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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.
`______________________________
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`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 RESCHEDULE ORAL ARGUMENT
`______________________________
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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 respectfully request rescheduling of oral argument in this
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`case, which the Court today scheduled for Monday, October 18, 2021.
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`USCA Case #21-5028 Document #1911396 Filed: 08/24/2021 Page 2 of 5
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`1. Undersigned counsel, who is responsible for argument in this
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`matter, is currently scheduled to present oral argument in the U.S. Court
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`of Appeals for the Ninth Circuit that same day, October 18, 2021. See Amer-
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`ican Claims Management v. Allied World Surplus Lines, No. 20-56055 (9th
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`Cir.).
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`2. Undersigned counsel will also present oral argument in this
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`Court on October 21, 2021, in Belmont Municipal Light Dep’t v. FERC, No.
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`19-1224. Counsel represents intervenor New England Power Generators
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`Association in that matter. FERC has agreed to share argument time with
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`counsel’s client, and an appropriate motion is forthcoming.
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`3.
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`In view of these earlier-scheduled arguments in the Ninth Cir-
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`cuit and this Court, undersigned counsel respectfully requests that the
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`Court reschedule oral argument in this matter. (For completeness, counsel
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`has separate arguments scheduled on September 10 and October 4, but no
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`other arguments yet scheduled for this calendar year).
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`4. Counsel for both appellant and appellee the Department of
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`Homeland Security have consented to the relief sought in this motion.
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`For the foregoing reasons, defendant respectfully requests that the
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`Court reschedule oral argument in this case.
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`USCA Case #21-5028 Document #1911396 Filed: 08/24/2021 Page 3 of 5
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`Dated: August 24, 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 #1911396 Filed: 08/24/2021 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 226 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: August 24, 2021
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`USCA Case #21-5028 Document #1911396 Filed: 08/24/2021 Page 5 of 5
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`CERTIFICATE OF SERVICE
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`I hereby certify that that on August 24, 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: August 24, 2021
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`/s/ Paul W. Hughes
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