Case 3:18-cv-06810-JST Document 60 Filed 11/29/18 Page 1 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 JOSEPH H. HUNT Assistant Attorney General SCOTT G. STEWART Deputy Assistant Attorney General AUGUST E. FLENTJE Special Counsel WILLIAM C. PEACHEY Director EREZ REUVENI Assistant Director CHRISTINA P. GREER Trial Attorney Office of Immigration Litigation U.S. Department of Justice, Civil Division P.O. Box 868, Ben Franklin Station Washington, DC 20044 Tel: (202) 598-8770 Email: Christina.P.Greer@usdoj.gov PATRICK GLEN Senior Litigation Counsel JOSEPH DARROW FRANCESCA GENOVA Trial Attorneys 15 16 17 18 19 20 21 22 23 24 25 26 27 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA ) East Bay Sanctuary Covenant, et al., ) ) Plaintiffs, ) ) v. ) ) ) ) Donald J. Trump, President of the United ) States, et al., ) ) Defendants. ) ) 28 NOTICE OF FILING OF THE ADMINISTRATIVE RECORD East Bay Sanctuary v. Trump, Case No. 3:18-cv-06810-JST NOTICE OF FILING OF THE ADMINISTRATIVE RECORD Civil Action No. 3:18-cv-06810-JST Case 3:18-cv-06810-JST Document 60 Filed 11/29/18 Page 2 of 4 1 Defendants, by and through undersigned counsel, today served on Plaintiffs the 2 administrative record for purposes of this lawsuit. That record, certified by relevant officials at 3 the Departments of Homeland Security and Justice, contains all materials—to the best of the 4 certifiers’ knowledge, information, and belief—considered by the Departments in promulgating 5 the interim final rule titled “Aliens Subject to a Bar on Entry Under Certain Presidential 6 Proclamations; Procedures for Protection Claims,” and issued November 9, 2018. See 83 Fed. 7 Reg. 55934. Defendants have served the record via email, and are sending a copy separately via 8 U.S. mail. Defendants today are also providing the court with a paper copy of the record. 9 Defendants also respectfully note that they reserve the right to supplement the record if 10 they identify additional materials that were part of the record subsequent to this filing. The interim 11 final rule is premised on significant factual material contained in myriad documents held between 12 two agencies and their subcomponents. Complex coordination between these agencies is required 13 to produce a full and complete record, as recognized by this Court’s Local Rule providing the 14 Government 90 days following the summons to compile and certify a record in the normal course. 15 See Local Rule 16-5. The Departments have been working diligently to compile the administrative 16 record since before this Court’s scheduling order (ECF No. 50), but given the extremely truncated 17 time in which the Defendants have been required to produce a record, it remains possible that 18 supplementation may be warranted. 19 // 20 // 21 22 23 24 25 26 27 28 NOTICE OF FILING OF THE ADMINISTRATIVE RECORD East Bay Sanctuary v. Trump, Case No. 3:18-cv-06810-JST Case 3:18-cv-06810-JST Document 60 Filed 11/29/18 Page 3 of 4 Respectfully submitted, 1 JOSEPH H. HUNT Assistant Attorney General 2 3 SCOTT G. STEWART Deputy Assistant Attorney General 4 5 AUGUST E. FLENTJE Special Counsel 6 7 WILLIAM C. PEACHEY Director 8 9 EREZ REUVENI Assistant Director 10 By: /s/ Christina P. Greer CHRISTINA P. GREER Trial Attorney Office of Immigration Litigation U.S. Department of Justice, Civil Division 450 5th Street NW Washington, DC 20530 Tel: (202) 598-8770 Email: Christina.P.Greer@usdoj.gov 11 12 13 14 15 16 17 EREZ REUVENI Assistant Director 18 PATRICK GLEN Senior Litigation Counsel 19 20 JOSEPH DARROW FRANCESCA GENOVA Trial Attorneys 21 22 23 Dated: November 29, 2018 24 25 26 27 28 NOTICE OF FILING OF THE ADMINISTRATIVE RECORD East Bay Sanctuary v. Trump, Case No. 3:18-cv-06810-JST Attorneys for Defendants Case 3:18-cv-06810-JST Document 60 Filed 11/29/18 Page 4 of 4 1 CERTIFICATE OF SERVICE 2 I hereby certify that on November 29, 2018, I electronically filed the foregoing document 3 with the Clerk of the Court for the United States Court of for the Northern District of California 4 by using the CM/ECF system. Counsel in the case are registered CM/ECF users and service will 5 be accomplished by the CM/ECF system. 6 7 8 9 By: /s/ Christina P. Greer CHRISTINA P. GREER Trial Attorney United States Department of Justice Civil Division 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF FILING OF THE ADMINISTRATIVE RECORD East Bay Sanctuary v. Trump, Case No. 3:18-cv-06810-JST