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)

DECLARATION OF
DAVID DUEA

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The Honorable James Robart
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

10 STATE OF WASHINGTON and
STATE OF MINNESOTA,
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Plaintiffs,
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v.
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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,
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CIVIL ACTION NO. 2:17-cv-00141-JLR

DECLARATION OF DAVID DUEA

Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, DAVID DUEA, hereby declare as follows:
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1. I am over the age of 18 and competent to be a witness. I am a resident of the State of
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Washington. I am the President and Chief Executive Officer of Lutheran Community
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Services Northwest (“LCSNW”).
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2. LCSNW is a social service agency that formed in 2001 from the merger of several
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Lutheran outreach ministries. LCSNW is a ministry of the Evangelical Lutheran Church
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DECLARATION OF DAVID DUEA

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of America and the Lutheran Church – Missouri Synod. Our mission is to partner with

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individuals, families and communities for health, justice and hope.

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commitment is to reach out, sharing God’s love, in service to our neighbors.

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LCSNW’s

3. LCSNW have ministered to over 40,000 refugees since 1975 by helping them resettle in
the United States.

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4. We accomplish this, in part, through helping refugees learn basic living skills and

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providing mental health services to those who have experienced traumatic events that led

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them to flee their country of origin. We welcome and provide services to refugees of all

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faiths as part of our ministry, as we see all refugees as God’s children.

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5. One of the refugee programs at LCSNW is Multicultural Community Services (“MCS”).

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MCS is contracted with the U.S. Department of State to help refugees rebuild their homes

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and their lives by providing reception and placement services. These services include

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securing housing, furnishings and food in preparation for the refugees’ arrival. After

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arrival, MCS case managers refer refugees to social services, including medical screening,

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employment programs, job coaching, English Language Learner classes, registering

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children in school and temporary cash assistance.

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6. Since August 1, 2016, LCSNW has provided resettlement assistance to 15 newly-arriving

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refugees from Syria. During that time, we have provided assistance to 169 newly-arriving

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refugees from Iran, Iraq, Somalia, Sudan, Libya and Yemen.

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7. We estimate that as a result of the President’s second Executive Order that becomes

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effective on March 16, we will be unable to provide assistance to between 100 and 200

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refugees who would otherwise have come to the U.S. and for whom LCSNW would

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provide services.

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8. As I stated above, LCSNW is a ministry of the Lutheran Church. As Christians, our work

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with refugees is a religious calling and is one way in which we serve our faith. We take to

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heart the parable of the Good Samaritan, and see our efforts to help refugees as a way of

DECLARATION OF DAVID DUEA

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exercising our religious beliefs. The President’s second Executive Order, by preventing

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refugees for whom we would have otherwise provided services from traveling to the

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United States, will prevent me and other employees of LCSNW from practicing our faith

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by ministering to these refugees.

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9. The President’s second Executive Order, by preventing the arrival of refugees to whom

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we would have otherwise provided services, will have a significant negative financial

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impact on LCSNW, as LCSNW is paid for providing services to refugees. This is lost

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revenue to LCSNW, as there is not a “pool” of refugees that we can assist to make up for

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the lost revenue from those refugees who have been prevented from travelling to the

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United States as a result of the Executive Order. We have notified 15 out of our 35 refugee

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assistance staff that they will be laid off after the second executive order goes into effect.

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I declare under penalty of perjury that the foregoing is true and correct.

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Executed on this _10th _ day of March, 2017 at Seattle, Washington.

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DAVID DUEA
President and CEO
Lutheran Community Services Northwest

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DECLARATION OF DAVID DUEA