AG Paxton reply brief to intervening motion to dismiss case

I could only find a few scattered screenshots on Twitter. I can't find the full text.

It was filed yesterday, on August 7th.

TL.DR – Paxton is begging the court not to dismiss the case before Sept. 5th in order to give Trump a chance to rescind DACA.

Note to admin: please feel free to resize the images.

Will be following this closely, thanks for posting

Paxton knows The admin will end DACA on Sept 5th

Why' would trump end the program on the exact day they will amend the lawsuit?

Can someone who understands this explain a little? Why is he "begging", as OP stated, the court not to dismiss the case?

My initial feeling was that this lawsuit was going to be dismissed. DACA is constitutional. DAPA was blocked by the same judge not on it's constitutionality but on other grounds.

do you remember what ground it was?

can't they just submit a new lawsuit even if it's dismissed? Will it end up at the same circuit court?

It was blocked because of the Administrative Procedure Act.

Generally, when the executive branch seeks to issue a new regulation, it must first give notice to the public and an opportunity for people to comment on it.

DHS did not give notice and ask for comment before issuing DAPA, which was the reason judge Hanen blocked DAPA. He did not rule on the constitutional arguments.

So it could be argued that since DACA has been around for 5 years, it can't be ruled on grounds of APA? Am I understanding this correctly?