State of Hawaii v. Trump

Filing 253

Declaration re 252 Reply to Response to Motion, Supplemental Declaration of Neal K. Katyal. (Attachments: # 1 Exhibit D (DHS Fact Sheet), # 2 Exhibit E (DHS Q&A), # 3 Exhibit F (N.Y. Times Article), # 4 Certificate of Service)(Katyal, Neal)

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DOUGLAS S. CHIN (Bar No. 6465) Attorney General of the State of Hawai‘i DEPARTMENT OF THE ATTORNEY GENERAL, STATE OF HAWAI‘I 425 Queen Street Honolulu, HI 96813 Telephone: (808) 586-1500 Fax: (808) 586-1239 Attorneys for Plaintiff, State of Hawai‘i NEAL K. KATYAL* HOGAN LOVELLS US LLP 555 Thirteenth Street NW Washington, DC 20004 Telephone: (202) 637-5600 Fax: (202) 637-5910 *Admitted Pro Hac Vice Attorneys for Plaintiffs, State of Hawai‘i and Ismail Elshikh (See Next Page For Additional Counsel) IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAI‘I STATE OF HAWAI‘I and ISMAIL ELSHIKH, Plaintiffs, v. DONALD J. TRUMP, in his official capacity as President of the United States; U.S. DEPARTMENT OF HOMELAND SECURITY; JOHN F. KELLY, in his official capacity as Secretary of Homeland Security; U.S. DEPARTMENT OF STATE; REX TILLERSON, in his official capacity as Secretary of State; and the UNITED STATES OF AMERICA, Defendants. \\DC - 069620/000007 - 10182408 v1 Civil Action No. 1:17-cv-00050DKW-KSC SUPPLEMENTAL DECLARATION OF NEAL K. KATYAL IN SUPPORT OF PLAINTIFFS’ MOTION TO CONVERT TEMPORARY RESTRAINING ORDER TO A PRELIMINARY INJUNCTION; EXHIBITS D, E, AND F IN SUPPORT OF PLAINTIFFS’ MOTION TO CONVERT TEMPORARY RESTRAINING ORDER TO A PRELIMINARY INJUNCTION; CERTIFICATE OF SERVICE ADDITIONAL COUNSEL CLYDE J. WADSWORTH (Bar No. 8495) Solicitor General of the State of Hawai‘i DEIRDRE MARIE-IHA (Bar No. 7923) DONNA H. KALAMA (Bar No. 6051) KIMBERLY T. GUIDRY (Bar No. 7813) ROBERT T. NAKATSUJI (Bar No. 6743) Deputy Attorneys General DEPARTMENT OF THE ATTORNEY GENERAL, STATE OF HAWAI‘I 425 Queen Street Honolulu, HI 96813 Telephone: (808) 586-1500 Fax: (808) 586-1239 Email: deirdre.marie-iha@hawaii.gov Attorneys for Plaintiff, State of Hawai‘i COLLEEN ROH SINZDAK* MITCHELL P. REICH* ELIZABETH HAGERTY* HOGAN LOVELLS US LLP 555 Thirteenth Street NW Washington, DC 20004 Telephone: (202) 637-5600 Fax: (202) 637-5910 Email: neal.katyal@hoganlovells.com THOMAS P. SCHMIDT* HOGAN LOVELLS US LLP 875 Third Avenue New York, NY 10022 Telephone: (212) 918-3000 Fax: (212) 918-3100 SARA SOLOW* ALEXANDER B. BOWERMAN* HOGAN LOVELLS US LLP 1835 Market St., 29th Floor Philadelphia, PA 19103 Telephone: (267) 675-4600 Fax: (267) 675-4601 *Admitted Pro Hac Vice Attorneys for Plaintiffs, State of Hawai‘i and Ismail Elshikh 2 SUPPLEMENTAL DECLARATION OF NEAL K. KATYAL IN SUPPORT OF PLAINTIFFS’ MOTION TO CONVERT TEMPORARY RESTRAINING ORDER TO A PRELIMINARY INJUNCTION I, NEAL K. KATYAL, hereby state and declare as follows: 1. I am counsel for Plaintiffs, the State of Hawai‘i and Ismail Elshikh. I have personal knowledge of and am competent to testify to the truth of the matters stated herein. This Supplemental Declaration is submitted in support of Plaintiffs’ Reply in Support of Motion to Convert Temporary Restraining Order to a Preliminary Injunction, filed concurrently herewith. 2. Attached as Exhibit D is a true and correct copy of a publication from the U.S. Department of Homeland Security, Office of Public Affairs, published electronically on March 21, 2017. See U.S. Dep’t of Homeland Security, Fact Sheet: Aviation Security Enhancements for Select Last Point of Departure Airports with Commercial Flights to the United States (Mar. 21, 2017), https://goo.gl/FQ4Mbt. 3. Attached as Exhibit E is a true and correct copy of a publication from the U.S. Department of Homeland Security, Office of the Press Secretary, published electronically on March 21, 2017 and updated on March 24, 2017. See U.S. Dep’t of Homeland Security, Q&A: Aviation Security Enhancements for Select Last Point of Departure Airports with Commercial Flights to the United States (updated Mar. 24, 2017), https://goo.gl/7rS8vS. 3 4. Attached as Exhibit F is a true and correct copy of a New York Times article published electronically on March 23, 2017 and in print on March 24, 2017. See Michael D. Shear, Trump Administration Orders Tougher Screening of Visa Applicants, N.Y. Times (Mar. 23, 2017), https://goo.gl/aJQ4m0. I declare under penalty of perjury that the foregoing is true and correct. DATED: Washington, D.C., March 25, 2017. /s/ Neal K. Katyal Neal K. Katyal 4

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