United States District Court

Western District of Texas

San Antonio Division

City of San Antonio,

Plaintiff,

v. No. 5:20-CV-00505-OLG

United States Department of Homeland 

Security; Chad F. Wolf, in his official capacity 

as Acting Secretary of the United States 

Department of Homeland Security; Chad 

Mizelle, in his official capacity as Senior 

Official Performing the Duties of the General 

Counsel for the United States Department of 

Homeland Security, Warren R. Kaufman, in 

his official capacity as Representative and 

Delegate of the Office of the General Counsel 

for the United States Department of Homeland 

Security; United States Immigration and 

Customs Enforcement; Matthew T. Albence in 

his official capacity as Deputy Director and 

Senior Official Performing the Duties of the 

Director of United States Immigration and 

customs Enforcement; and United States of 

America,

Defendants.

Joint Status Report

The parties are continuing to work together to complete agreed upon discovery pursuant to 

a settlement agreement that allows for non-party discovery under the Texas Rules of Civil 

Procedure, including an oral deposition and depositions on written questions. The parties 

conducted an oral deposition on January 13, 2021. The parties continue to negotiate depositions 

on written questions and anticipate finalizing those within 30 days of this report. As a result, the 

parties jointly request that this Court continue to hold the case in abeyance while they complete 

the agreed upon discovery. Following the completion of this discovery, Plaintiff will file a Notice 

of Voluntary Dismissal, pursuant to the terms of the settlement agreement. The parties agree to 

Case 5:20-cv-00505-OLG Document 23 Filed 01/29/21 Page 1 of 3
file a fourth joint status report with this Court by March 5, 2021, if the issues have not been 

resolved by the date. 

Respectfully submitted,

Gregg N. Sofer

United States Attorney

By: /s/ Lacy L. McAndrew

Lacy L. McAndrew

Assistant United States Attorney

Florida Bar No. 45507

601 N.W. Loop 410, Suite 600

San Antonio, Texas 78216

(210) 384-7340 (phone)

(210) 384-7312 (fax)

lacy.mcandrew@usdoj.gov

Attorneys for Defendants

SCOTT DOUGLASS & McCONNICO LLP

303 Colorado Street, Suite 2400

Austin, Texas 78701

(512) 495-6300 (phone)

(512) 495-6399 (fax)

By: /s/Kennon L. Wooten*________________

Kennon L. Wooten

State Bar No. 24046624

kwooten@scottdoug.com

Steve McConnico

State Bar No. 13450300

smcconnico@scottdoug.com

William G. Cochran

State Bar No. 24092263

wcochran@scottdoug.com

Attorneys for Plaintiff

*signed with permission

Case 5:20-cv-00505-OLG Document 23 Filed 01/29/21 Page 2 of 3
Certificate of Service

I certify that on January 29, 2021, I electronically filed this document with the Clerk of Court 

using the CM/ECF system.

☒ The CM/ECF system will send notification to the following CM/ECF participant(s):

Steve McConnico (smcconnico@scottdoug.com)

Kennon L. Wooten (kwooten@scottdoug.com)

William G. Cochran (wcochran@scottdoug.com)

/s/ Lacy L. McAndrew

Lacy L. McAndrew

Assistant United States Attorney

Case 5:20-cv-00505-OLG Document 23 Filed 01/29/21 Page 3 of 3