NAJAFI V. POMPEO (CAND CASE # 4:19-cv-05782)

In Najafi v. Pompeo, Iranian American families are challenging the U.S. Government’s designation of the authority and discretion to approve case-by-case waivers to individual consular officers to consular managers, visa chiefs, consular section chiefs, consular management, the Visa Office, and Quality Support, Inc. contractors, which is unlawful under Presidential Proclamation 9645, §3(C) ("PP 9645"). 

Plaintiffs in this action are U.S. citizens, Legal Permanent Residents, and their Iranian national immediate relatives who are immigrant visa applicants that have been denied timely adjudication of case-by-case PP 9645 waivers as a result of the State Department's usurpation of consular officer authority and discretion.

The Iranian American families are represented by Curtis Lee Morrison through:

The Law Office of Rafael Ureña

925 N La Brea Ave, 4th Floor

Los Angeles, CA 90038

ru@urenaesq.com

(917) 204-0670

For a free consult, reach Curtis Morrison:

email: curtis@curtismorrisonlaw.com

whatsapp/telegram: @curtisatlaw or +1 714-661-3446

FEBRUARY 17, 2021 STIPULATION OF DISMISSAL WITH PREJUDICE PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 41(a)(1)

FEBRUARY 4, 2021 JOINT STATUS REPORT REGARDING EFFECT OF REVOCATION OF PP 9645 BY JANUARY 20, 2021 PRESIDENTIAL PROCLAMATION

JANUARY 27, 2021   ORDER GRANTING DEFENDANTS’ MOTION FOR PROTECTIVE ORDER 

JANUARY 21, 2021 DEFENDANTS' AMENDED ANSWER 

JANUARY 21, 2021 ORDER CONTINUING MOTION HEARING; REQUIRING JOINT STATUS REPORT

JANUARY 11, 2021  DEFENDANTS’ REPLY MEMORANDUM IN

SUPPORT OF MOTION TO DISMISS; MOTION TO STAY

JANUARY 8, 2021 GOVERNMENT RECORDS DECLARATION 

JANUARY 8, 2021  DEFENDANTS’ NOTICE OF FILING OF PART

ONE OF CERTIFIED ADMINISTRATIVE RECORD

JANUARY 7, 2021  ORDER DENYING PLAINTIFF'S MOTION TO STRIKE

DECEMBER 28, 2020 PLAINTIFFS’ OPPOSITION TO BOTH DEFENDANTS’

(FOURTH) MOTION TO DISMISS AND MOTION TO STAY

DECEMBER 21, 2020 ORDER CORRECTING HEARING DATE 

DECEMBER 18, 2020   DEFENDANTS’ NOTICE OF MOTION AND MOTION TO DISMISS; MOTION TO STAY 

DECEMBER 16, 2020  ORDER VACATING HEARING 

DECEMBER 7, 2020 CLERKS NOTICE SETTING ZOOM HEARING

DECEMBER 1, 2020 JOINT INITIAL CASE MANAGEMENT STATEMENT

NOVEMBER 18, 2020  DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION UNDER F.R.C.P. 12(f)

NOVEMBER 5, 2020   MOTION HEARING SET FOR 12/17/2020

NOVEMBER 5, 2020  RE-NOTICE OF MOTION UNDER v. F.R.C.P. 12(f) 

NOVEMBER 5, 2020 CLERK'S NOTICE : HEARING DATE VACATED 

NOVEMBER 4, 2020   NOTICE OF MOTION AND MOTION UNDER F.R.C.P. 12(f) AND MEMORDANDUM IN SUPPORT 

OCTOBER 14, 2020  ANSWER TO FIRST AMENDED COMPLAINT
 

SEPTEMBER 28, 2020 STIPULATION TO ENLARGEN TIME DEADLINE

SEPTEMBER 28, 2020  STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES

SEPTEMBER 14, 2020 ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS' MOTION TO DISMISS

JUNE 11, 2020 ORDER VACATING JUNE 18TH HEARING

MAY 9, 2020 PLAINTIFFS' OPPOSITION TO DEFENDANT'S  MOTION TO DISMISS PLAINTIFFS' FIRST AMENDED COMPLAINT

MAY 1, 2020 DEFENDANTS' MOTION TO DISMISS PLAINTIFFS' FIRST AMENDED COMPLAINT

MAR. 26, 2020 PLAINTIFFS' AMENDED COMPLAINT WITH EXHIBITS A-E

MAR. 5, 2020 ORDER GRANTING GOVERNMENT'S SECOND MOTION TO DISMISS, GIVING PLAINTIFFS LEAVE TO AMEND COMPLAINT WITHIN 30 DAYS

FEB. 14, 2020 COURT'S RESCHEDULING OF HEARING ON GOVERNMENT'S MOTION TO DISMISS

FEB. 9, 2020 PLAINTIFFS' THIRD NOTICE OF SUPPLEMENTAL AUTHORITY

FEB. 6, 2020 GOVERNMENT'S REPLY IS SUPPORT OF SECOND MOTION TO DISMISS 

JAN. 30, 2020 PLAINTIFFS' NOTICE OF SUPPLEMENTAL AUTHORITY  (Motaghedi v Pompeo  ORDER)

JAN. 27, 2020 CERTIFIED TRANSCRIPT FROM DEC. 3, 2019 HEARING

JAN. 27, 2020 PLAINTIFFS' OPPOSITION TO DEFENDANTS SECOND MOTION TO. DISMISS

JAN. 17, ORDER REGARDING DISCOVERY LETTER; DENYING REQUEST FOR RULE 26(F) CONFERENCE

JAN. 16, 2020 GOVERNMENT'S SECOND MOTION TO DISMISS

JAN. 7, 2020 DEFENDANTS' OPPOSITION TO RULE 26(f) CONFERENCE, ARGUING distress over what will happen to family members in Iran given recent U.S. military action – does not justify dispensing with the judicial efficiencies that would come with deferring a Rule 26(f) conference until after resolution of the motion to dismiss." 

JAN. 3, 2020 PLAINTIFFS' REQUEST FOR RULE 26(f) CONFERENCE

DEC. 11, 2019 FIVE MORE FAMILIES/COUPLES DISMISS THEIR CLAIMS AFTER ISSUANCES OF VISAS 

DEC. 5, 2019 ORDER DENYING PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION; TERMINATING GOVERNMENTS' MOTION TO DISMISS

DEC. 3, 2019 GOVERNMENT'S OPPOSITION TO PLAINTIFFS' SUBMISSION OF JOEL NANTAIS DECLARATION

DEC. 2, 2019 PLAINTIFFS ASK COURT TO CONSIDER DECLARATION OF JOEL NANTAIS

NOV. 27, 2019 PARTIES' JOINT LETTER RE: DISCOVERY DISPUTE OVER DEFENDANTS' RESPONSES TO PLAINTIFFS' INTERROGATORIES

NOV. 22, 2019 ORDER GRANTING PLAINTIFFS' APPLICATION TO SUBMIT SUPPLEMENTAL EVIDENCE IN SUPPORT OF PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION (RELATED TO IRAN INTERNET OUTAGES)

NOV. 19, 2019 GOVERNMENT DEFENDANTS' MOTION TO DISMISS

NOV. 19, 2019 PLAINTIFFS' UNOPPOSED EX PARTE APPLICATION FOR LEAVE TO FILE SUPPLEMENTAL EVIDENCE IN SUPPORT OF PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION 

NOV. 14, 2019 PLAINTIFFS' REPLY BRIEF IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION

NOV. 13, 2019 FIVE FAMILIES/COUPLES DISMISS THEIR CLAIMS AFTER ISSUANCES OF VISAS 

NOV. 9, 2019 GOVERNMENT DEFENDANTS' OBJECTIONS TO PLAINTIFFS’ EMERGENCY EX PARTE APPLICATION TO MOTION TO COMPEL RESPONSES TO INTERROGATORIES

NOV. 9, 2019  PLAINTIFFS’ EMERGENCY EX PARTE APPLICATION TO COMPEL RESPONSES TO INTERROGATORIES 

NOV. 8, 2019 DEFENDANTS' OPPOSITION TO PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION

OCT. 23, 2019 ORDER GRANTING EX PARTE APPLICATION FOR EXPEDITED DISCOVERY

OCT. 18, 2019 PLAINTIFFS' REPLY TO GOVT'S OPPOSITION TO PLAINTIFFS' MOTION FOR EXPEDITED DISCOVERY

OCT. 17, 2019 GOVERNMENT'S OPPOSITION TO PLAINTIFFS' MOTION FOR EXPEDITED DISCOVERY

OCT. 11, 2019 ORDER SETTING BRIEFING SCHEDULE FOR PLAINTIFFS' PRELIMINARY INJUNCTION MOTION, RESCHEDULING HEARING FOR DEC. 5, 2019, AND DIRECTING PARTIES TO MEET AND CONFER ON PLAINTIFFS' MOTION FOR EXPEDITED DISCOVERY

OCT. 10, 2019 DEFENDANTS CONSENT TO JURISDICTION OF MAGISTRATE JUDGE KANDIS A. WESTMORE

OCT. 10, 2019 ALL PARTIES STIPULATE TO BRIEFING SCHEDULE ON PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION.

OCT. 8, 2019 KENNETH W. BRAKEBILL, ASSISTANT U.S. ATTORNEY, ENTERS APPEARANCE AS COUNSEL FOR GOVERNMENT DEFENDANTS

OCT. 2, 2019 PLAINTIFFS' EX PARTE APPLICATION FOR EXPEDITED DISCOVERY 

SEPT. 30, 2019 PLAINTIFFS' RE-NOTICE FOR PRELIMINARY INJUNCTION HEARING (ADJUSTING HEARING DATE TO NOV. 7, 2019)

SEPT. 26, 2019 PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION AND MEMO IN SUPPORT

SEPT. 26, 2019 PLAINTIFFS' CONSENT TO MAGISTRATE JUDGE'S AUTHORITY

SEPT. 16, 2019 CASE ASSIGNED TO MAGISTRATE JUDGE KANDIS A. WESTMORE.

SEPT. 15, 2019, COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF AND FOR WRIT OF MANDAMUS.

JUNE 11, 2020 INSIDER: 'I'm dying slowly': An Iranian teen says she has to travel from country to country or be sent back to her abusive father

APRIL 29, 2020  The Intercept: First the Muslim Ban, now coronavirus - Iranian families separated by one Trump order after another

MAR. 6, 2020 LAW360: Calif. Judge Finds No Delays In Travel Ban Waiver Processing

NOV. 9, 2019 San Francisco Chronicle: Iranian families separated by Trump travel ban sue over waiver delays

OCT. 25, 2019 LAW360: State Dept. Given 14 Days To Share Travel Ban Waiver Info

SEPT. 24, 2019 LAW360: State Dept. Says New System Has Cut Travel Ban Waiver Wait