTIFICATE OF FONT AND POINT SELECTION
Undersigned counsel hereby certifies, pursuant to L.R. 7.1(D), N.D. Ga., that
the foregoing JOINT MOTION TO RESET DEADLINES was 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/ Sheetul S. Wall
Sheetul S. Wall

-5-

 Case 1:17-cv-00353-TCB Document 27 Filed 03/09/17 Page 6 of 6

CERTIFICATE OF SERVICE
I hereby certify that I have this day filed a true and correct copy of the
within and foregoing JOINT MOTION TO RESET DEADLINES by using the
Court’s CM/ECF, which will automatically send e-mail notification of this filing to
all counsel of record.
This 9th day of March 2017.
/s/ Sheetul S. Wall
Sheetul S. Wall

-6-