State of Hawaii v. Trump

Filing 38

Declaration of Clyde J. Wadsworth Regarding Exhibit C to Declaration of Douglas S. Chin in Support of Plaintiff's Motion for Temporary Restraining Order. (Attachments: # 1 Certificate of Service)(Wadsworth, Clyde)

NEAL K. KATYAL*
DOUGLAS S. CHIN (Bar No. 6465)
Attorney General of the State of Hawai‘i HOGAN LOVELLS US LLP
CLYDE J. WADSWORTH (Bar No. 8495) 555 Thirteenth Street NW
Washington, DC 20004
Solicitor General of the State of Hawai‘i
Telephone: [phone]
DEIRDRE MARIE-IHA (Bar No. 7923)
Fax: [phone]
DEPARTMENT OF THE ATTORNEY
Email:
GENERAL, STATE OF HAWAI‘I
[e-mail]
425 Queen Street
Honolulu, HI 96813
*Admitted Pro Hac Vice
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
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: [phone]
Fax: [phone]

COLLEEN ROH SINZDAK*
MITCHELL P. REICH*
ELIZABETH HAGERTY**
HOGAN LOVELLS US LLP
555 Thirteenth Street NW
Washington, DC 20004
Telephone: [phone]
Fax: [phone]
THOMAS P. SCHMIDT*
HOGAN LOVELLS US LLP
875 Third Avenue
New York, NY 10022
Telephone: [phone]
Fax: [phone]
SARA SOLOW*
ALEXANDER B. BOWERMAN*
HOGAN LOVELLS US LLP
1835 Market St., 29th Floor
Philadelphia, PA 19103
Telephone: [phone]
Fax: [phone]
*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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