CCSF’s Supp. RJN ISO Opp. to Motion to Dismiss; 

CCSF v. President Trump, et al; Case No. 17-00485

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DENNIS J. HERRERA, State Bar #139669

City Attorney 

JESSE C. SMITH, State Bar #122517 Chief Assistant City Attorney 

RONALD P. FLYNN, State Bar #184186 Chief Deputy City Attorney 

YVONNE R. MERÉ, State Bar #173594

Chief of Complex and Affirmative Litigation 

CHRISTINE VAN AKEN, State Bar #241755 

TARA M. STEELEY, State Bar #231775

MOLLIE M. LEE, State Bar #251404 

SARA J. EISENBERG, State Bar #269303

MATTHEW S. LEE, State Bar #295247

NEHA GUPTA, State Bar #308864 

Deputy City Attorneys 

City Hall, Room 234 

1 Dr. Carlton B. Goodlett Place 

San Francisco, California 94102-4602 

Telephone: (415) 554-4748 

Facsimile: (415) 554-4715 

E-Mail: brittany.feitelberg@sfgov.org 

Attorneys for Plaintiff 

CITY AND COUNTY OF SAN FRANCISCO 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

CITY AND COUNTY OF SAN 

FRANCISCO, 

 Plaintiff, 

 vs. 

DONALD J. TRUMP, President of the United 

States, UNITED STATES OF AMERICA, 

JOHN F. KELLY, Secretary of United States 

Department of Homeland Security, 

JEFFERSON B. SESSIONS III, Attorney 

General of the United States, DOES 1-100, 

 Defendants. 

Case No. 3:17-cv-00485-WHO 

SUPPLEMENTAL REQUEST FOR JUDICIAL 

NOTICE IN SUPPORT OF PLAINTIFF CITY 

AND COUNTY OF SAN FRANCISCO’S 

OPPOSITION TO DEFENDANTS’ MOTION 

TO DISMISS 

Date: July 12, 2017 

Time: 2:00 p.m. 

Judge: Honorable William H. Orrick 

Dept: Courtroom 2 

Date Filed: January 31, 2017 

Trial Date: April 23, 2018 

Case 3:17-cv-00485-WHO Document 136 Filed 07/06/17 Page 1 of 4
 

CCSF’s Supp. RJN ISO Opp. to Motion to Dismiss; 

CCSF v. President Trump, et al; Case No. 17-00485

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REQUEST FOR JUDICIAL NOTICE

Plaintiff City and County of San Francisco hereby respectfully requests, pursuant to Federal 

Rule of Evidence 201, that this Court take judicial notice of the following material in support of its 

Opposition to Defendants’ Motion to Dismiss: 

1. Attached hereto as Exhibit A is a true and correct copy of Press Release No. 17-736 

issued by the Department of Justice, Office of Public Affairs titled “Department of Justice Reviewing 

Letters from Ten Potential Sanctuary Jurisdictions,” dated July 6, 2017. This document is available on 

the Department of Justice website at https://www.justice.gov/opa/pr/department-justice-reviewingletters-ten-potential-sanctuary-jurisdictions. 

Exhibit A is judicially noticeable because government memoranda, bulletins, reports, letters 

and statements are matters of public record appropriate for judicial notice. See Brown v. Valoff, 422 

F.3d 926, 933 n.9 (9th Cir. 2005) (judicially noticing an administrative bulletin). It is also judicially 

noticeable because it is posted to an official government website. See Daniels–Hall v. Nat’l Educ. 

Ass’n, 629 F.3d 992, 998–99 (9th Cir. 2010) (judicially noticing information contained on a 

government website); Paralyzed Veterans of America v. McPherson, No. C 06–4670 SBA, 2008 WL 

4183981, at *5 (N.D. Cal. Sept. 9, 2008) (finding that courts commonly take judicial notice of 

information and documents on government websites, and citing cases from various jurisdictions).

Dated: July 6, 2017 

DENNIS J. HERRERA 

City Attorney 

By: /s/ Mollie M. Lee 

MOLLIE M. LEE 

 Deputy City Attorney 

Attorneys for Plaintiff 

CITY AND COUNTY OF SAN FRANCISCO 

Case 3:17-cv-00485-WHO Document 136 Filed 07/06/17 Page 2 of 4
 

EXHIBIT A

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