Hawaii Joint Motion

Case 1:17-cv-00050-DKW-KJM Document 57 Filed 03/07/17 Page 1 of 5 PageID #: 777
DOUGLAS S. CHIN (Bar No. 6465) NEAL K. KATYAL*

Attorney General of the State of Hawaii HOGAN LOVELLS US LLP
CLYDE J. WADSWORTH (Bar No. 8495) 555 Thirteenth Street NW
Solicitor General of the State of Hawaii Washington, DC 20004
DEIRDRE MARIE-IHA (Bar No. 7923) Telephone: (202) 637-5600
DEPARTMENT OF THE ATTORNEY Fax: (202) 637-5910
GENERAL, STATE OF HAWAII Email:
425 Queen Street [email protected]
Honolulu, HI 96813
Telephone: (808) 586-1500 *Admitted Pro Hac Vice
Fax: (808) 586-1239
Email: [email protected]
Attorneys for Plaintiff, State of Hawaii Attorneys for Plaintiffs, State of
Hawaii and Ismail Elshikh
(See Next Page For Additional Counsel)
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF HAWAII
STATE OF HAWAII and ISMAIL ELSHIKH,
Plaintiffs,
v.
DONALD J. TRUMP, in his official capacity as

President of the United States; U.S. Civil Action No. 1:17-cv-
DEPARTMENT OF HOMELAND SECURITY; 00050-DKW-KJM
JOHN F. KELLY, in his official capacity as
Secretary of Homeland Security; U.S.
DEPARTMENT OF STATE; REX TILLERSON,
in his official capacity as Secretary of State; and
the UNITED STATES OF AMERICA,
Defendants.
JOINT MOTION FOR ENTRY OF PROPOSED BRIEFING SCHEDULE

ORDER FOR PLAINTIFFS FORTHCOMING MOTION FOR A
TEMPORARY RESTRAINING ORDER
1
ADDITIONAL COUNSEL
DONNA H. KALAMA (Bar No. 6051) COLLEEN ROH SINZDAK*

KIMBERLY T. GUIDRY (Bar No. 7813) MITCHELL P. REICH*
ROBERT T. NAKATSUJI (Bar No. 6743) ELIZABETH HAGERTY*
Deputy Attorneys General HOGAN LOVELLS US LLP
DEPARTMENT OF THE ATTORNEY 555 Thirteenth Street NW
GENERAL, STATE OF HAWAII Washington, DC 20004
425 Queen Street Telephone: (202) 637-5600
Honolulu, HI 96813 Fax: (202) 637-5910
Telephone: (808) 586-1500
Fax: (808) 586-1239 THOMAS P. SCHMIDT*
HOGAN LOVELLS US LLP
Attorneys for Plaintiff, State of Hawaii 875 Third Avenue
New York, NY 10022
Telephone: (212) 918-3000
Fax: (212) 918-3100
SARA SOLOW*
ALEXANDER B. BOWERMAN*
HOGAN LOVELLS US LLP
1835 Market St., 29th Floor
Philadelphia, PA 19103
Telephone: (267) 675-4600
Fax: (267) 675-4601
*Admitted Pro Hac Vice
Attorneys for Plaintiffs, State of

Hawaii and Ismail Elshikh
2
JOINT MOTION FOR ENTRY OF PROPOSED BRIEFING SCHEDULE

ORDER FOR PLAINTIFFS FORTHCOMING MOTION FOR A
TEMPORARY RESTRAINING ORDER
The parties file the instant joint motion with this Court, respectfully moving
for the entry of a Proposed Briefing Schedule Order for Plaintiffs forthcoming
Motion for a Temporary Restraining Order.
On March 6, 2017, Plaintiffs conferred with counsel for the Government and
informed the Government that Plaintiffs intended to file a Motion to Lift the Stay
and for Leave to File a Second Amended Complaint, as well as a Second Amended
Complaint and a Motion for a Temporary Restraining Order in connection with
President Donald Trumps new Executive Order, signed March 6, 2017. On
March 7, 2017, the Government responded that it consents to Plaintiffs request to
lift the stay of the proceedings in this case to the extent that Plaintiffs seek to
challenge the new Executive Order. The Government related that it takes no
position on Plaintiffs Motion for Leave to File a Second Amended Complaint.
Upon further discussion, the parties have agreed to the following briefing
and argument schedule on Plaintiffs forthcoming Motion for a Temporary
Restraining Order, if it is acceptable to this Court. Namely, the parties propose
that: Plaintiffs file their Second Amended Complaint, Motion for a Temporary
Restraining Order, and any declarations in support thereof on March 8, 2017; the
Government files its Opposition to Plaintiffs Motion for a Temporary Restraining
3
Order by 6 AM Hawaii Standard Time on March 13, 2017; Plaintiffs file a Reply
by 12 Noon Hawaii Standard Time on March 14, 2017; and both parties prepare to
appear at a hearing in this Court with telephonic access available on the morning of
March 15, 2017. The parties have also agreed, if it is acceptable to this Court, to
seek leave to allow both parties to file briefs of up to 12,000 words for Plaintiffs
Memorandum of Law in Support of their Motion for a Temporary Restraining
Order and the Governments opposition thereto.
The parties respectfully move for the entry of a proposed briefing schedule
with the above dates and word limits. Given that the Executive Order will become
effective at 6:01 P.M. Hawaii Standard Time on March 15, 2017, the proposed
briefing and argument schedule will enable the Court to consider Plaintiffs motion
for a temporary restraining order before the Executive Order is scheduled to take
effect.
DATED: Honolulu, Hawaii, March 7, 2017.
Respectfully submitted,
4
/s/ Brad P. Rosenberg /s/ Neal K. Katyal
CHAD A. READLER NEAL K. KATYAL*

Acting Assistant Attorney General COLLEEN ROH SINZDAK*
FLORENCE T. NAKAKUNI MITCHELL P. REICH*
United States Attorney ELIZABETH HAGERTY*
EDRIC M. CHING THOMAS P. SCHMIDT*
Assistant United States Attorney SARA SOLOW*
JOHN R. TYLER ALEXANDER B. BOWERMAN*
Assistant Branch Director HOGAN LOVELLS US LLP
MICHELLE R. BENNETT *Admitted Pro Hac Vice

(Co. Bar No. 37050)
BRAD P. ROSENBERG Attorneys for Plaintiffs, State of Hawaii
(D.C. Bar No. 467513) and Ismail Elshikh
DANIEL SCHWEI (N.Y. Bar)
Trial Attorneys DOUGLAS S. CHIN (Bar No. 6465)
UNITED STATES DEPARTMENT Attorney General of the State of Hawaii
OF JUSTICE CLYDE J. WADSWORTH (Bar No. 8495)
CIVIL DIVISION, FEDERAL Solicitor General of the State of Hawaii
PROGRAMS BRANCH DEIRDRE MARIE-IHA (Bar No. 7923)
20 Massachusetts Ave, N.W. DONNA H. KALAMA (Bar No. 6051)
Washington, DC 20530 KIMBERLY T. GUIDRY (Bar No. 7813)
Tel: (202) 514-3374 ROBERT T. NAKATSUJI (Bar No. 6743)
Fax: (202) 616-8460 Deputy Attorneys General
E-mail: [email protected] DEPARTMENT OF THE ATTORNEY
GENERAL, STATE OF HAWAII
Attorneys for Defendants
Attorneys for Plaintiff, State of Hawaii

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Case 1:17-cv-00050-DKW-KJM Document 57 Filed 03/07/17 Page 1 of 5 PageID #: 777

DOUGLAS S. CHIN (Bar No. 6465) NEAL K. KATYAL*

IN THE UNITED STATES DISTRICT COURT

STATE OF HAWAII and ISMAIL ELSHIKH,

DONALD J. TRUMP, in his official capacity as

JOINT MOTION FOR ENTRY OF PROPOSED BRIEFING SCHEDULE

DONNA H. KALAMA (Bar No. 6051) COLLEEN ROH SINZDAK*

*Admitted Pro Hac Vice

Attorneys for Plaintiffs, State of

JOINT MOTION FOR ENTRY OF PROPOSED BRIEFING SCHEDULE

Motion for a Temporary Restraining Order.

Complaint and a Motion for a Temporary Restraining Order in connection with

President Donald Trumps new Executive Order, signed March 6, 2017. On

March 7, 2017, the Government responded that it consents to Plaintiffs request to

position on Plaintiffs Motion for Leave to File a Second Amended Complaint.

and argument schedule on Plaintiffs forthcoming Motion for a Temporary

Restraining Order, if it is acceptable to this Court. Namely, the parties propose

Government files its Opposition to Plaintiffs Motion for a Temporary Restraining

Memorandum of Law in Support of their Motion for a Temporary Restraining

Order and the Governments opposition thereto.

DATED: Honolulu, Hawaii, March 7, 2017.

/s/ Brad P. Rosenberg /s/ Neal K. Katyal

CHAD A. READLER NEAL K. KATYAL*

MICHELLE R. BENNETT *Admitted Pro Hac Vice

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