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handle is hein.preview/suppwkht0001 and id is 1 raw text is: KIRKLAND & ELLIS LLP AND AFFILIATED PARTNERSHIPS 1301 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Paul D. Clement United States To Call Writer Directly: Facsimile: +1 202 389 5000 +1 202 389 5000 +1 202 389 5200 paul.clement@kirkland.com www.kirkland.com April 19, 2019 Hand Delivery and Electronic Filing Scott S. Harris Clerk of the Court Supreme Court of the United States One First Street, NW Washington, DC 20543-0001 Re: New York State Rifle & Pistol Ass'n v. City of New York, No. 18-280 Dear Mr. Harris: I represent petitioners in the above-captioned matter. I write in response to respondents' April 12, 2019 letter making the unusual request that the Court stay the briefing in this case pending the outcome of an administrative rulemaking proceeding that was only recently initiated in response to this Court's grant of certiorari. A stay is neither necessary nor appropriate. This litigation has been ongoing for more than six years. Throughout those six years, respondents have vigorously defended the City's novel handgun transport ban, which prohibits law-abiding New Yorkers from taking their licensed handguns anywhere-including any legal destination outside of the state of New York-other than the meager seven authorized shooting ranges within the limits of the 8.5-million-person city. See 38 R.C.N.Y. §5-23(a). In the courts below, respondents denied that the City's ban even implicates the Second Amendment, while simultaneously arguing that it is necessary to protect public safety. And, to date, respondents have succeeded not only in defending the City's ban, but in procuring a precedential decision upholding the ban and minimizing Second Amendment protections within the entire Second Circuit. Even now, respondents insist that the transport ban promotes public safety, but in a nakedly transparent effort to evade this Court's review, respondents have commenced an administrative rulemaking to reconsider the ban. Although that process was only recently initiated, and respondents have not yet received any of the public comments they have solicited, respondents make the extraordinary request that this Court stay any further briefing in this case. That request is radically premature and should be denied in all events. Respondents ask this Court to put this case on indefinite hold merely because the New York City Police Department has initiated a rulemaking process involving proposed amendments Beijing Boston Chicago Dallas Hong Kong Houston London Los Angeles Munich New York Palo Alto San Francisco Shanghai

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