Case 1:11-cv-02074-BAH Document 16-1 Filed 01/23/12 Page 1 of 11 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA SHARIF MOBLEY, et al., * * Plaintiffs, * * v. * * Civil Action No. 1:11-cv-02074 (BAH) DEPARTMENT OF HOMELAND * SECURITY, * * Defendant. * * * * * * * * * * * * * * * MOTION FOR A PRELIMINARY INJUNCTION Plaintiffs respectfully move the Court for a preliminary injunction enjoining Defendant Department of Homeland Security from refusing to process Plaintiffs’ FOIA/PA Request No. DHS/OS/PRIV 11-1218 under the Privacy Act. In support of this Motion, the Court is respectfully referred to Plaintiffs’ Memorandum of Points and Authorities in Support of Plaintiffs’ Motion for a Preliminary Injunction. A proposed Order consistent with the relief sought also accompanies this Motion. Case 1:11-cv-02074-BAH Document 16-1 Filed 01/23/12 Page 2 of 11 Date: January 23, 2012 Respectfully submitted, __/s/ Kelly B. McClanahan_ Kelly B. McClanahan, Esq. D.C. Bar #984704 National Security Counselors 1200 South Courthouse Road Suite 124 Arlington, VA 22204 301-728-5908 240-681-2189 fax
[email protected] Counsel for Plaintiffs 2 Case 1:11-cv-02074-BAH Document 16-1 Filed 01/23/12 Page 3 of 11 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA SHARIF MOBLEY, et al., * * Plaintiffs, * * v. * * Civil Action No. 1:11-cv-02074 (BAH) DEPARTMENT OF HOMELAND * SECURITY, * * Defendant. * * * * * * * * * * * * * * * PLAINTIFFS’ STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE Pursuant to Local Rule 65.1(d), Plaintiffs submit this statement of material facts as to which there is no genuine issue: 1.