1 

United States District Court 

Northern District of Texas 

Amarillo Division

State of Texas,

Plaintiff,

v. 

Alejandro Mayorkas, et al.;

Defendants.

Case 2:22-cv-00094-Z

AMENDED JOINTLY PROPOSED BRIEFING SCHEDULE

 The parties previously filed a Jointly Proposed Briefing Schedule on July 9, 2023 (ECF 

135). The Court has not entered a scheduling order to date. 

Defendants filed the certified administrative record (ECF 139, 140) on August 9, 2024. 

Because two attorneysfor Plaintiff have moved to withdraw from this case (ECF 142, 144) and two 

attorneys for Plaintiff have filed notices of appearance in this case since July 9 (ECF 143, 145), the

parties now wish to propose the following amended briefing schedule for the Court’s 

consideration.

1. Plaintiff will file its motion for summary judgment by October 18, 2024. 

2. Defendants will file their cross motion for summary judgment and opposition to Plaintiff’s 

motion for summary judgment by November 19, 2024. 

3. Plaintiff will file its opposition to Defendants’ motion for summary judgment and its reply 

in support of Plaintiff’s motion for summary judgment by December 16, 2024. 

4. Defendants will file their reply in support of Defendants’ motion for summary judgment 

by January 13, 2025. 

The motions for summary judgment will then stand fully submitted for the Court’s adjudication.

A proposed order reflecting this schedule is submitted herewith. 

Case 2:22-cv-00094-Z Document 146 Filed 08/22/24 Page 1 of 3 PageID 16788
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Dated: August 22, 2024 Respectfully submitted.

Gene P. Hamilton

America First Legal Foundation 

611 Pennsylvania Avenue SE, #231

Washington, DC 20003

(202) 964-3721

gene.hamilton@aflegal.org

James Rogers

Utah Bar No. 18783

America First Legal Foundation 

611 Pennsylvania Avenue SE, #231

Washington, DC 20003

(480) 570-4988

James.Rogers@aflegal.org

Ken Paxton

Attorney General 

Brent Webster

First Assistant Attorney General

Ralph Molina 

Deputy First Assistant Attorney General 

Austin Kinghorn

Deputy Attorney General for Legal Strategy 

Ryan Walters

Chief, Special Litigation Division

Texas Bar No. 254105085

/s/ David Bryant 

David Bryant 

Attorney-in Charge

Senior Special Counsel

Texas Bar No. 03281500

Munera Al-Fuhaid 

Special Counsel

Texas Bar No. 24094501

Office of the Attorney General

Special Litigation Division

P.O. Box 12548 

Austin, Texas 78711-2548

(512) 936-1700

David.Bryant@oag.texas.gov

Munera.Al-Fuhaid@oag.texas.gov

Counsel for the State of Texas

Case 2:22-cv-00094-Z Document 146 Filed 08/22/24 Page 2 of 3 PageID 16789
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BRIAN M. BOYNTON

Principal Deputy Assistant Attorney General

WILLIAM C. PEACHEY 

Director

Office of Immigration Litigation 

District Court Section 

EREZ REUVENI

Senior Counsel

BRIAN C. WARD

Senior Litigation Counsel

/s/ Joseph A. Darrow

JOSEPH A. DARROW

ERIN T. RYAN

ELISSA P. FUDIM

Trial Attorneys

U.S. Department of Justice 

Civil Division

Office of Immigration Litigation

District Court Section 

P.O. Box 868, Ben Franklin Station

Washington, DC 20044

Tel.: (202) 598-7537 

Joseph.a.darrow@usdoj.gov

ELIZABETH TULIS

Trial Attorney 

Federal Programs Branch

U.S. Department of Justice 

Counsel for Defendants

CERTIFICATE OF SERVICE

On August 22, 2024, I filed this document through the Court’s CM/ECF system, which 

automatically serves it upon all counsel of record. 

/s/ David Bryant

David Bryant

Case 2:22-cv-00094-Z Document 146 Filed 08/22/24 Page 3 of 3 PageID 16790