State of Washington, et al., v. Trump., et al

Filing 118

Second MOTION to Amend Complaint, filed by Plaintiff State of Washington. (Attachments: # 1 Complaint Second Amended, # 2 Exhibit Exhibits to Second Amended Complaint, # 3 Index of Declarations, # 4 Decl. of R. Althaibani, # 5 Decl. of S. Amin, # 6 Decl. of B. Callaghan, # 7 Decl. of S. Dadgari, # 8 Decl. of A. Elfgeeh, # 9 Decl. of N. Fallah, # 10 Decl. of H. Ghasemzadeh, # 11 Decl. of E. Hassett, # 12 Decl. of A. Mubarez, # 13 Decl. of S. Parsian, # 14 Decl. of Z. Rasouli, # 15 Decl. of A. Shayegan, # 16 Decl. of J. Sime, # 17 Decl. of R. Branon, # 18 Decl. of A. Chaudhry, # 19 Decl. of D. Eaton, # 20 Decl. of D. Heatwole, # 21 Decl. of S. Hemmati, # 22 Decl. of R. Lewin, # 23 Decl. of A. Mehrizi-Sani, # 24 Decl. of V. Rabinowitz, # 25 Decl. of J. Riedinger, # 26 Decl. of V. Shah, # 27 Decl. of J. Wasserheit, # 28 Decl. of J. Wasserheit, # 29 Decl. of J. Wood, # 30 Decl. of N. Zimpher, # 31 Decl. of S. Buell, # 32 Decl. of R. Fullerton, # 33 Decl. of P. Johnson, # 34 Decl. of A. Lavine, # 35 Decl. of D. Pashman, # 36 Decl. of M. Rosenn, # 37 Decl. of M. Saunders, # 38 Decl. of J. Simeone, # 39 Decl. of D. Soike, # 40 Decl. of S. Topiwala, # 41 Decl. of J. Truppman, # 42 Decl. of R. Zawaideh, # 43 Decl. of M. Akhtari, # 44 Decl. of M. de Leon, # 45 Decl. of R. Eskandari, # 46 Decl. of T. Johnson, # 47 Decl. of E. Scherzer, # 48 Decl. of W. Berkovitz, # 49 Decl. of D. Duea, # 50 Decl. of L. Warren, # 51 Proposed Order) Noting Date 3/31/2017, (Melody, Colleen)

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DECLARATION OF DAVID DUEA 1 2 The Honorable James Robart 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 10 STATE OF WASHINGTON and STATE OF MINNESOTA, 11 Plaintiffs, 12 v. 13 DONALD TRUMP, in his official 14 capacity as President of the United States; U.S. DEPARTMENT OF 15 HOMELAND SECURITY; JOHN F. KELLY, in his official capacity as 16 Secretary of the Department of Homeland Security; REX 17 TILLERSON, in his official capacity as Secretary of State; and the UNITED 18 STATES OF AMERICA, 19 CIVIL ACTION NO. 2:17-cv-00141-JLR DECLARATION OF DAVID DUEA Defendants. 20 Pursuant to 28 U.S.C. § 1746(2), I, DAVID DUEA, hereby declare as follows: 21 1. I am over the age of 18 and competent to be a witness. I am a resident of the State of 22 Washington. I am the President and Chief Executive Officer of Lutheran Community 23 Services Northwest (“LCSNW”). 24 2. LCSNW is a social service agency that formed in 2001 from the merger of several 25 Lutheran outreach ministries. LCSNW is a ministry of the Evangelical Lutheran Church 26 DECLARATION OF DAVID DUEA 1 of America and the Lutheran Church – Missouri Synod. Our mission is to partner with 2 individuals, families and communities for health, justice and hope. 3 commitment is to reach out, sharing God’s love, in service to our neighbors. 4 5 LCSNW’s 3. LCSNW have ministered to over 40,000 refugees since 1975 by helping them resettle in the United States. 6 4. We accomplish this, in part, through helping refugees learn basic living skills and 7 providing mental health services to those who have experienced traumatic events that led 8 them to flee their country of origin. We welcome and provide services to refugees of all 9 faiths as part of our ministry, as we see all refugees as God’s children. 10 5. One of the refugee programs at LCSNW is Multicultural Community Services (“MCS”). 11 MCS is contracted with the U.S. Department of State to help refugees rebuild their homes 12 and their lives by providing reception and placement services. These services include 13 securing housing, furnishings and food in preparation for the refugees’ arrival. After 14 arrival, MCS case managers refer refugees to social services, including medical screening, 15 employment programs, job coaching, English Language Learner classes, registering 16 children in school and temporary cash assistance. 17 6. Since August 1, 2016, LCSNW has provided resettlement assistance to 15 newly-arriving 18 refugees from Syria. During that time, we have provided assistance to 169 newly-arriving 19 refugees from Iran, Iraq, Somalia, Sudan, Libya and Yemen. 20 7. We estimate that as a result of the President’s second Executive Order that becomes 21 effective on March 16, we will be unable to provide assistance to between 100 and 200 22 refugees who would otherwise have come to the U.S. and for whom LCSNW would 23 provide services. 24 8. As I stated above, LCSNW is a ministry of the Lutheran Church. As Christians, our work 25 with refugees is a religious calling and is one way in which we serve our faith. We take to 26 heart the parable of the Good Samaritan, and see our efforts to help refugees as a way of DECLARATION OF DAVID DUEA 1 exercising our religious beliefs. The President’s second Executive Order, by preventing 2 refugees for whom we would have otherwise provided services from traveling to the 3 United States, will prevent me and other employees of LCSNW from practicing our faith 4 by ministering to these refugees. 5 9. The President’s second Executive Order, by preventing the arrival of refugees to whom 6 we would have otherwise provided services, will have a significant negative financial 7 impact on LCSNW, as LCSNW is paid for providing services to refugees. This is lost 8 revenue to LCSNW, as there is not a “pool” of refugees that we can assist to make up for 9 the lost revenue from those refugees who have been prevented from travelling to the 10 United States as a result of the Executive Order. We have notified 15 out of our 35 refugee 11 assistance staff that they will be laid off after the second executive order goes into effect. 12 13 I declare under penalty of perjury that the foregoing is true and correct. 14 15 Executed on this _10th _ day of March, 2017 at Seattle, Washington. 16 17 18 DAVID DUEA President and CEO Lutheran Community Services Northwest 19 20 ________________________________________ 21 22 23 24 25 26 DECLARATION OF DAVID DUEA

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