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`ORAL ARGUMENT SCHEDULED FOR NOVEMBER 3, 2021
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`No. 21-5028
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`In the
`United States Court of Appeals
`for the
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`District of Columbia Circuit
`______________________________
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`WASHINGTON ASSOCIATION OF TECHNOLOGY WORKERS,
`Plaintiff-Appellant,
`– v. –
`U.S. DEPARTMENT OF HOMELAND SECURITY,
`Defendant-Appellee,
`NATIONAL ASSOCIATION OF MANUFACTURERS, et al.,
`Intervenors-Appellees.
`______________________________
`
`On appeal from a final judgment of the
`United States District Court for the District of Columbia
`No. 16-cv-01170
`Hon. Reggie B. Walton
`______________________________
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`MOTION TO DIVIDE ORAL ARGUMENT TIME
`______________________________
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`Appellees the National Association of Manufacturers, the Chamber of
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`Commerce of the United States of America, and the Information Technology
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`Industry Council (the Association Appellees) respectfully request that the
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`Court divide the oral argument time currently allotted to all Appellees in
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`USCA Case #21-5028 Document #1918950 Filed: 10/20/2021 Page 2 of 5
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`this case, so that they and the government may argue separately. The gov-
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`ernment consents to divided argument.
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`1. On August 24, 2021, the Court originally scheduled oral argu-
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`ment in this case for October 18, 2021. On unopposed motion of the Associ-
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`ation Appellees, the Court rescheduled oral argument for November 3, 2021,
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`so that undersigned counsel (who had a conflict with another oral argument
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`on October 18), could participate in the argument. Doc. 1911837, at 1; see
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`generally Doc. 1911396 (motion).
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`2. Yesterday, the Court issued an order allocating argument time,
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`with 15 minutes allocated to Appellees as a whole, and “[o]ne counsel per
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`side to argue.” Doc. 1918824, at 1.
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`3. On the understanding that the current order does not permit
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`them to argue separately from the government, the Association Appellees
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`therefore respectfully request divided argument in this case.
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`4. Specifically, the Association Appellees and the government have
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`agreed to the following division of their collective 15-minute argument time.
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`Government Appellees: 10 minutes
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`Association Appellees:
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`5 minutes
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`For the foregoing reasons, the Association Appellees respectfully re-
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`quest that the Court permit divided argument in this case.
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`USCA Case #21-5028 Document #1918950 Filed: 10/20/2021 Page 3 of 5
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`Dated: October 20, 2021
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`Respectfully submitted,
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`/s/ Paul W. Hughes
`Paul W. Hughes
`MCDERMOTT WILL & EMERY LLP
`500 North Capitol Street NW
`Washington, DC 20006
`(202) 756-8000
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`Counsel for Intervenors-
`Appellees
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`USCA Case #21-5028 Document #1918950 Filed: 10/20/2021 Page 4 of 5
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`CERTIFICATE OF COMPLIANCE
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`Pursuant to Federal Rule of Appellate Procedure 32(g), the under-
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`signed counsel for intervenor certifies that this motion:
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`(i)
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`complies with the type-volume limitation of Rule 27(d)(2)(A)
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`because it contains 225 words, including footnotes and excluding the
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`parts of the motion exempted by Rule 32(f) and Circuit Rule 32(e)(1); and
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`(ii) complies with the typeface requirements of Rule 32(a)(5) and
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`the type style requirements of Rule 32(a)(6) because it has been prepared
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`using Microsoft Office Word 2016 and is set in New Century Schoolbook
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`font in a size equivalent to 14 points or larger.
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`/s/ Paul W. Hughes
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`Dated: October 20, 2021
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`USCA Case #21-5028 Document #1918950 Filed: 10/20/2021 Page 5 of 5
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`CERTIFICATE OF SERVICE
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`I hereby certify that that on October 20, 2021, I filed the foregoing
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`motion via the Court’s CM/ECF system, which effected service on all reg-
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`istered parties to this case.
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`Dated: October 20, 2021
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`/s/ Paul W. Hughes
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