Civil Action No. 00-0723 (JR) (D.D.C. Jul. 26, 2001) Cited 6 times
Finding that, while it appeared that litigation over INS's decision to return Elian Gonzalez to Mexico was "likely," it was not so obvious that the district court could simply take judicial notice of it and a "barebones, conclusory" declaration did not establish that litigation was inevitable