`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`
`A.A.R.P., et al.,
`
` Petitioners–Plaintiffs,
`
`v.
`
`DONALD J. TRUMP, in his official capacity as
`President of the United States, et al.,
`
` Respondents–Defendants.
`
`
` Case No. 1:25-cv-59-H
`
`
`
`
`
`UNOPPOSED MOTION FOR LEAVE TO FILE AMENDED CLASS PETITION FOR
`WRIT OF HABEAS CORPUS AND COMPLAINT FOR DECLARATORY AND
`INJUNCTIVE RELIEF AND AMENDED CLASS CERTIFICATION MOTION
`
`Plaintiffs-Petitioners (“Petitioners”) respectfully submit this motion to file an Amended
`
`
`
`
`
`
`
`
`Class Petition for Writ of Habeas Corpus and Complaint for Declaratory and Injunctive Relief
`
`and an amended class certification motion and accompanying memorandum of law. The
`
`proposed amended pleadings have been contemporaneously filed with this motion, as a proposed
`
`order. The government consents to filing amended versions of both pleadings. Pursuant to
`
`Federal Rule of Civil Procedure 15(a)(1)(A), Petitioners may file the amended pleadings as of
`
`right, and seek leave to do so if leave is necessary.
`
`
`
`Dated: April 18, 2025
`
`
`
`
`
`Lee Gelernt*
`Daniel Galindo*
`Ashley Gorski*
`Patrick Toomey*
`Sidra Mahfooz*
`Omar Jadwat*
`
`Respectfully submitted,
`
`/s/Brian Klosterboer
`Brian Klosterboer
`Tx Bar No. 24107833
`Thomas Buser-Clancy*
`TX Bar No. 24078344
`Savannah Kumar*
`TX Bar No. 24120098
`Charelle Lett*
`
`
`
`Case 1:25-cv-00059-H Document 35 Filed 04/18/25 Page 2 of 2 PageID 276
`
`Hina Shamsi*
`AMERICAN CIVIL LIBERTIES UNION
`FOUNDATION
`125 Broad Street, 18th Floor
`New York, NY 10004
`T: (212) 549-2660
`E: lgelernt@aclu.org
`E: dgalindo@aclu.org
`E: agorski@aclu.org
`E: ptoomey@aclu.org
`E: smahfooz@aclu.org
`E: ojadwat@aclu.org
`E: hshamsi@aclu.org
`
`Noelle Smith*
`Oscar Sarabia Roman*
`My Khanh Ngo*
`Cody Wofsy*
`AMERICAN CIVIL LIBERTIES UNION
`FOUNDATION
`425 California Street, Suite 700
`San Francisco, CA 94104
`T: (415) 343-0770
`E: nsmith@aclu.org
`E: osarabia@aclu.org
`E: mngo@aclu.org
`E: cwofsy@aclu.org
`
`
`
`
`
`
`TX Bar No. 24138899
`Ashley Harris*
`TX Bar No. 24123238
`Adriana Piñon*
`TX Bar No. 24089768
`Adriana Piñon*
`TX Bar No. 24089768
`ACLU FOUNDATION OF TEXAS,
`INC.
`1018 Preston St.
`Houston, TX 77002
`(713) 942-8146
`bklosterboer@aclutx.org
`tbuser-clancy@aclutx.org
`skumar@aclutx.org
`clett@aclutx.org
`aharris@aclutx.org
`apinon@aclutx.org
`
`
`
`Attorneys for Petitioners-Plaintiffs
`*Pro hac vice applications
`forthcoming
`
`
`
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