State of Hawaii v. Trump

Filing 258

NOTICE of Filing of Declaration of Lawrence E. Bartlett by John F. Kelly, Rex Tillerson, Donald J. Trump, U.S. Department of Homeland Security, U.S. Department of State, United States of America re 238 MOTION to Convert Temporary Restraining Order to Preliminary Injunction , 251 Memorandum in Opposition to Motion . (Attachments: # 1 Declaration of Lawrence E. Bartlett, # 2 Certificate of Service)(Rosenberg, Brad) Modified on 3/29/2017 (emt, ).

JEFFREY B. WALL
Acting Solicitor General
CHAD A. READLER
Acting Assistant Attorney General
ELLIOT ENOKI (No. 1528)
Acting United States Attorney
EDRIC M. CHING (No. 6697)
Assistant United States Attorney
JOHN R. TYLER
Assistant Branch Director
BRAD P. ROSENBERG (DC Bar No. 467513)
MICHELLE R. BENNETT (CO Bar No. 37050)
DANIEL SCHWEI (NY Bar)
Trial Attorneys
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Avenue, N.W.
Washington, D.C. 20530
Tel: [phone]; Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF HAWAII
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.

No. 1:17-cv-00050-DKWKSC
DEFENDANTS’ NOTICE
OF FILING OF
DECLARATION OF
LAWRENCE E.
BARTLETT
Judge: Hon. Derrick K.
Watson
Hearing: March 29, 2017,
9:30 a.m.
Related Documents:
Dkt. Nos. 238, 251

DEFENDANTS’ NOTICE OF FILING OF
DECLARATION OF LAWRENCE E. BARTLETT
PLEASE TAKE NOTICE that Defendants, by their undersigned counsel,
hereby file the Declaration of Lawrence E. Bartlett, for this Court’s consideration
of whether its Temporary Restraining Order (ECF No. 219) (“TRO”) should be
converted to a preliminary injunction. In their reply brief in support of their
motion to convert this Court’s TRO to a preliminary injunction, Plaintiffs claim
that they have standing to challenge the refugee provisions contained in Executive
Order 13,780. See Reply in Support of Motion to Convert Temporary Restraining
Order to a Preliminary Injunction at 8-11, ECF No. 252. As set forth in the
attached declaration, Hawaii has resettled only 20 of the 538,297 refugees that
have been resettled in the United States in the past eight fiscal years (including
this fiscal year to date).

Dated: March 28, 2017

Respectfully submitted,
JEFFREY B. WALL
Acting Solicitor General
CHAD A. READLER
Acting Assistant Attorney General
ELLIOT ENOKI (No. 1528)
Acting United States Attorney
EDRIC M. CHING (No. 6697)
Assistant United States Attorney
JOHN R. TYLER
Assistant Director, Federal Programs Branch
/s/ Brad P. Rosenberg
BRAD P. ROSENBERG (DC Bar. No. 467513)
MICHELLE R. BENNETT (CO Bar. No. 37050)
DANIEL SCHWEI (NY Bar)
Trial Attorneys
U.S. Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Avenue, N.W.
Washington, D.C. 20530
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants

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