https://www.courtlistener.com/docket/69741724/19/jgg-v-trump/
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
J.G.G., et al., Civil Action No. 1:25-cv-00766
Plaintiffs-Petitioners,
v.
DONALD J. TRUMP, in his official
capacity as President of the United States,
et al.,
Defendants-Respondents.
NOTICE TO THE COURT
For the reasons explained on the record, Federal Defendants object to this Court’s assertion
of jurisdiction, including over the President’s exercise of powers vested in him by Article
II. Subject to that objection, Federal Defendants were promptly notified of the Court’s temporary
restraining order issued in the morning and the 7:26 PM EDT minute order that temporarily
enjoined any removals pursuant to the Presidential Proclamation. Federal Defendants have sought
emergency appellate relief from the D.C. Circuit as to both orders; the Court of Appeals has now
ordered expedited briefing on both motions.
The five individual Plaintiffs that were the subject of
the first TRO have not been removed.
Going forward, and in the absence of appellate relief, Federal Defendants will continue to
protect the United States using authorities other than the Proclamation. Federal Defendants further
report, based on information from the Department of Homeland Security, that some gang members
subject to removal under the Proclamation had already been removed from United States territory
under the Proclamation before the issuance of this Court’s second order.
Respectfully Submitted,
PAMELA J. BONDI
U.S. Attorney General
TODD BLANCHE
Deputy Attorney General
EMIL BOVE
Principal Associate Deputy
Attorney General
CHAD MIZELLE
Acting Associate Attorney General
YAAKOV M. ROTH
Acting Assistant Attorney General
s/ Drew C. Ensign
DREW C. ENSIGN
Deputy Assistant Attorney General
950 Pennsylvania Avenue
Washington, DC 20530
Phone: (202) 514-2000
e-Mail: drew.c.ensign@usdoj.gov
AUGUST E. FLENTJE
Acting Director
EREZ REUVENI
Assistant Director
BRIAN C. WARD
Acting Assistant Director
CHRISTINA P. GREER
Senior Litigation Counsel
PATRICK GLEN
Senior Litigation Counsel
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