Case 2:17-cv-10310-VAR-SDD ECF No. 120 filed 12/06/17 PageID.2375 Page 1 of 7 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 FOR EXTENSION OF DEADLINES SET IN COURT’S ORDER OF NOVEMBER 16, 2017 Plaintiffs and Defendants (“the Parties”), by and through counsel, hereby seek an extension of the deadlines set in the Court’s Order of November 16, 2017 (ECF #119). In that Order, the Court directed Plaintiffs to file a third amended complaint by December 15, 2017, and Defendants to answer or otherwise respond to the complaint by January 15, 2018. On December 4, 2017, the Supreme Court issued Orders in Trump v. Hawaii et al. (No. 17A550) and Trump v. International Refugee Assistance Project et al. (No. 17A560). In those Orders, the Court stayed the preliminary injunctions that the lower courts had issued against Proclamation 9645, 82 Fed. Reg. 45161, pending the Case 2:17-cv-10310-VAR-SDD ECF No. 120 filed 12/06/17 PageID.2376 Page 2 of 7 “dispositions of the Government’s appeal[s]” in the Courts of Appeals, and of any petitions by the Government for writs of certiorari. The Supreme Court’s stays “shall terminate automatically” upon either the denial of certiorari or the entry of a judgment by the Supreme Court. The Supreme Court advised the Courts of Appeals to “render [their] decision[s] with appropriate dispatch.” So that the Court and the Parties can be guided in further proceedings by any rulings by the Supreme Court in these cases, the Parties agree that an extension of the deadlines set forth in this Court’s November 16, 2017 Order would serve the interests of judicial efficiency. The Parties therefore ask that the Court order that: (1) Plaintiffs may file a third amended complaint by no later than thirty days after the Supreme Court denies certiorari or enters a judgment in Trump v. Hawaii et al. or Trump v. International Refugee Assistance Project et al.; if the Supreme Court disposes of those two cases separately, then Plaintiffs’ third amended complaint will be due by thirty days after the later of the Supreme Court’s orders; and (2) Defendants must answer or otherwise respond to the third amended complaint by no later than thirty days after it is filed. Case 2:17-cv-10310-VAR-SDD ECF No. 120 filed 12/06/17 Dated: December 6, 2017 PageID.2377 Page 3 of 7 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. 120 filed 12/06/17 Counsel for Defendants AUGUST FLENTJE Special Counsel WILLIAM C. PEACHEY Director GISELA A. WESTWATER Assistant Director By: /s/ Briana Yuh BRIANA YUH 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) 532-4165 briana.yuh@usdoj.gov JOSHUA S. PRESS KATHERINE J. SHINNERS Trial Attorneys PageID.2378 Page 4 of 7 Case 2:17-cv-10310-VAR-SDD ECF No. 120 filed 12/06/17 PageID.2379 Page 5 of 7 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 EXTENDING THE DEADLINES SET IN COURT’S ORDER OF NOVEMBER 16, 2017 It is hereby ORDERED that the Parties’ Stipulated Motion for Extension of Deadlines Set in Court’s Order of November 16, 2017 (ECF #119) is GRANTED. Plaintiffs may file a third amended complaint by no later than thirty days after the Supreme Court denies certiorari or enters a judgment in Trump v. Hawaii et al. or Trump v. International Refugee Assistance Project et al. If the Supreme Court disposes of those two cases separately, then Plaintiffs’ third amended complaint will be due by thirty days after the later of the Supreme Court’s orders. Defendants must answer or otherwise respond to the third amended complaint by no later than thirty days after it is filed. Case 2:17-cv-10310-VAR-SDD ECF No. 120 filed 12/06/17 PageID.2380 Page 6 of 7 IT IS ORDERED. ____________________________________ Victoria A. Roberts United States District Judge Dated: __________________ Case 2:17-cv-10310-VAR-SDD ECF No. 120 filed 12/06/17 PageID.2381 Page 7 of 7 CERTIFICATE OF SERVICE This Motion was filed on December 6, 2017, via the Court’s ECF system, which provides notice to all counsel of record. /s/ Nishchay H. Maskay Nishchay H. Maskay