Case 2:17-cv-10310-VAR-SDD ECF No. 122 filed 07/23/18 PageID.2384 Page 1 of 5 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. UNOPPOSED MOTION FOR EXTENSION OF DEADLINES SET IN COURT’S ORDER OF DECEMBER 7, 2017 Plaintiffs, by and through counsel, hereby seek an extension of the deadlines set in the Court’s Order of December 7, 2017 (ECF #121). In that Order, the Court authorized Plaintiffs to 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. [‘Hawaii’] or Trump v. International Refugee Assistance Project et al. [‘IRAP’]. 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.” Case 2:17-cv-10310-VAR-SDD ECF No. 122 filed 07/23/18 PageID.2385 Page 2 of 5 On June 26, 2018, the Supreme Court issued an Opinion in the Hawaii case (docket No. 17-965). On June 28, 2018, the Supreme Court issued an Order remanding the IRAP case (docket No. 17-1270) for further consideration in light of Trump. The time period contemplated by this Court’s Order of December 7, 2017, will therefore expire on Monday, July 30, 2018. See Fed. R. Civ. P. 6(a)(1)(C). Given the need for Plaintiffs’ counsel to advise their clients about the ramifications of the Supreme Court’s decision and obtain their consent to any significant future steps that will be taken in this litigation, Plaintiffs believe that a 45-day extension of this deadline would be appropriate and would serve the interests of judicial efficiency. Defendants have notified Plaintiffs that they do not object to a 45-day extension of this deadline. Plaintiffs therefore ask that the Court extend the deadline for them to file a third amended complaint to September 13, 2018. Case 2:17-cv-10310-VAR-SDD ECF No. 122 filed 07/23/18 Dated: July 23, 2018 PageID.2386 Page 3 of 5 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. 122 filed 07/23/18 PageID.2387 Page 4 of 5 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] ORDER EXTENDING THE DEADLINES SET IN THE COURT’S ORDER OF DECEMBER 7, 2017 It is hereby ORDERED that Plaintiffs’ Unopposed Motion for Extension of Deadlines Set in Court’s Order of December 7, 2017 (ECF #121) is GRANTED. Plaintiffs may file a third amended complaint by September 13, 2018. IT IS ORDERED. ____________________________________ Victoria A. Roberts United States District Judge Dated: __________________ Case 2:17-cv-10310-VAR-SDD ECF No. 122 filed 07/23/18 PageID.2388 Page 5 of 5 CERTIFICATE OF SERVICE This Motion was filed on July 23, 2018, via the Court’s ECF system, which provides notice to all counsel of record. /s/ Nishchay H. Maskay Nishchay H. Maskay