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

Filing 148

Emergency MOTION for Temporary Restraining Order , filed by Plaintiff State of Washington. Oral Argument Requested. (Attachments: # 1 Declaration of N. Purcell, # 2 Proposed Order) Noting Date 3/15/2017, (Melody, Colleen)

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THE HONORABLE JAMES L. ROBART

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON and
9 STATE OF MINNESOTA,
Civil Action No. 2:17-cv-00141-JLR
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Plaintiffs,
v.

12 DONALD TRUMP, in his official
capacity as President of the United
13 States; U.S. DEPARTMENT OF
HOMELAND SECURITY; JOHN
14 F. KELLY, in his official capacity as
Secretary of the Department of
15 Homeland Security; REX W.
TILLERSON, in his official capacity
16 as Secretary of State; and the
UNITED STATES OF AMERICA,
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Defendants.
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DECLARATION OF NOAH G.
PURCELL IN SUPPORT OF
EMERGENCY MOTION FOR
TEMPORARY RESTRAINING ORDER
Motion Noted: March 15, 2017

19 STATE OF OREGON,
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Intervenor-Plaintiff,
v.

22 DONALD TRUMP, et al.,
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Intervenor-Defendants.

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PURCELL DECL. ISO EMERGENCY
MOTION FOR TEMPORARY RESTRAINING
ORDER

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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Pursuant to 28 U.S.C. § 1746(2), I, Noah G. Purcell, hereby declare as follows:

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I am over the age of eighteen and competent to testify.

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I am the Solicitor General for the State of Washington. I make this declaration

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as a representative of the State of Washington (“Washington”) in support of the Emergency

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Motion for Temporary Restraining Order filed concurrently herewith.

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3.

Pursuant to Western District of Washington Local Rule 65(b)(1), on March 15,

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2017, at approximately 11:35 a.m., an attorney on my staff contacted counsel for Defendants

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by telephone to provide notice of Washington’s intent to file a Motion for Temporary

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Restraining Order by that afternoon, and to note it for same-day hearing on March 15, 2017.

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4.

Counsel for Washington spoke with Michelle Bennett and John Tyler of the

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U.S. Department of Justice, Civil Division, Federal Programs Branch, 20 Massachusetts

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Avenue, NW, Washington, D.C. 20530, [phone].

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Ms. Bennett advised that she is the point of contact for Defendants’ counsel.

Ms. Bennett may be reached at [phone] and [e-mail].
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Ms. Bennett and Mr. Tyler advised that Defendants oppose the Motion for

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

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Executed this 15th day of March, 2017

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s/ Noah G. Purcell
NOAH G. PURCELL, WSBA #43492
Solicitor General
Office of the Attorney General
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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PURCELL DECL. ISO EMERGENCY
MOTION FOR TEMPORARY RESTRAINING
ORDER

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ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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CERTIFICATE OF SERVICE

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I hereby certify that the foregoing document was electronically filed with the United

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States District Court using the CM/ECF system. I certify that all participants in the case are

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registered CM/ECF users and that service will be accomplished by the appellate CM/ECF

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system.

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March 15, 2017

s/ Noah G. Purcell
NOAH G. PURCELL, WSBA 43492

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PURCELL DECL. ISO EMERGENCY
MOTION FOR TEMPORARY RESTRAINING
ORDER

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ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]