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JAMIE S. GORELICK

jamie.gorelick@wilmerhale.com

CATHERINE M.A. CARROLL

catherine.carroll@wilmerhale.com

CLAIRE M. BERGERON

claire.bergeron@wilmerhale.com

SHEILA E. MENZ

sheila.menz@wilmerhale.com

WILMER CUTLER PICKERING

 HALE AND DORR LLP

1875 Pennsylvania Avenue, NW

Washington, D.C. 20006

Telephone: (202) 663-6500

Facsimile: (202) 663-6363

Attorneys for Amici Curiae

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

CITY AND COUNTY OF SAN FRANCISCO,

Plaintiff,

v.

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, Attorney General of the United States, 

DOES 1-100,

Defendants.

COUNTY OF SANTA CLARA,

Plaintiff,

v.

DONALD J. TRUMP, President of the United 

States of America, JOHN F. KELLY, in his official 

capacity as Secretary of the United States 

Department of Homeland Security, JEFFERSON B. 

SESSIONS, in his official capacity as Attorney 

General of the United States, JOHN MICHAEL 

“MICK” MULVANEY, in his official capacity as 

Director of the Office of Management and Budget, 

and DOES 1-50,

Defendants.

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

Case No. 3:17-cv-00574-WHO

MOTION FOR LEAVE TO FILE BRIEF 

AMICI CURIAE FOR TAHIRIH 

JUSTICE CENTER, ASIAN LAW 

ALLIANCE, ASIAN PACIFIC 

INSTITUTE ON GENDER BASED 

VIOLENCE, ASISTA, CASA DE 

ESPERANZA, DOLORES STREET 

COMMUNITY SERVICES, 

IMMIGRATION CENTER FOR WOMEN 

AND CHILDREN, MAITRI, AND 

PANGEA LEGAL SERVICES IN 

SUPPORT OF PLAINTIFFS’ MOTIONS 

FOR PRELIMINARY INJUNCTIONS;

[PROPOSED] ORDER

Judge: Hon. William H. Orrick 

Case 3:17-cv-00485-WHO Document 41 Filed 03/22/17 Page 1 of 6
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MOTION FOR LEAVE TO

FILE BRIEF AMICI CURIAE

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

Case No. 3:17-cv-00574-WHO

MOTION FOR LEAVE TO FILE BRIEF AMICI CURIAE

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE THAT the Tahirih Justice Center (“Tahirih”) and the other abovenamed amici hereby request permission to file the attached amicus brief in support of the Motions 

for Preliminary Injunctions in related actions filed by Plaintiffs the City and County of San 

Francisco (No. 3:17-cv-00485) and the County of Santa Clara (No. 3:17-cv-00574). Amici have 

conferred with counsel for the Plaintiffs and Defendants; Plaintiffs consent to the filing of this 

motion, and Defendants take no position. The proposed amicus brief is attached to this motion as 

Exhibit 1. A list of all amici appears in Appendix 1 to the brief. A proposed order is attached to this 

motion as Exhibit 2.

I. STANDARD FOR MOTION FOR LEAVE TO FILE BRIEF AMICI CURIAE

The District Court, in its discretion, may accept amicus curiae briefs “concerning legal issues 

that have potential ramifications beyond the parties directly involved, or if amici have unique 

information or perspective that can help the court beyond the help that the lawyers for the parties are 

able to provide.” NGV Gaming, Ltd. v. Upstream Point Molate, LLC, 355 F. Supp. 2d 1061, 1068 

(N.D. Cal. 2005) (citation and internal quotation marks omitted).

II. STATEMENT AND IDENTITY OF INTEREST OF AMICI CURIAE

Tahirih is the largest multi-city direct services and policy advocacy organization specializing 

in assisting immigrant women and girls who survive gender-based violence, including human 

trafficking, forced labor, domestic violence, rape and sexual assault, and female genital 

cutting/mutilation. Tahirih serves clients at four local offices, including in San Francisco, and to 

date, has provided free legal assistance to more than 20,000 individuals. The additional amici, Asian 

Law Alliance, Asian Pacific Institute on Gender-Based Violence, ASISTA, Casa de Esperanza, 

Dolores Street Community Services, Immigration Center for Women & Children, Maitri, and 

Pangea Legal Services, include immigration service providers that serve immigrant women survivors 

of gender-based crimes in San Francisco and Santa Clara County, as well as national policy 

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organizations that advocate for legal and other protections for survivors of gender-based crimes in 

the United States. Amici have a special understanding of the direct and severe impact that the 

Administration’s January 25, 2017 Executive Order, Enhancing Public Safety in the Interior of the 

United States, No. 13,768, 82 Fed. Reg. 8799 (the “Executive Order”), will have on immigrant 

survivors by limiting their access to protection from and treatment for the effects of gender-based 

violence.

III. AMICI’S PERSPECTIVE WILL BENEFIT THE COURT

Based on their extensive work with survivors of gender-based violence, amici have special 

insight into the Executive Order’s severely detrimental effect on immigrant women and girls in San 

Francisco, Santa Clara County, and nationally. For example, in the two months since the Executive 

Order was issued, the number of cases referred to Tahirih has tripled nationwide compared to the 

year before.1

 As service providers to immigrant women and national advocates on behalf of 

immigrant women, Tahirih and co-amici regularly engage with local law enforcement on a variety of 

efforts to assist survivors of domestic abuse in seeking protection and obtaining justice. Amici

therefore have firsthand knowledge of the Executive Order’s impact, which is already deterring 

immigrant women from reporting abuse for fear that they will be deported, and is leaving crime 

victims, local communities, and all Americans less safe.

IV. CONCLUSION

Accordingly, Tahirih Justice Center, et al., request leave to file the attached brief amici curiae

in both actions.

 1 Tyler Kingkade, Trump Deportation Vow Is Scaring Domestic Abuse Victims From Coming 

Forward, Buzzfeed News (Mar. 16, 2017), http://bzfd.it/2nNRX9L. 

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Dated: March 22, 2017

By: /s/ JAMIE S. GORELICK

JAMIE S. GORELICK

jamie.gorelick@wilmerhale.com

CATHERINE M.A. CARROLL

catherine.carroll@wilmerhale.com

CLAIRE M. BERGERON

laire.bergeron@wilmerhale.com

SHEILA E. MENZ

sheila.menz@wilmerhale.com

WILMER CUTLER PICKERING

 HALE AND DORR LLP

1875 Pennsylvania Avenue, NW

Washington, D.C. 20006

Telephone: (202) 663-6500

Facsimile: (202) 663-6363

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ATTORNEY ATTESTATION

I, Jamie S. Gorelick, am the ECF User whose ID and password are being used to file this 

Motion for Leave to File Brief Amici Curiae for Tahirih Justice Center, Asian Law Alliance, Asian 

Pacific Institute on Gender Based Violence, ASISTA, Casa de Esperanza, Dolores Street 

Community Services, Immigration Center for Women and Children, Maitri, and Pangea Legal 

Services in Support of Plaintiffs’ Motions for Preliminary Injunctions. In compliance with N.D. Cal. 

Civil L.R. 5-1(i)(3), I hereby attest that concurrence in the filing of the document has been obtained 

from each of the signatories.

By: /s/ JAMIE S. GORELICK

JAMIE S. GORELICK

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CERTIFICATE OF SERVICE

I hereby certify that on March 22, 2017, I electronically filed the above document with the 

Clerk of the Court using CM/ECF which will send electronic notification of such filing to all 

registered counsel.

By: /s/ JAMIE S. GORELICK

JAMIE S. GORELICK

Case 3:17-cv-00485-WHO Document 41 Filed 03/22/17 Page 6 of 6