State of Hawaii v. Trump
Filing
30
MOTION to Partially Lift Stay Neal Katyal appearing for Plaintiff State of Hawaii (Attachments: # 1 Exhibit Proposed First Am. Compl., # 2 Exhibit Decl. of Clyde J. Wadsworth, # 3 Exhibit Proposed Order, # 4 Certificate of Service)(Katyal, Neal)
DOUGLAS S. CHIN (Bar No. 6465)
NEAL K. KATYAL*
Attorney General of the State of Hawai‘i HOGAN LOVELLS US LLP
CLYDE J. WADSWORTH (Bar No. 8495) 555 Thirteenth Street NW
Solicitor General of the State of Hawai‘i
Washington, DC 20004
DEIRDRE MARIE-IHA (Bar No. 7923)
Telephone: (202) 637-5600
DEPARTMENT OF THE ATTORNEY
Fax: (202) 637-5910
GENERAL, STATE OF HAWAI‘I
Email:
425 Queen Street
neal.katyal@hoganlovells.com
Honolulu, HI 96813
Telephone: (808) 586-1500
*Admitted Pro Hac Vice
Fax: (808) 586-1239
Email: deirdre.marie-iha@hawaii.gov
Attorneys for Plaintiff, State of Hawai‘i
(See Next Page For Additional Counsel)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF HAWAI‘I
STATE OF HAWAI‘I,
Plaintiff,
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;
REX TILLERSON, in his official capacity as
Secretary of State; and the UNITED STATES
OF AMERICA,
Defendants.
Civil Action No.
1:17-CV-00050-DKW-KJM
DECLARATION OF CLYDE
J. WADSWORTH
REGARDING EXHIBIT C TO
DECLARATION OF
DOUGLAS S. CHIN IN
SUPPORT OF PLAINTIFF’S
MOTION FOR TEMPORARY
RESTRAINING ORDER
ADDITIONAL COUNSEL
KIMBERLY T. GUIDRY (Bar No. 7813)
DONNA H. KALAMA (Bar No. 6051)
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
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
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
*Pro Hac Vice Applications
Forthcoming
** Admitted Pro Hac Vice
Attorneys for Plaintiff, State of Hawai‘i
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DECLARATION OF CLYDE J. WADSWORTH REGARDING EXHIBIT C
TO DECLARATION OF DOUGLAS S. CHIN IN SUPPORT OF
PLAINTIFF’S MOTION FOR TEMPORARY RESTRAINING ORDER
I, CLYDE J. WADSWORTH, hereby state and declare as follows:
1.
I am the Solicitor General for the State of Hawai‘i and an attorney of
record representing Plaintiff in this case. Unless otherwise stated, I have personal
knowledge of and am competent to testify to the truth of the matters stated in this
Declaration.
2.
On February 3, 2017, Plaintiff filed the following documents, among
others, in this case: (1) Declaration of Douglas S. Chin in Support of Plaintiff’s
Motion for Temporary Restraining Order (the “Chin Declaration”) (Dkt. No. 10);
(2) Ex Parte Motion for In Camera Review of Exhibits A, B, and C to Declaration
of Douglas S. Chin in Support of Plaintiff’s Motion for Temporary Restraining
Order (the “Ex Parte Motion”) (Dkt. No. 15); and (3) Declaration of Clyde J.
Wadsworth in Support of Ex Parte Motion for In Camera Review of Exhibits A, B,
and C to Declaration of Douglas S. Chin in Support of Plaintiff’s Motion for
Temporary Restraining Order (the “Wadsworth Declaration”) (Dkt. No. 15-1).
3.
Exhibits A, B, and C to the Chin Declaration were submitted to this
Court for in camera review for the reasons stated in the Ex Parte Motion and the
Wadsworth Declaration.
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4.
The declarant for Exhibit C (“Declarant C”), as well as his family,
was described in the Ex Parte Motion at Page 6 and the Wadsworth Declaration at
Paragraph 6.
5.
Hours after Plaintiff filed its Complaint and Motion for Temporary
Restraining Order in this action, the United States District Court for the Western
District of Washington issued a temporary restraining order barring enforcement
nationwide of provisions of the Executive Order at issue in this action.
6.
On February 7, 2017, Declarant C informed my office that, due to the
TRO that has been imposed on the Executive Order, his family members were able
to return, and have now returned, to the United States.
I declare under penalty of perjury that the foregoing is true and correct.
DATED: Honolulu, Hawaii, February 8, 2017.
/s/ Clyde J. Wadsworth
Clyde J. Wadsworth
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