Pursuant to the Court’s April 15 & April 30 Orders, ECF Nos. 79 & 107, & Federal Rule of Civil Procedure 30(b)(6), Plaintiffs hereby move for leave to take three (3) additional depositions by oral examination of the U.S. Department of Homeland Security (DHS), the U.S. Department of State (DOS), & the U.S. Department of Justice (DOJ), through an officer, director, agent, or other representative from each Department who shall be designated to testify regarding all information known or reasonably available to the Departments with respect to the topics set forth in the Rule 30(b)(6) notices attached as Exhibits A–C hereto. The relief sought herein is needed to give effect to the Court’s Order granting expedited discovery. As the Court stated in that Order, “discovery is necessary in light of Defendants’ uniform refusal to disclose ‘what it can’ regarding their facilitation of Abrego Garcia’s release & return to the status quo ante.”
NEW: #KilmarAbregoGarcia's lawyers are asking Judge #Xinis to permit them to take 3 additional #depositions — from #State, #DHS, #DOJ. And they say that they might request a 4th deposition from the #Trump White House […]
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