Case 2:17-cv-10310-VAR-SDD ECF No. 116 filed 10/20/17 PageID.2339 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION ARAB AMERICAN CIVIL RIGHTS LEAGUE, et al., Plaintiffs, Case No. 2:17-cv-10310-VAR-SDD v. Hon. Victoria A. Roberts DONALD TRUMP, et al., Mag. J. Stephanie D. Davis Defendants. STIPULATED MOTION TO SET SCHEDULE FOR FILING OF JOINT STATEMENT PURSUANT TO COURT’S ORDER OF JUNE 9, 2017 Plaintiffs and Defendants (“the Parties”), by and through counsel, hereby file this motion for an order setting as November 6, 2017 the deadline for the Parties to file a “joint statement” regarding further proceedings in this case. On June 9, 2017, this Court issued an order staying proceedings in this case pending a decision by the Supreme Court in Trump v. International Refugee Assistance Project (No. 16-1436) (“IRAP”), which challenged the same Executive Orders that are at issue in this litigation (ECF #114). The June 9 Order directed the parties to file a joint statement proposing the schedule for any further proceedings once the Supreme Court took final action in IRAP. Id. On June 26, 2017, the Case 2:17-cv-10310-VAR-SDD ECF No. 116 filed 10/20/17 PageID.2340 Page 2 of 6 Supreme Court granted certiorari in the IRAP case and consolidated it with Trump v. Hawaii (No. 16-1540). On September 24, 2017, the President issued Proclamation 9645 (82 Fed. Reg. 45,161). On October 10, 2017, after receiving further briefing, the Supreme Court issued an order remanding the IRAP case, but has not issued further orders in the Hawaii case. On October 17, 2017, the District Courts hearing the Hawaii and IRAP cases issued orders restraining and enjoining enforcement of relevant portions of Proclamation 9645. See Order, Hawaii v. Trump, No. 17-cv0050 (D. Haw. Oct. 17, 2017); Order, IRAP v. Trump, No. 17-cv-0361 (D. Md. Oct. 17, 2017). In light of the proceedings in the IRAP and Hawaii cases referenced above, the Parties propose that they file the “joint statement” called for by this Court’s June 9 Order on November 6, 2017, to allow the Parties sufficient time to meet and confer regarding a proposed schedule for further proceedings in this case. Case 2:17-cv-10310-VAR-SDD ECF No. 116 filed 10/20/17 Dated: October 20, 2017 PageID.2341 Page 3 of 6 Respectfully submitted, Counsel for Arab American Civil Rights League, American Arab Chamber of Commerce, Hend Alshawish, Salim Alshawish, Yousef Abdullah, Fahmi Jahaf, and Mohamed Alshega AYAD LAW, P.L.L.C. /s/ Nabih H. Ayad Nabih H. Ayad (P59518) 645 Griswold St., Ste. 2202 Detroit, MI 48226 (313) 983-4600 nayad@ayadlaw.com Counsel for American Civil Liberties Union of Michigan, Arab American and Chaldean Council, Arab American Studies Association, Adeeb Saleh, Sofana Bella, Hilal Alkatteeb and S.A., a minor through her Parent and Next Friend, Hilal Alkatteeb /s/ Jason C. Raofield Jason C. Raofield (D.C. Bar #463877) Covington & Burling LLP One City Center 850 10th Street, NW Washington, D.C. 20001 (202) 662-5072 jraofield@cov.com Case 2:17-cv-10310-VAR-SDD ECF No. 116 filed 10/20/17 Counsel for Defendants AUGUST FLENTJE Special Counsel WILLIAM C. PEACHEY Director GISELA A. WESTWATER Assistant Director By: /s/ Katherine J. Shinners KATHERINE J. SHINNERS Trial Attorney U.S. Department of Justice, Civil Division Office of Immigration Litigation District Court Section P.O. Box 868, Ben Franklin Station Washington, DC 20044 Phone: (202) 598-8259 katherine.j.shinners@usdoj.gov JOSHUA S. PRESS BRIANA YUH Trial Attorneys PageID.2342 Page 4 of 6 Case 2:17-cv-10310-VAR-SDD ECF No. 116 filed 10/20/17 PageID.2343 Page 5 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION ARAB AMERICAN CIVIL RIGHTS LEAGUE, et al., Plaintiffs, Case No. 2:17-cv-10310-VAR-SDD v. Hon. Victoria A. Roberts DONALD TRUMP, et al., Mag. J. Stephanie D. Davis Defendants. [PROPOSED] STIPULATED ORDER SETTING SCHEDULE FOR FILING OF JOINT STATEMENT PURSUANT TO ORDER OF JUNE 9, 2017 It is hereby ORDERED that the Parties’ Motion to Set Schedule for Filing of Joint Statement Pursuant to Court’s Order of June 9, 2017 is GRANTED. The Parties are directed to file a joint statement providing the information called for in the Court’s June 9 Order (ECF #114) by November 6, 2017. IT IS ORDERED. ____________________________________ Victoria A. Roberts United States District Judge Dated: __________________ Case 2:17-cv-10310-VAR-SDD ECF No. 116 filed 10/20/17 PageID.2344 Page 6 of 6 CERTIFICATE OF SERVICE This Motion was filed on October 20, 2017, via the Court’s ECF system, which provides notice to all counsel of record. /s/ Jason C. Raofield Jason C. Raofield (D.C. Bar #463877)