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alaisg.bsky.social
@alaisg.bsky.social
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Peloton law mom. Former D1 runner. Former Obama appointee. Believer in democracy, civil liberties, and rule of law.
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ericcolumbus.bsky.social
JUDGE HOWELL moves *very* fast and schedules hearing for Wednesday 2pm on PERKINS COIE’s motion for a temporary restraining order.

Brief here:

storage.courtlistener.com/recap/gov.us...

All case docs here:

storage.courtlistener.com/recap/gov.us...
Mar 11, MINUTE ORDER (paperless) DIRECTING 2025 the parties to appear for a hearing on plaintiff's 2 Motion for Temporary Restraining Order on March 12, 2025, at 2:00 PM, in Courtroom 26A- In Person before Judge Beryl A. Howell, and ORDERING plaintiff to serve defendants with a copy of this Order immediately upon receipt to ensure that counsel for defendants has sufficient notice to appear at the hearing. Signed by Judge Beryl A. Howell on March 11, 2025. (Icbah2) Case 1:25-cv-00716 Document 2-1 Filed 03/11/25 Page 1 of 57 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA PERKINS COIE LLP, Plaintiff, V. U.S. DEPARTMENT OF JUSTICE, FEDERAL COMMUNICATIONS COMMISSION, OFFICE OF MANAGEMENT AND BUDGET, EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, OFFICE OF PERSONNEL MANAGEMENT, GENERAL SERVICES ADMINISTRATION, OFFICE OF THE DIRECTOR OF NATIONAL INTELLIGENCE, THE UNITED STATES OF AMERICA, and, in their official capacities, PAMELA J. BONDI, BRENDAN CARR, RUSSELL T. VOUGHT, ANDREA R. LUCAS, CHARLES EZELL, STEPHEN EHEKIAN, and TULSI GABBARD, Defendants. Civil Action No. 1:25-cv-00716 EMERGENCY HEARING RESPECTFULLY REQUESTED MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF PERKINS COIE'S MOTION FOR A TEMPORARY RESTRAINING ORDER Case 1:25-cv-00716 Document 2-1 Filed 03/11/25 Page 2 of 57 TABLE OF CONTENTS TABLE OF CONTENTS TABLE OF AUTHORITIES. iii INTRODUCTION 1| BACKGROUND .4 A. B. Perkins Coie's History of Advocating for Its Clients.. The Executive Order and Accompanying "Fact Sheet" 4 C. The Order Is Already Inflicting Irreparable Harm.. ...5 .7 D. The Executive Order Is Politically Motivated Retribution LEGAL STANDARD AND REVIEWABLITY.. .9 ARGUMENT I. PERKINS COIE IS LIKELY TO SUCCEED ON THE MERITS …10 ..12 .12 A. The Executive Order Exceeds the President's Constitutional Authority and Violates the Separation of Powers 1. No Statutory or Constitutional Authority Supports the Order 2. The Executive Order Improperly Usurps Judicial Power The Executive Order Violates the First Amendment. 1. The Executive Order Retaliates in Violation of the First Amendment. .12 .13 …15 .19 .20 C. D. 2. The Executive Order Constitutes Viewpoint Discrimination The Executive Order Violates Perkins Coie's Right to Due Process .22 .24 1. The Order Deprives Perkins Coie of Liberty and Property Interests ..25 2. The Executive Order Was Issued Without Notice or A Hearin,..............29 3. The Executive Order Is Impermissibly Vague. .30 The Executive Order Violates Sixth Amendment and Due Process Rights to Counsel. 1. Perkins Coie Has Standing To Challenge These Violations. .31 .32 i Case 1:25-cv-00716 Document 2-1 Filed 03/11/25 Page 3 of 57 The Executive Order Violates Bedrock Sixth Amendment Rights 3. The Executive Order Also Violates the Due Process Right to Counsel E. The Executive Order Violates Equal Protection A TRO IS NEEDED TO STOP IRREPARABLE HARM. A. Perkins Coie Is Suffering Irreparable Economic Harm. B. The Executive Order Has Impaired Perkins Coie's Constitutional Rights C. Perkins Coie Is Suffering Ongoing and Irreparable Reputational Harm. M. THE EQUITIES AND PUBLIC INTEREST STRONGLY FAVOR A TRO CONCLUSION.. ..32 .34 .35 .36 .37 ...39 .42 .43 .45
March 11, 2025 at 10:02 PM