Case 2:85-cv-04544-DMG-AGR Document 449 Filed 06/29/18 Page 1 of 4 Page ID #:18040

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MICHAEL N. FEUER, SBN 111529
City Attorney
JAMES P. CLARK, SBN 64780
LEELA A. KAPUR, SBN 125548
VALERIE L. FLORES, SBN 138572
MICHAEL DUNDAS, SBN 226930
200 North Main St., City Hall East Suite 800
Los Angeles, California 90012
mike.dundas@lacity.org
Telephone: (213) 978-8130
Facsimile: (213) 978-8312
Attorneys for Amicus Curiae City of Los Angeles

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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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Case No.
JENNY LISETTE FLORES, et
al.,

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Plaintiffs,

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v.

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JEFFERSON B. SESSIONS III,
Attorney General of the
United States, et al.,
Defendants.

2:85-cv-4544-DMG

ADMINISTRATIVE MOTION
FOR LEAVE TO FILE BRIEF
OF CITY OF LOS ANGELES,
CITY OF CHICAGO, CITY OF
NEW YORK, CITY AND
COUNTY OF SAN FRANCISCO
AS AMICI CURIAE IN
OPPOSITION TO
DEFENDANTS’ EX PARTE
APPLICATION FOR RELIEF
FROM THE FLORES
SETTLEMENT

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 Case 2:85-cv-04544-DMG-AGR Document 449 Filed 06/29/18 Page 2 of 4 Page ID #:18041

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Amici Curiae, the City of Los Angeles, City of Chicago, City of New

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York, and City and County of San Francisco, hereby request leave to file

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the attached Proposed Brief of Amici Curiae in Opposition of

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Defendants’ Ex Parte Application for Relief from the Flores Settlement.

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A copy of the proposed brief is attached to this motion as Attachment 1.

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Plaintiffs and Defendants both consent to amici’s filing of this brief.
On June 26, 2018, Judge Dana M. Sabraw, in the District Court for

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the Southern District of California issued an order requiring the federal

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government to reunite many Plaintiffs in this instant case – those who

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have been cruelly and unnecessarily separated from their families by

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Defendants – with their parents.1 Because many, if not most, of

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Plaintiffs’ parents remain in Defendants’ custody, Defendants are

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asking this court for relief from critical child welfare protections set

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forth in the longstanding Flores Settlement Agreement.
The precipitating crisis, i.e. forced family separation, was a

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creation of Defendants’ own doing, and amici assert that Defendants’ Ex

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Parte Application for Relief from the Flores Settlement threatens the

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well-being of not just Plaintiffs and their families, but also amici’s police

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power interests in seeing the state licensing requirements be properly

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applied and enforced within our respective jurisdictions.
Specifically, amici, by and through either our respective police

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departments or our prosecutors, enforce and prosecute violations of

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respective state child welfare laws. Amici have a strong interest,

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therefore, in the continued licensed regulation of Defendants’ child

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welfare programs, especially considering that thousands of

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unaccompanied minors have been placed with sponsors in our respective

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Ms. L. v. U.S. Immigration & Customs Enf't, No. 18-cv-0428 (DMS)
(MDD), 2018 U.S. Dist. LEXIS 107365 (S.D. Cal. June 26, 2018).
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 Case 2:85-cv-04544-DMG-AGR Document 449 Filed 06/29/18 Page 3 of 4 Page ID #:18042

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jurisdictions in recent years and, separately, hundreds of children taken

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from their families by Defendants in recent weeks are currently being

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held in facilities located in our jurisdictions.

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For the foregoing reasons, amici respectfully request the court’s
permission to file the attached brief.
Dated:

June 29, 2018

Respectfully submitted,
By:/s/

Michael Dundas

Michael N. Feuer
City Attorney
James P. Clark
Leela Kapur
Valerie Flores
Michael Dundas
200 North Main Street,
Los Angeles, CA 90012

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Attorneys for Amicus Curiae
City of Los Angeles, California

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EDWARD N. SISKEL
Corporation Counsel
30 N. LaSalle Street, Suite 800
Chicago, IL 60602

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Attorney for Amicus Curiae
City of Chicago, Illinois

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ZACHARY W. CARTER
Corporation Counsel
100 Church Street
New York, NY 10007

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Attorney for Amicus Curiae
City of New York, New York

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DENNIS J. HERRERA
City Attorney
City Hall Room 234
One Dr. Carlton B. Goodlett Pl.
San Francisco, CA 94102

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Attorney for Amicus Curiae
City and County of San Francisco,
California

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 Case 2:85-cv-04544-DMG-AGR Document 449 Filed 06/29/18 Page 4 of 4 Page ID #:18043

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CERTIFICATE OF SERVICE

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I hereby certify that on June 29, 2018, a copy of the foregoing

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Administrative Motion for Leave to File Brief of City of Los Angeles,

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City of Chicago, City of New York and City and County of San Francisco

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as Amici Curiae in Opposition to Defendants’ Ex Parte Application for

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Relief from the Flores Settlement; and attached Proposed Brief were

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filed and served pursuant to the Court’s electronic filing procedures

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using CM/ECF.

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/s/

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Michael Dundas
Michael Dundas

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