Case 2:17-cv-00178-JLR Document 100 Filed 01/04/18 Page 1 of 11

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THE HONORABLE JAMES L. ROBART

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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JOHN DOES, et al.,

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CASE NO. C17-0178JLR
Plaintiffs,

v.
DONALD TRUMP, et al.,

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Defendants.

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JEWISH FAMILY SERVICE, et al.,

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JFS PLAINTIFFS’ OPPOSITION TO
DEFENDANTS’ EMERGENCY
MOTION FOR STAY OF
PRELIMINARY INJUNCTION
PENDING APPEAL
(RELATING TO CASE NO. C17-1707JLR)
CASE NO. C17-1707JLR

Plaintiffs,
v.
DONALD TRUMP, et al.,
Defendants.

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JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR)

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000

 Case 2:17-cv-00178-JLR Document 100 Filed 01/04/18 Page 2 of 11

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INTRODUCTION

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Defendants’ “Emergency Motion for Stay of Preliminary Injunction Pending Appeal”
(“Motion” or “Mot.”) (Dkt. No. 95) is a bald, procedurally improper attempt to modify and stay
this Court’s injunction based on arguments that Defendants have already made or could have
made to the Court previously. The Court should deny the Motion.1

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ARGUMENT
I.

THE COURT SHOULD REJECT DEFENDANTS’ ATTEMPT TO
UNILATERALLY MODIFY THE PRELIMINARY INJUNCTION.
Defendants’ sweeping assertion in their Motion that they “do not understand the

preliminary injunction to require affirmative action to undo any of the steps that were taken to
implement [the October 23, 2017 Memorandum (“Agency Memo”)] prior to December 23”
(Mot. at 4 (emphasis added)), is no less than an attempt to unilaterally modify and undermine
this Court’s preliminary injunction order. After reviewing the parties’ evidence and the
arguments on the preliminary injunction motion, this Court enjoined and restrained Defendants,
from the date of the Court’s order, from enforcing provisions of the Agency Memo that “suspend
the processing of FTJ refugee applications or suspend the admission of FTJ refugees into the
United States,” as well as those provisions “that suspend or inhibit, including through the
diversion of resources, the processing of refugee applications or the admission into the United
States of refugees from SAO countries.” (Findings of Fact, Conclusions of Law, and Order
Issuing a Preliminary Injunction at 64, 65 (Dkt. No. 92) (“Order”).) This of course requires
Defendants to take any action necessary to undo the implementation of the Agency Memo
prospectively. For instance, if Defendants sent guidance suspending admission of refugees from
the SAO countries or of FTJ beneficiaries, they must rescind it. If they issued instructions to

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Defendants also request that the Court stay its injunction pending decision on this Motion. (See Mot. at
1.) Given the likelihood of irreparable harm to the Plaintiffs without the injunction in place (see Order at 56-58),
that request should also be denied.

JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR) – 1

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000

 Case 2:17-cv-00178-JLR Document 100 Filed 01/04/18 Page 3 of 11

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staff to de-prioritize the processing of applications from SAO countries, they must reverse those
instructions. Defendants are required to restore the status quo ante—that is, the regular
functioning of the U.S. Refugee Admissions Program—which does not transform this injunction
into a mandatory one. See Ariz. Dream Act Coal. v. Brewer, 757 F.3d 1053, 1060-61 (9th Cir.
2014) (holding that injunctions that prohibit enforcement of a new law or policy are prohibitory,
not mandatory, even where policy had already taken effect prior to the filing of the lawsuit).
The Court should reject Defendants’ attempt to gut the injunction—and thereby continue
the ban that this Court found likely violates the INA and APA—through the guise of this stay
motion. First, the attempt is procedurally improper because any request to modify the injunction
at this stage should be brought in a motion for reconsideration.2 See Credit Suisse First Boston
Corp. v. Grunwald, 400 F.3d 1119, 1124 (9th Cir. 2005) (holding that a motion to modify a
preliminary injunction should be considered a motion to reconsider where it “seeks to relitigate
the issues underlying” the original order). But motions for reconsideration “may not be used to
raise arguments or present evidence for the first time when they could reasonably have been
raised earlier in the litigation.” Kona Enters., Inc. v. Estate of Bishop, 229 F.3d 877, 890 (9th
Cir. 2000). The appropriate time for Defendants to have raised arguments regarding the burden
of the proposed injunction was in their opposition to the preliminary injunction motion. Instead
of raising such arguments, Defendants characterized the Agency Memo as implementing “[a]t
most” a short, inconsequential “delay” on the refugee program. (Defs.’ Opp. to JFS Pls.’ Mot.
for Prelim. Inj. at 15, 28 (Dkt. No. 77) (“Defs.’ Opp.”).) After strategically foregoing the

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Defendants are trying to have it both ways by asking the Court to reconsider its decision and
simultaneously seeking to obtain a stay pending appeal. An appeal generally deprives the district court of
jurisdiction, thus preventing it from reconsidering its prior ruling. See generally Griggs v. Provident Consumer
Discount Co., 459 U.S. 56, 58 (1982) (“The filing of a notice of appeal is an event of jurisdictional significance—it
confers jurisdiction on the court of appeals and divests the district court of its control over those aspects of the case
involved in the appeal.”).

JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR) – 2

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000

 Case 2:17-cv-00178-JLR Document 100 Filed 01/04/18 Page 4 of 11

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appropriate opportunity to make those arguments, Defendants do not get a second bite at the
apple.3
Second, Defendants’ attempt to be excused from taking any “affirmative actions”
necessary to undo implementation of the Agency Memo is vague, conclusory, and unsupported
by any evidence. (See, e.g., Mot. at 5 (asserting, without any support or details, that “there is
significant doubt about whether it would even be possible for Defendants to undo some of their
prior decisions”).) In fact, the only concrete example of such action that Defendants provide—
based solely on counsel’s unsworn statements—is canceling the circuit ride interviews that were
scheduled for the second quarter of fiscal year 2018 pursuant to the Agency Memo’s direction to
redirect resources away from processing applications for nationals of SAO countries. (See Mot.
at 5.) Defendants are wrong that complying with the preliminary injunction requires canceling
already-scheduled circuit rides,4 but their refusal to undo other unspecified actions that they took
to implement the now-enjoined provisions of the Agency Memo remains wholly unsubstantiated
and deeply concerning. At this juncture, Plaintiffs have no way to know even what those
unspecified actions are.5 If Defendants have specific actions that they believe should be carved

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Moreover, motions for reconsideration are denied “absent highly unusual circumstances, unless the
district court is presented with newly discovered evidence, committed clear error, or if there is an intervening change
in the controlling law.” 389 Orange St. Partners v. Arnold, 179 F.3d 656, 665 (9th Cir. 1999); accord Local Rules
W.D. Wash. LCR 7(h)(1); see also Connors v. Iqueque U.S.L.L.C., No C05-334JLR, 2005 WL 2237593, at *1
(W.D. Wash. Sept. 13, 2005) (Robart, J.) (stating that local rules disfavor such motions and they will “be denied
unless there is a showing of (a) manifest error in the prior ruling, or (b) facts or legal authority which could not have
been brought to the attention of the court earlier, through reasonable diligence”). Defendants have not pointed to
any clear error in the Court’s Order, nor have they submitted any evidence that could not have been previously
brought to the Court’s attention.
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Complying with the injunction does require Defendants to restore circuit rides that would have been
scheduled absent the Agency Memo. Defendants have provided no evidence why such interviews could not be
restored without canceling existing interviews.
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If anything, Defendants’ vague and unsubstantiated assertions highlight the need for discovery into
implementation of the Agency Memo. On January 2, 2017, JFS Plaintiffs reached out to Defendants to schedule a
Rule 26(f) conference. Defendants responded that, in their view, a conference is unnecessary because the Court
vacated its December 14, 2017 Order, which ordered a Joint Status Report and a Discovery Plan in the consolidated
case, Doe v. Trump. (See Minute Entry (Dec. 21, 2017) (Dkt. No. 87).) For avoidance of doubt, the JFS Plaintiffs—
who have never agreed to any stay of discovery—respectfully request that the Court order the parties to confer
pursuant to Rule 26(f).

JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR) – 3

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000

 Case 2:17-cv-00178-JLR Document 100 Filed 01/04/18 Page 5 of 11

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out from the scope of the injunction, they must raise those issues through appropriate motions
and support them with sufficient evidence. A “motion to stay” without details or evidence is not
a procedurally proper or valid vehicle for modifying the scope of this Court’s injunction.
II.

THE COURT SHOULD DENY DEFENDANTS’ REQUEST TO STAY THE
PRELIMINARY INJUNCTION.
The remainder of Defendants’ contentions in the Motion rehash the same arguments that

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this Court has already rejected and should reject again. On a motion to stay, the movant bears

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the burden of (1) making a “strong showing” that they are likely to succeed on the merits; (2)

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demonstrating that they “will be irreparably injured absent a stay”; (3) refuting the Court’s

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finding that Plaintiffs will suffer substantial injury absent a preliminary injunction; and (4)

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showing that the public interest does not favor immediate relief for the Plaintiffs. See Nken v.

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Holder, 556 U.S. 418, 433-35 (2009) (explaining that the first two factors are “the most critical”

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and that mere “possibility” of irreparable injury is insufficient for the second factor). Defendants

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satisfy none of the stay factors. Cf. Washington v. Trump, 847 F.3d 1151, 1169 (9th Cir. 2017)

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(denying the Government’s emergency motion for a stay pending appeal, even where “[a]spects

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of the public interest favor[ed] both sides.”), cert.denied, 86 U.S.L.W. 3238 (U.S. Nov. 13, 2017)

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(No. 17-5424).

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A.

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As Defendants themselves acknowledge, their arguments regarding likelihood of success

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on the merits merely reassert previous arguments that this Court has already rejected. (See, e.g.,

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Mot. at 10 (“Yet as the Government previously argued . . . .” (emphasis added)).) The Court has

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already considered, and rejected, each of Defendants’ arguments, including that the follow-to-

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join suspension is consistent with 8 U.S.C. § 1157(c)(2)(A) (compare Mot. at 10 with Order at

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48-51), that the SAO suspension is consistent with the Refugee Act of 1980 (compare Mot. at 10

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with Order at 51-56 (holding that the Agency Memo “impermissibly redefine[s] the term

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‘refugee’” in the Refugee Act)), and that these suspensions are procedural rules that did not

Defendants Have Not Shown Likelihood of Success on the Merits.

JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR) – 4

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000

 Case 2:17-cv-00178-JLR Document 100 Filed 01/04/18 Page 6 of 11

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require notice-and-comment rulemaking (compare Mot. at 11-12 with Order at 39-46 (holding
that the suspensions should have been subject to notice-and-comment rulemaking)).6 The Court
has no reason to revisit these rulings here.
B.

Defendants Have Not Shown Irreparable Harm to the Government or Public
Interest Favoring a Stay.

Defendants’ arguments on irreparable harm and the public interest also conflict with what

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this Court has already found—that the balance of hardships here favors Plaintiffs over

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Defendants. (See Order at 59-61.) Defendants simply repeat old arguments about harm to

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national security (see, e.g., Mot. at 2-3), but as this Court has already found: “Defendants . . . do

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not point to any specific national security threat that the Agency Memo curtails,” nor have they

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“put forth evidence of how a preliminary injunction might cause specific injury or harm in this

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instance or how the recent preliminary injunction of EO-1’s or EO-2’s suspensions of all or

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portions of USRAP caused any harm or injury.” (Order at 59-60.) Defendants cannot simply

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rely on unspecified national-security concerns. See Ziglar v. Abbasi, 137 S. Ct. 1843, 1862

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(2017) (explaining that “national-security concerns must not become a talisman used to ward off

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inconvenient claims—a ‘label’ used to ‘cover a multitude of sins’” (citation omitted)); Hawaiʻi v.

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Trump, No. 17-17168, 2017 WL 6554184, at *22 (9th Cir. Dec. 22, 2017) (holding that in the

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absence of “sufficient findings that the ‘entry of certain classes of aliens would be detrimental to

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the national interest,’” national security interests did not outweigh harm to plaintiffs (citation

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omitted)); Washington v. Trump, 847 F.3d at 1168 (similarly holding that the Government’s

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general interest in combating terrorism, without more, was insufficient to outweigh likely harm

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to the plaintiffs).

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Defendants argue that the Court’s rule would “threaten agencies’ abilities to take important actions . . . on
a timely basis” (Mot. at 12), but there is no reason to believe that the Court’s careful application of rulemaking
requirements to these suspensions throws open the door to rulemaking in every context. Moreover, as Plaintiffs’
counsel pointed out at oral argument, the APA contains a “good cause exception” to rulemaking. See 5 U.S.C. §
553(b)(B). The agencies chose not to invoke the exception here.

JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR) – 5

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000

 Case 2:17-cv-00178-JLR Document 100 Filed 01/04/18 Page 7 of 11

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Defendants further argue that the injunction “necessarily imposes irreparable harm on the
Government and the public interest” because the government suffers injury whenever it is
enjoined “‘from effectuating statutes enacted by representatives of its people’” (Mot. at 3
(citation omitted)), but this argument, too, was previously raised before this Court. (See Defs.’
Opp. at 28.) Moreover, the argument fails where this Court has held that the government is
acting unlawfully—i.e., in a manner that violates a statute enacted by representatives of the
people. See Hawaiʻi v. Trump, 2017 WL 6554184, at *23 (“It is axiomatic that the President
must exercise his executive powers lawfully. When there are serious concerns that the President
has not done so, the public interest is best served by ‘curtailing unlawful executive action.’”
(quoting Texas v. United States, 809 F.3d 134, 187 (5th Cir. 2015), aff’d mem. per curiam by an
equally divided court, 136 S. Ct. 2271 (2016))). Even if Defendants’ argument were accepted,
the Ninth Circuit has emphasized that any such harm “‘is not dispositive of the balance of harms
analysis.’” Latta v. Otter, 771 F.3d 496, 500 (9th Cir. 2014) (per curiam) (citation omitted)
(balance of second and third Nken factors favored individuals whose constitutional rights were
infringed over state’s interest in not having its laws and constitutional amendments enjoined).
This vague assertion of harm cannot overcome the absence of evidence of likely harm to
Defendants here, particularly when weighed against Plaintiffs’ evidence of irreparable harm.
Defendants once again invite this Court to rely on the Supreme Court’s stay in Trump v.
Hawaiʻi, No. 17A550, 2017 WL 5987406 (U.S. Dec. 4, 2017), and Trump v. International
Refugee Assistance Project, No. 17A560, 2017 WL 5987435 (U.S. Dec. 4, 2017), to argue that
the balance of equities tips in their favor (see Mot. at 2), but this Court has already declined to
speculate on the reasons for those orders (see Order at 61-62 n.30 (“It is simply impossible to say
how the Court considered the equities in the December 4, 2017, rulings, and whether the Court’s
analysis applies here.”)). Defendants have offered no reason for the Court to revisit its decision.

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JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR) – 6

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000

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Finally, Defendants’ lack of urgency in their actions belie their assertion of irreparable
harm. See Ruckelshaus v. Monsanto Co., 463 U.S. 1315, 1318 (1983) (Blackmun, J., in
chambers) (“[F]ailure to act with greater dispatch tends to blunt [one’s] claim of urgency and
counsels against the grant of a stay.”). Defendants filed this “emergency” motion nearly a week
after the Court’s Order—even though the Government can and does act more expeditiously in an
emergency. See, e.g., Notice of Appeal at 1, Washington v. Trump, No. 2:17-cv-00141 (JLR)
(W.D. Wash. filed Feb. 4, 2017) (Dkt. No. 53) (Government filed a Notice of Appeal the day
after court issued temporary restraining order); Kiyemba v. Obama, 555 F.3d 1022, 1024 n.2
(D.C. Cir. 2009) (Government moved for a stay the same day as injunction directing release of
detainees at Guantanamo Bay), vacated on other grounds, 559 U.S. 131 (2010), and reinstated
as amended, 605 F.3d 1046 (D.C. Cir. 2010). Moreover, Defendants now contend that family
members of one of the Plaintiffs, Joseph Doe, are moving ahead with travel to the United States,
and “all I-730 refugee applicants who received valid travel letters on or before October 24, 2017,
would be allowed to travel as planned.” (Decl. of Jennifer L. Smith in Support of Mot. ¶¶ 2-4
(Dkt. No. 95-1).) That Defendants have decided to permit Joseph Doe’s family and other followto-join beneficiaries from SAO countries to travel to the United States as long as they received
valid travel letters prior to the Agency Memo confirms that the government will suffer no
irreparable harm by allowing refugee admissions for follow-to-join beneficiaries and for refugees
from the SAO countries to continue during the pendency of an appeal.
C.

Defendants Have Not Rebutted the Finding of Irreparable Harm to
Plaintiffs.

Defendants’ contentions regarding irreparable harm to Plaintiffs also reiterate arguments

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that this Court has already rejected. Defendants spend almost two full pages explaining why

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each Plaintiff, or a Plaintiff’s family member, is not on “the brink of travel” such that the

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suspension purportedly would not concretely affect them (see Mot. at 7-9), even though the

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Court already considered—at length—the circumstances of each individual Plaintiff (see Order
JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR) – 7

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000

 Case 2:17-cv-00178-JLR Document 100 Filed 01/04/18 Page 9 of 11

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at 12-16, 20-25) and determined that “[a]ll of the individual Plaintiffs have been injured by
prolonged separation from their family members. Those individual Plaintiffs stranded abroad in
perilous circumstances are injured by their inability to travel to safety in the United States.”
(Order at 16 (citations omitted).)7 The Court should not enter a stay of the injunction, as such a
stay will irreparably harm the refugees abroad seeking safety, as well as the family members and
others awaiting their arrival here in the United States.
CONCLUSION
For the foregoing reasons, Plaintiffs respectfully request that the Court deny Defendants’
Emergency Motion for Stay of Preliminary Injunction Pending Appeal.

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Defendants also ignore the Court’s finding of irreparable harm to the organizational Plaintiffs and their
clients. (See Order at 25-28.)

JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR) – 8

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000

 Case 2:17-cv-00178-JLR Document 100 Filed 01/04/18 Page 10 of 11

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Respectfully submitted,
s/ Lauren Watts Staniar
David Burman, WSBA No. 10611
Lauren Watts Staniar, WSBA No. 48741
Tyler Roberts, WSBA No. 52688
Perkins Coie LLP
1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Telephone: 206.359.8000
Facsimile: 206.359.9000
dburman@perkinscoie.com
lstaniar@perkinscoie.com
troberts@perkinscoie.com
Mariko Hirose, Pro Hac Vice
Deepa Alagesan, Pro Hac Vice
Linda Evarts, Pro Hac Vice
Kathryn C. Meyer, Pro Hac Vice
International Refugee Assistance Project
40 Rector Street, 9th Floor
New York, NY 10006
Tel: (646) 459-3044
mhirose@refugeerights.org
dalagesan@refugeerights.org
levarts@refugeerights.org
kmeyer@refugeerights.org
Elizabeth Sweet, Pro Hac Vice
Mark Hetfield, Pro Hac Vice
HIAS, Inc.
1300 Spring Street, Suite 500
Silver Spring, MD 20910
Tel: 301-844-7300
liz.sweet@hias.org
mark.hetfield@hias.org

DATED: January 4, 2018
Justin B. Cox, Pro Hac Vice
National Immigration Law Center
PO Box 170208
Atlanta, GA 30317
Tel: (678) 279-5441
Fax: (213) 639-3911
cox@nilc.org
Karen C. Tumlin, Pro Hac Vice
Melissa S. Keaney, Pro Hac Vice
Esther H. Sung, Pro Hac Vice
National Immigration Law Center
3450 Wilshire Blvd, #108-62
Los Angeles, CA 90010
Tel: (213) 639-3900
Fax: (213) 639-3911
tumlin@nilc.org
keaney@nilc.org
sung@nilc.org
Lauren E. Aguiar, Pro Hac Vice
Mollie M. Kornreich, Pro Hac Vice
Abigail E. Davis, Pro Hac Vice
Four Times Square
New York, NY 10036
Tel: (212) 735-3000
Fax: (212) 735-2000
lauren.aguiar@probonolaw.com
mollie.kornreich@probonolaw.com
abigail.sheehan@probonolaw.com

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Counsel for Plaintiffs Jewish Family Service, et
al.

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JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR) – 9

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000

 Case 2:17-cv-00178-JLR Document 100 Filed 01/04/18 Page 11 of 11

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CERTIFICATE OF SERVICE
I hereby certify that on January 4, 2018, I electronically filed the foregoing document

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with the Clerk of the Court using the CM/ECF system which will send notification of such filing

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to all of the registered CM/ECF users for this case.

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I hereby declare under penalty of perjury of the laws of the State of Washington that the
foregoing in true and correct.
DATED this 4th day of January, 2018.
/s/ Lauren Watts Staniar
Lauren Watts Staniar, WSBA No. 48741

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JFS PLAINTIFFS’ OPP. TO MOT. FOR
STAY (No. 17-cv-1707-JLR) – 10

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000