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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

AMARILLO DIVISION

)

STATE OF TEXAS, )

)

Plaintiff, )

)

v. ) Civil Action No. 2:22-cv-00094-Z

)

ALEJANDRO MAYORKAS, )

in his official capacity as )

Secretary of Homeland Security, et al., )

)

Defendants. )

)

JOINT MOTION FOR CLARIFICATION OF ORDER CONCERNING PAGE LIMITS

The parties jointly request that the Court clarify its May 23 order (ECF 22) granting 

Plaintiff’s request for an enlargement of pages. In that order, the Court ruled that “[b]oth parties

may file briefs on Plaintiff’s Motion for a Preliminary Injunction not exceeding 45 pages including

the caption, tables, signature block, and certificate of service’ and that “Plaintiff may file a reply 

brief not to exceed 20 pages including same.”

The parties, however, had met and conferred and agreed to jointly request that both parties’

primary briefs be limited to 45 pages exclusive of captions, tables, signature block, etc., and that 

Plaintiff’s reply brief be limited to 20 pages, with the same limitation. Having conferred further, it 

appears that Plaintiff’s motion contained a typo, requesting “leave of Court to file a brief in excess 

of the page limit, not to exceed 45 pages, including the caption, tables, signature block, and

certificate of service.” ECF 19 at 1 (emphasis added). The proposed order submitted, however, 

provides that “it is ORDERED that Plaintiff’s Motion is Granted, and may file its Motion for 

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Preliminary Injunction, in excess of the page limit for non-dispositive motions and responses as 

set forth in the local rules but not to exceed 45 pages exclusive of the caption, tables, signature 

block and certificate of service.” ECF 19-1 at 1 (emphasis added).

The parties apologize to the Court for the error and jointly request that the Court clarify its 

order to provide both parties 45 pages exclusive of caption, tables, signature block, and certificates, 

see Local Rule 7.2(c) on their primary briefs, and Plaintiff 20 pages exclusive of the same on their 

reply brief. 

Dated: May 24, 2022 Respectfully submitted,

BRIAN M. BOYNTON

Principal Deputy Assistant Attorney General

WILLIAM C. PEACHEY 

Director

Office of Immigration Litigation 

District Court Section

/s/ Erez Reuveni

EREZ REUVENI

Assistant Director

U.S. Department of Justice

Civil Division, Office of Immigration 

Litigation

450 5th St NW

Washington, DC 20530

Tel: (202) 307-4293 

Email: erez.r.reuveni@usdoj.gov

BRIAN C. WARD

Senior Litigation Counsel

Counsel for Defendants

Case 2:22-cv-00094-Z Document 25 Filed 05/24/22 Page 2 of 5 PageID 581
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KEN PAXTON 

Attorney General of Texas 

BRENT WEBSTER 

First Assistant Attorney General 

OFFICE OF THE ATTORNEY GENERAL 

P.O. Box 12548 

Austin, Texas 78711-2548 

(512) 936-1700 

AARON F. REITZ 

Lead Counsel 

Deputy Attorney General for Legal Strategy 

Texas Bar No. 24105704 

aaron.reitz@oag.texas.gov 

LEIF A. OLSON 

Special Counsel 

Texas Bar No. 24032801 

leif.olson@oag.texas.gov 

GENE P. HAMILTON 

America First Legal Foundation 

300 Independence Avenue SE 

Washington, DC 20003 

(202) 964-3721 

gene.hamilton@aflegal.org 

Counsel for Plaintiff

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CERTIFICATE OF CONFERENCE

I hereby certify that on May 24, 2022, I conferred with counsel for Plaintiff about the 

relief requested in this motion. Plaintiff opposes this motion.

/s/ Erez Reuveni

EREZ REUVENI

U.S. Department of Justice

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CERTIFICATE OF SERVICE

I hereby certify that on May 24, 2022, I electronically filed this motion with the Clerk of 

the Court for the United States District Court for the Northern District of Texas by using the 

CM/ECF system. Counsel in the case are registered CM/ECF users and service will be 

accomplished by the CM/ECF system.

/s/ Erez Reuveni

EREZ REUVENI

U.S. Department of Justice

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