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Last night, our amazing Attorney, Ana Toledo, filed an important and historic Motion in the 5th Circuit (New Orleans).
Case Number 23-20342
We will be posting it soon. Stay tuned!
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STATEMENT REGARDING ORAL ARGUMENT
Due to the unprecedented and momentous issues this case presents, Plaintiffs-
Appellants requests the Court grant an oral argument and it be held en banc. Never has a Court of Appeals adjudicated the controversies this appeal presents.
The lives of hundreds of thousands of Americans, coupled with the safety and protection of the Court’s Honorable Judges called to defend the U.S. Constitution justifies an en banc oral argument.
Plaintiffs-Appellants posit that the volume of the pleadings, motions and
important matters at stake render an oral argument beneficial for the Court’s consideration of the complex factual background and important constitutional issues in this case.
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Plaintiffs-Appellants particularly request oral argument on the following
grounds:
1. This appeal presents the novel question of whether the practice of
including in the Terrorist Screening Database (“TSDB”) the names of
innocent Americans such as Plaintiffs-Appellants that Defendant-
Appellees admit do not constitute a terrorist threat, represents ultra vires,
unconstitutional exercise of government power that interferes with
Americans’ basic liberty and property rights.
2. Whether it constitutes a violation of the Constitution of the United States
and the Privacy Act, Privacy Act, 5 USC § 552(a)(4)(B), the practice of
Case: 23-20342 Document: 16 Page: 12 Date Filed: 09/05/2023XIII
disseminating to at least 18,000 law-enforcement, 1441 organizations, 533
corporations, and 60 countries, a terrorist database, labeling innocent
Americans --including toddlers-- as suspected terrorists, even though
Defendants-Appellants acknowledge they do not represent a terrorist
threat.
3. Whether the district court erred in refusing to issue a Preliminary and
Permanent Injunction despite Plaintiffs-Appellants’ likeliness of success
on the merits as well as Defendants-Appellees’ failure to set forth any
government injury that would result from removing the names of innocent
Americans improperly included in the TSDB.
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Given the urgency of the irreparable damages that Plaintiffs-Appellants and
TJ Members continue to endure, an en banc oral argument will allow the parties to assist the Court in the statutory and factual analysis required to resolve the appeal in the most thorough and expeditious manner pursuant to Supreme Court and Fifth Circuit precedent.
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Watch for Len Ber’s podcast coming Sunday - to get the full details.
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P.S. - “ultra vires” means, “beyond their legal authority.”
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