IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

The STATE OF TEXAS, et. al., §

§

Plaintiffs, §

§ CIVIL ACTION NO. 3:22–cv–00780-m

 vs. §

§

JOSEPH R. BIDEN, JR., §

in his official capacity as §

President of the United States, et al., §

§

Defendants, §

§

and §

§

TIMOTEO, and UZIAS, §

§

Intervenor-Defendants. §

MOTION TO INTERVENE UNDER FED. R. CIV. P. 24

AND BRIEF IN SUPPORT

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TABLE OF CONTENTS

TABLE OF AUTHORITIES .......................................................................................................... ii 

INTRODUCTION .......................................................................................................................... 1

BACKGROUND ............................................................................................................................ 1

A. Relevant Background on the CAM Program.......................................................... 1

B. Plaintiff States’ Challenge to the Biden Administration’s Reopening of 

CAM ....................................................................................................................... 5

C. Proposed 2023 Intervenors are the Intended Beneficiaries of the CAM 

Enhancements......................................................................................................... 6

ARGUMENT.................................................................................................................................. 8

CONCLUSION............................................................................................................................. 13

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TABLE OF AUTHORITIES

Page(s)

Cases

League of United Latin Am. Citizens, Council No. 4434 v. Clements,

884 F.2d 185 (5th Cir. 1989) .....................................................................................................9

S.A. v. Trump,

363 F. Supp. 3d 1048 (N.D. Cal. 2018).....................................................................................3

S.A. v. Trump,

No. 18-cv-03539-LB, 2019 WL 990680 (N.D. Cal. Mar. 1, 2019).......................................3, 4

Students for Fair Admissions, Inc. v. Univ. of Texas at Austin,

338 F.R.D. 364 (W.D. Tex. 2021) .............................................................................................9

Texas v. U.S. Dep’t of Homeland Sec.,

No. 6:23-CV-00007, 2023 WL 3025080 (S.D. Tex. Apr. 19, 2023)...........................10, 11, 12

Texas v. United States,

805 F.3d 653 (5th Cir. 2015) ...............................................................................................8, 12

Other Authorities

Fed. R. Civ. P. 24.............................................................................................................................9

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INTRODUCTION

Proposed Intervenors Antonio, Magdalena, Marta, and Elizabeth1(“Proposed 2023 

Intervenors”) move to intervene as defendants in this action seeking to thwart the reopening of 

the Central American Minors (“CAM”) Program. This Court previously granted intervention to 

two parents, Defendant-Intervenors Timoteo and Uzias, who sought to reunify with their children 

under earlier phases of CAM’s reopening. Order 3, ECF 41. In its Order, the Court recognized 

Defendant-Intervenors’ interest in this case and acknowledged that their experience of applying 

for CAM parole for their children would bring “a perspective that will contribute to full 

development of the underlying factual issues.” Id. Timoteo has since been reunited with his 

daughter in the United States through CAM. Joint Status Report Regarding Jurisdictional 

Discovery 2, ECF 96. And in April 2023, the Biden Administration again expanded eligibility 

for CAM’s reopening, giving Proposed 2023 Intervenors an opportunity to be considered for 

CAM parole. See Meyer Decl., Ex. BB, App’x at 503 (“CAM Enhancements”). Plaintiff States 

have just informed the Court that they intend to proceed with this action and incorporate the 

enhancements into their existing challenge, see Unopposed Mot. for Leave for Pls. to File a 

Suppl. Cmpl., ECF 108, and Proposed 2023 Intervenors now seek to defend their humanitarian 

interest in reuniting with their children through the CAM program.

BACKGROUND

A. Relevant Background on the CAM Program2

The Obama Administration created the CAM Program in 2014 in response to 

unprecedented numbers of unaccompanied minors fleeing danger in Central America and 

1 Proposed 2023 Intervenors concurrently file a motion to proceed under pseudonym. 

2

In light of the Court’s familiarity with the CAM Program, Proposed 2023 Intervenors focus 

their discussion on facts relevant to how Proposed Intervenors who are newly eligible for CAM

are differently situated than the current Defendant-Intervenors. 

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arriving at the southern border. See Meyer Decl., Ex. A, App’x at 70. CAM provided lawfully 

present parents, who were established in the United States but lacking a pathway to reunite with 

family, with an avenue to bring their children safely and legally by plane. See Meyer Decl., Ex. 

B, App’x at 117. Eligible statuses for CAM parents at that time included Temporary Protected 

Status (“TPS”), a legal status that has been available to certain Salvadorans and Hondurans in the 

United States who entered prior to 2001 and 1999, respectively, and who did not otherwise have 

a legal means for sponsoring their children to join them in the United States. Meyer Decl., Ex. 

A, App’x at 86 & n.127, 102; Id., Ex. Y, App’x at 458; Id., Ex. Z, App’x at 472. When CAM 

began, asylum seekers and individuals who were eligible to apply for visas after being victims of 

crime (U Visa petitioners) or trafficking (T Visa applicants) were not eligible. Cf. id., Ex. A, 

App’x at 102 (omitting these statuses from the list of qualifying statuses).

CAM was created as a dual track refugee and parole program. Id., Ex. A., App’x at 102-

03. First, CAM applicants are considered for refugee resettlement, which affords a path to 

permanent legal status in the United States. Id., App’x at 96, 106. If applicants are not approved 

as refugees, they are considered for temporary parole in the United States on a case-by-case 

basis. Id. at 106. CAM processing begins with multiple screening and vetting steps, including 

DNA testing to confirm the biological relationship with the U.S.-based parent, security checks, 

an in-person interview, and ultimately a USCIS decision conditionally granted refugee 

resettlement or parole. Id., App’x 104-06. If an applicant is approved to proceed on either the 

refugee or the parole track, they must then complete a medical exam, undergo additional security 

vetting, and arrange for their flights to the United States.3Id., App’x at 106-07. This process can 

3 Parolees must pay for their own medical exams and flights to the United States. Meyer Decl., 

Ex. A, App’x at 105.

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be lengthy and take several years. Id., App’x at 85; see also Id., Ex. AA, App’x at 495 

(discussing backlogs and delays in CAM processing).

When the Trump Administration shut down the CAM program soon after President 

Trump took office, it did so in stages. First, the Trump Administration shut down CAM’s parole 

track, including for applicants who had been in processing for years, were conditionally 

approved for parole, and were on the verge of travel. See Mot. to Intervene 2-3, ECF 19 (noting 

DHS stopped processing CAM parole cases in early 2017 and publicly terminated CAM parole 

six months later). But the refugee track remained open. Meyer Decl., Ex. D., App’x at 131. 

During this time, pending CAM cases in the pipeline that had been filed under the Obama 

Administration were only considered for refugee status—not for CAM parole, id., as they had 

understood they would be considered for when they applied. As a result, if a pending application 

was found to be ineligible for refugee resettlement, the family received a CAM denial outright

without being evaluated for parole. Proposed Intervenors Antonio and Magdalena are in this 

group of CAM petitioners. See Antonio Decl. ¶¶ 27-29, 39, App’x at 15-16; Magdalena Decl. ¶¶ 

19-22, App’x at 27.

Later, the Trump Administration shut down CAM’s refugee track, also in stages. In 

January 2018, it shut down the refugee track for pending applicants who had applied under the 

Obama Administration and had been in processing for years but who had not yet been 

interviewed. Meyer Decl., Ex. C, App’x at 125. Current Defendant-Intervenor Timoteo is in this 

group of CAM applicants. Mot. to Intervene 6, ECF 19. 

Meanwhile, a non-profit organization and six families sued to reopen the CAM parole 

program. S.A. v. Trump, 363 F. Supp. 3d 1048, 1055 (N.D. Cal. 2018) (“S.A. I”); see also S.A. v. 

Trump, No. 18-cv-03539-LB, 2019 WL 990680, at *2 (N.D. Cal. Mar. 1, 2019) (“S.A. II”); Mot. 

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to Intervene 3-4, ECF 19.4 Through a preliminary injunction and subsequent settlement 

agreement in this litigation, the government agreed to reopen and finish processing over 2,700 

CAM cases that had been in the final stages of parole processing when the program was 

terminated—specifically, applicants who had already been “conditionally approved for parole.”

See S.A. II, 2019 WL 990680 at *13, 17; Meyer Decl., Ex. F, App’x at 137-40. But the 

government was not required to reopen pending cases, such as Antonio’s and Magdalenda’s

families’ applications, that had been denied refugee resettlement but never considered for parole

because parole processing was closed. Antonio Decl. ¶¶ 24-29, App’x at 15; Magdalena Decl. ¶¶ 

19-22, App’x at 26. 

When the Biden Administration reopened CAM beginning in 2021, it reopened the 

program in stages. First, in “Phase One,” it moved to reopen the program for applicants such as 

Defendant-Intervenor Timoteo, who filed CAM applications under the Obama Administration 

but had not yet been interviewed and never received a decision. Meyer Decl., Ex. J, App’x at 

177. Then, in “Phase Two,” it reopened CAM to new applicants and expanded eligibility to 

certain lawfully present parents in the United States who did not otherwise have a legal pathway 

to reunite with their children, namely parents with pending asylum and U Visa petitions whose 

underlying asylum applications and U Visa petitions were submitted before May 15, 2021. Id., 

Ex. K, App’x at 179. Current Defendant-Intervenor Uzias is in this group of newly eligible CAM 

parents. Mot. to Intervene 6-7, ECF 19. 

Two years later, in April 2023, the Biden Administration again expanded CAM eligibility 

and made additional changes to CAM processing through the CAM Enhancements. Meyer Decl., 

4 As the Court is aware, Proposed 2023 Intervenors’ counsel, the International Refugee 

Assistance Project, was counsel for the Plaintiffs in S.A. v. Trump. See Mot. to Intervene 3 n.3, 

ECF 19.

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Ex. BB, App’x at 503, 509-10. Of relevance here is that the Enhancements gave parents like 

Antonio and Magdalena, who applied under the Obama Administration and had undergone an 

interview, the opportunity to have their children’s applications considered for humanitarian 

parole for the first time. See id.; Antonio Decl. ¶ 39, App’x at 16; Magdalena Decl. ¶ 22, App’x 

at 27. It also expanded CAM eligibility: T Visa applicants were permitted to file CAM 

applications for the first time, and more asylum seekers and U Visa petitioners became eligible—

specifically individuals whose asylum applications and U Visa petitions were filed between May 

15, 2021 and April 11, 2023. Meyer Decl., Ex. BB, App’x at 510. Proposed 2023 Intervenors 

Marta and Elizabeth are in this group of CAM applicants. See Marta Decl. ¶ 34, App’x at 40; 

Elizabeth Decl. ¶ 31, App’x at 51. 

B. Plaintiff States’ Challenge to the Biden Administration’s Reopening of CAM

On January 28, 2022, Plaintiff States challenged the Biden Administration’s reopening of

CAM. Compl., ECF 1; see also Am. Compl., ECF 14. The Court thereafter permitted Timoteo 

and Uzias, two parents with pending CAM applications for their children under the 2021 Biden 

reopening, to intervene. Order, ECF 41 at 3. One of the Defendant-Intervenors, Timoteo, was 

reunited with his daughter in the United States, Joint Status Report Regarding Jurisdictional 

Discovery 2, ECF 96; she remains eligible for CAM re-parole but is no longer awaiting CAM incountry processing in El Salvador.

The parties are currently engaging in a reciprocal jurisdictional discovery process and are 

scheduled to serve responses and objections on September 15, 2023. Order on Schedule for 

Further Proceedings, ECF 107. The case remains in its infancy, Order, ECF 102, with no answer 

or dispositive motions filed to date, and motion to dismiss briefing set for October and

November, See Order, ECF 107. On August 23, 2023, Plaintiffs filed a motion for leave to file a

supplemental complaint, in which they incorporated the April 2023 CAM Enhancements into 

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their challenge. Unopposed Mot. for Leave to File a Suppl. Compl., ECF 108; Suppl. Compl, 

ECF 108-1.

C. Proposed 2023 Intervenors are the Intended Beneficiaries of the CAM 

Enhancements 

Proposed 2023 Intervenors Antonio, Magdalena, Marta, and Elizabeth move to intervene 

to defend the CAM program and their opportunity to reunite safely with their relatives under the 

CAM Enhancements. 

Proposed Intervenor Antonio has lived in Massachusetts for about 22 years. Antonio 

Decl. ¶ 3, App’x at 13. He has Temporary Protected Status and has other relatives with status in 

the United States, including a son in Boston who has Lawful Permanent Resident status. Id. ¶¶ 

4-6, App’x at 13. During the Obama Administration, Antonio applied to CAM on behalf of his 

youngest son and wife who live in El Salvador. Id. ¶ 22, App’x at 14. In 2017, after his wife and 

son had been interviewed, they were denied refugee resettlement under CAM. Id. ¶¶ 26-27, 

App’x at 15. Their case was then closed without being considered for CAM parole because the 

Trump Administration had already shut down parole processing. Id. ¶¶ 28-29, App’x at 15. The 

situation in El Salvador has remained very dangerous for Antonio’s wife and son. Id. ¶¶ 30-38, 

App’x at 15-16. One day, men broke into Antonio’s mother-in-law’s home and beat her until 

she nearly died, and the family fears that gangs will forcibly recruit or attack Antonio’s son. Id.

¶¶ 32-36, App’x at 15. Antonio’s family’s CAM case is newly eligible to be considered for 

CAM parole under the CAM Enhancements. Id. ¶ 39, App’x at 16.

Proposed Intervenor Magdalena has lived in Virginia for 22 years and has Temporary 

Protected Status. Magdalena Decl. ¶¶ 3-4, App’x at 20, 26. In 2015, Magdalena applied to CAM 

on behalf of her two youngest daughters in El Salvador. Id. ¶¶ 8, 19, App’x at 26-27. Her 

daughters were subsequently interviewed, but their case was then closed without being 

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considered for CAM parole because the Trump Administration had already shut down parole 

processing. Id. ¶¶ 20-21, App’x at 27. Magdalena continues to fear for her family’s safety and is 

eager to safely reunite with her daughters in the United States. Id. ¶¶ 25, 38, App’x at 27, 29. 

Her family lives in an area of El Salvador with strong gang presence, and one of her daughters 

was stabbed in an attempted robbery. Id. ¶¶ 26, 28, App’x at 27-28. In 2022, the police arrested 

three of her daughters as part of the Salvadoran government’s “state of exception,” which has 

involved the mass detention of tens of thousands of citizens and suspension of civil rights and 

liberties; two have since been released and one remains imprisoned. Id. ¶¶ 31-33, App’x at 28; 

see also Meyer Decl., Ex. CC, App’x at 514-15. Magdalena’s daughters’ CAM cases are newly 

eligible to be considered for CAM parole under the CAM Enhancements. Magdalena Decl. ¶ 

22, App’x at 27.

Proposed Intervenor Marta has lived in North Carolina for about two years. Marta Decl. ¶ 

3, App’x at 38. She has a pending asylum application and lives with her son who came with her 

to the United States. Id. ¶¶ 4-6,, App’x at 38. Marta fled Honduras with her youngest son after 

her brother, who is in a gang, repeatedly threatened to kill her. Id. ¶¶ 16-18, App’x at 38-39. She 

has three other children whom she could not bring with her and who stayed behind with her 

mother in Honduras, who has since passed away. Id. ¶¶ 19-20, 25, App’x at 39. The situation in 

Honduras has remained very dangerous for Marta’s children. Id. ¶¶ 21-27, App’x at 39. Her 

brother has threatened to harm her children, and they have had to change where they live 

frequently out of fear for their safety. Id. ¶¶ 23, 27, App’x at 39. Marta is newly eligible to apply 

to reunite with her children under the CAM Enhancements because she has a pending asylum 

application filed after May 15, 2021 and before April 11, 2023. Id. ¶ 34, App’x at 40.

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Proposed Intervenor Elizabeth has lived in New York for about a year and a half. 

Elizabeth Decl. ¶ 4, App’x at 49. She has a pending asylum application and lives with her partner 

and young son. Id. ¶¶ 5-6, App’x at 49. Elizabeth fled Guatemala with her partner and thennewborn after facing abuse from the father of her two older children. Id. ¶¶ 15, 21, App’x at 49-

50. She was not able to bring her two older children to the United States with her, and they 

stayed behind in the care of her mother. Id. ¶¶ 21-22, App’x at 50. The situation in Guatemala 

has remained very dangerous for Elizabeth’s children, and she fears that their father will attack 

her family or take her children away. Id. ¶¶ 23-24, App’x at 50. Elizabeth is newly eligible to 

apply to reunite with her children under the CAM Enhancements because she has a pending 

asylum application filed after May 15, 2021 and before April 11, 2023. Id. ¶¶ 30-32, App’x at 

50-51.

ARGUMENT

Proposed 2023 Intervenors request that the Court grant them permission to intervene for 

the same reasons it permitted Defendant-Intervenors Timoteo and Uzias to participate in this 

case: namely, to defend their personal interest in the continued availability of the CAM Program 

as a means for families to reunite in safety and to provide the Court with important perspectives 

and information about the Program that may otherwise be lacking. See Order 3, ECF 41. Rule 24 

is to be “liberally construed” and intervention should be permitted “where no one would be hurt 

and greater justice could be attained.” Texas v. United States, 805 F.3d 653, 657 (5th Cir. 2015)

(“Texas I”) (quoting Sierra Club v. Epsy, 18 F.3d 1202, 1205 (5th Cir. 1994)). 

The Court previously granted permissive intervention to Defendant-Intervenors Timoteo 

and Uzias upon its finding that their motion was timely, they had an interest in this case, and 

their personal experience would contribute to the Court’s understanding of the factual issues at 

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play. See Order 3, ECF 41. So too is permissive intervention appropriate here to enable newly 

eligible applicants to defend the CAM program. Proposed 2023 Intervenors Antonio, Magdalena,

Marta, and Elizabeth satisfy the legal requirements for permissive intervention and would add an 

important perspective. Given that they have just become eligible for CAM under the 

Enhancements, their cases have not yet begun processing, and they will have an ongoing interest 

in the CAM program’s availability for children in danger in Central America. Current 

Defendant-Intervenors’ interest is or is likely to become more limited, given that their relatives

are well along in processing or have already arrived in the United States. 

A court may, in its discretion, grant permissive intervention where: (1) the motion is 

timely, (2) the proposed intervenor “has a claim or defense that shares with the main action a 

common question of law or fact,” and (3) where the intervention will not “unduly delay or 

prejudice the adjudication of the original parties’ rights.” Fed. R. Civ. P. 24(b)(1), (3). In 

addition, courts “may consider, inter alia, the effect of permitting intervention on the existing 

parties, whether the intervenors’ interests are adequately represented by other parties and 

whether the intervenors will significantly contribute to full development of the underlying factual 

issues in the suit.” Order, ECF 41 at 2 (citing New Orleans Pub. Serv., Inc. v. United Gas Pipe

Line Co., 732 F.2d 452, 472 (5th Cir. 1984)); see also League of United Latin Am. Citizens, 

Council No. 4434 v. Clements, 884 F.2d 185, 189 (5th Cir. 1989).

Proposed 2023 Intervenors’ motion is timely and will not unduly delay or prejudice the 

existing parties. See Fed. R. Civ. P. 24(b)(1), (3); Cf. Students for Fair Admissions, Inc. v. Univ. 

of Texas at Austin, 338 F.R.D. 364, 372-73 (W.D. Tex. 2021) (“The analysis as to whether the 

intervention will cause undue delay or prejudice is essentially the same as the timeliness 

analysis.”). This case remains in the early stages and no dispositive motions have yet been filed. 

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Order, ECF 102 (ordering Plaintiffs to inform the Court of the likelihood of pursuing the instant 

action given that the case has been pending for a year and a half “and yet remains in the very 

preliminary stages”); see also Order 3, ECF 41 (permitting Defendant-Intervenors to intervene 

where “the case [was] in its infancy, the Court has not yet entered a scheduling order, and no 

dispositive motions have been filed”) The Court stayed and held in abeyance the deadline for 

responses to the Amended Complaint while the parties engage in jurisdictional discovery, with 

responses and objections set to be exchanged on September 15, 2023. Order, ECF 50; Order,

ECF 107; see also Texas v. U.S. Dep’t of Homeland Sec., No. 6:23-CV-00007, 2023 WL 

3025080, at *3 (S.D. Tex. Apr. 19, 2023) (“Texas II”) (Parole applicants who intervened while 

discovery was ongoing did not prejudice existing parties because “obtaining a more fulsome 

record . . . is in the interest of justice and poses no harm.”). Proposed 2023 Intervenors now 

move to intervene within days of Plaintiffs filing their supplemental complaint incorporating the 

Enhancements into their challenge. See Unopposed Mot. for Leave to File a Suppl. Compl., ECF 

108. Proposed 2023 Intervenors, who are represented by Defendant-Intervenors’ counsel, are 

prepared to diligently participate in the litigation and will not disrupt the existing schedule for 

further proceedings. 

Just as with the current Defendant-Intervenors, Proposed 2023 Intervenors’ defense of 

CAM and their ability to reunite with their children under the Enhancements shares common 

questions of law and fact with the existing challenge to CAM’s reopening. See id. at 3 (noting 

Plaintiffs’ Supplemental Complaint “addresses nearly identical legal and factual issues as the 

reinstituted CAM Program”). These questions include Plaintiff standing; the scope of 

Defendants’ statutory parole authority; whether CAM’s reopening—including the 

Enhancements—is final agency action; the relevance of Plaintiffs’ reliance interests; and whether 

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injunctive relief is appropriate. See Mot. to Intervene 15, ECF 19. Proposed 2023 Intervenors’

defenses also arise out of the same facts as the main action: the Biden Administration’s 

reopening of the CAM Program.

Last, Proposed 2023 Intervenors are individual parents who bring an important firsthand

perspective to developing the underlying factual issues of CAM’s reopening. Their direct 

experience applying to reunite with their children under the CAM Enhancements will aid the 

Court in its assessment of the underlying issues related to this phase of CAM’s reopening. See 

Order 3, ECF 41 (finding Defendant-Intervenors brought “a perspective that will contribute to 

full development of the underlying factual issues”); Texas II, 2023 WL 3025080 at *4 

(permitting individual parole applicants to intervene in a challenge to another parole program 

because they bring “important perspectives, substantial expertise, and experience that will aid the 

Court in its consideration of the issues”).

Proposed 2023 Intervenors’ perspective as newly eligible CAM parents is distinct from 

that of the current Defendant-Intervenors. While both share an interest in the continued 

availability of the CAM Program, Defendant-Intervenors’ interests are, or will soon become, 

more limited. Now that Defendant-Intervenor Timoteo’s daughter has traveled to the United 

States, his interest is in the remaining availability of CAM re-parole for individuals already in the 

United States, and Defendant-Intervenor Uzias’ interest may soon be similarly limited. Proposed 

2023 Intervenors bring an important perspective given that they have just learned of their 

eligibility for CAM, they have not been able to begin processing yet, and they will have an 

interest in the continuing availability of CAM for children in danger in Central America for the 

foreseeable future. 

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As is well documented, CAM processing can be a years-long process. See Meyer Decl., 

Ex. A, App’x at 85; Id., Ex. AA, App’x at 495. Newly eligible CAM applicants, such as 

Proposed 2023 Intervenors, who have not yet been able to file CAM cases or whose cases remain 

in early stages of in-country processing, can expect to wait many months, if not years, before 

receiving even an initial decision on their cases. Id. And if they are conditionally approved for 

parole then they will then be subject to even more time-intensive processing steps, such as 

medical exams and security checks. Meyer Decl., Ex. A, App’x at 106-07; Id., App’x at 496. In 

18 months, a new Administration may well opt to terminate the CAM Program yet again, 

including for pending cases, just as the Trump Administration did. While the current DefendantIntervenors already have or are likely to have the in-country processing of their cases completed 

by then, cases reopened under later stages such as the CAM Enhancements almost certainly will 

not. Proposed 2023 Intervenors are among those that will have a strong incentive to defend the 

continued operation of CAM processing in Central America, while the CAM families who have 

already been reunited in the United States will no longer have that same interest. 

Nor are the interests of the newly eligible Proposed 2023 Intervenors adequately 

represented by Federal Defendants, who must balance their defense of CAM with institutional 

interests in broad interpretations of executive authority. See Texas I, 805 F.3d at 663 

(recognizing differing interests of parent-beneficiaries and federal government in another 

immigration program context); Texas II, 2023 WL 3025080 at *4 (same in another parole 

context). Proposed 2023 Intervenors’ sole focus, on the other hand, is on their ability to reunite 

with their families through the CAM program. 

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CONCLUSION

In light of the foregoing, Proposed 2023 Intervenors respectfully request that the Court 

grant them intervention.

Dated: August 31, 2023 Respectfully submitted,

/s/ Debra J. McComas /s/ Kathryn C. Meyer

Debra J. McComas Kathryn C. Meyer 

NYS Bar #5504485 (pro hac vice)

HAYNES & BOONE LLP Linda B. Evarts 

NYS Bar #5236948 (pro hac vice)

State Bar No. 00794261 Mariko Hirose 

NYS Bar #4802674 (pro hac vice)

2323 Victory Ave., Suite 700 INTERNATIONAL REFUGEE 

Dallas, Texas 75219 ASSISTANCE PROJECT

Tel. (214) 651-5000 One Battery Park Plaza, 4th Floor

Fax (214) 651-5940 New York, NY 10004

debbie.mccomas@haynesboone.com Tel. (516) 838-1655

Fax: (929) 999-8115

kmeyer@refugeerights.org 

levarts@refugeerights.org

mhirose@refugeerights.org

Counsel for Proposed Defendant-Intervenors

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CERTIFICATE OF CONFERENCE

On August 29, 2023, counsel for Proposed 2023 Intervenors and Defendant-Intervenors

conferred with counsel for Plaintiffs and Defendants concerning this motion. The identities of the 

attorneys conferring were as follows: Ryan Walters for the Plaintiffs, Joseph Darrow for the 

Defendants, and Kathryn C. Meyer, for the Proposed 2023 Intervenors and DefendantIntervenors. Plaintiffs, Defendants, and Defendant-Intervenors do not object to Proposed 2023 

Intervenors’ permissive intervention motion. 

CERTIFICATE OF SERVICE

The undersigned certifies that on August 31, 2023, I electronically filed the foregoing 

document with the Clerk of Court for the U.S. District Court, Northern District of Texas, using 

the CM/ECF system. I hereby certify that I have served the documentation on all counsel by a 

manner authorized by Federal Rule of Civil Procedure 5(b)(2) via the Court’s CM/ECF filing 

system. 

/s/ Kathryn C. Meyer

Kathryn C. Meyer

Case 3:22-cv-00780-M Document 111 Filed 08/31/23 Page 17 of 17 PageID 1179