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

Filing 193

MOTION to Lift Stay of Proceedings, filed by Plaintiffs Commonwealth of Massachusetts, State of California, State of Maryland, State of New York, State of Washington, Intervenor Plaintiff State of Oregon. (Attachments: # 1 Proposed Order) Noting Date 10/16/2017, (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; STATE
10 OF CALIFORNIA; STATE OF
MARYLAND; COMMONWEALTH
11 OF MASSACHUSETTS; STATE OF
NEW YORK; and STATE OF
12 OREGON,

CIVIL ACTION NO. 2:17-cv-00141-JLR

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Motion Noted: October 16, 2017

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Plaintiffs,

MOTION TO LIFT STAY OF
PROCEEDINGS

v.

15 DONALD TRUMP, in his official
capacity as President of the United
16 States; U.S. DEPARTMENT OF
HOMELAND SECURITY; ELAINE
17 C. DUKE, in her official capacity as
Acting Secretary of the Department of
18 Homeland Security; REX
TILLERSON, in his official capacity
19 as Secretary of State; and the UNITED
STATES OF AMERICA,
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Defendants.
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MOTION TO LIFT STAY OF PROCEEDINGS

Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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I.

INTRODUCTION

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On September 24, 2017, President Trump issued a third immigration ban. Proclamation

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No. 9645, Enhancing Vetting Capabilities and Processes for Detecting Attempted Entry Into

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the United States by Terrorists and Other Public-Safety Threats, 82 Fed. Reg. 45,161 (Sept. 27,

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2017) (“EO3”). EO3 indefinitely restricts entry to the United States by foreign nationals from

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six Muslim-majority countries, plus Venezuela and North Korea, suspending entirely

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immigrant visas for anyone from the six Muslim-majority countries. This severe and expansive

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proclamation suffers from many of the same constitutional and statutory deficiencies as EO1

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and EO2. The new immigration ban goes into effect nationwide on October 18, 2017.

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The plaintiff States―including their residents, employers, health care systems, and

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educational institutions―will face immediate harms if EO3 is allowed to take effect as

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scheduled. Accordingly, the States respectfully request that the Court lift the stay of

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proceedings so that the States may move to amend their complaint and seek emergency relief.

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The States have conferred with counsel for Defendants. Defendants do not oppose

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lifting the stay. However, as detailed below, Defendants take a different position than the

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States as to the appropriate timing and briefing schedule for the State’s accompanying Motion

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for a Temporary Restraining Order. See infra, at pp. 7-8.

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The States respectfully propose that Defendants be given until 12:00 noon Pacific

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Daylight Time (PDT) on October 15, 2017, to file a response to the Motion for a Temporary

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Restraining Order. The States will forego a reply brief and respectfully request that a hearing

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be scheduled at 1:00 p.m. PDT on October 16, 2017, on the States’ Motion for a Temporary

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Restraining Order.1

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This proposed briefing schedule closely tracks the schedule in Hawai‘i v. Trump, CV
No. 17-00050 DKW-KSC, __ F. Supp. 3d __, 2017 WL 2989048 (D. Haw. July 13, 2017).
There, the district court ordered the Hawai‘i plaintiffs to file their Motion for Leave to File a
Third Amended Complaint and Motion for a Temporary Restraining order by 6:00 a.m. Hawaii
Standard Time (HST) on October 10, 2017. The Government must file its response to both

MOTION TO LIFT STAY OF PROCEEDINGS

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Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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II.

RELEVANT PROCEDURAL HISTORY

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The State of Washington first filed this lawsuit challenging President Trump’s issuance

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of Executive Order No. 13769 (“EO1”) on January 30, 2017. ECF 1. On February 3, 2017, this

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Court granted the State’s motion for a temporary restraining order (“TRO”) and enjoined

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enforcement of several provisions of EO1. ECF 52. The Ninth Circuit denied Defendants’

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emergency motion for a stay of the injunction. Washington v. Trump, 847 F.3d 1151 (9th Cir.

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2017) (per curiam). Defendants chose not to seek review by the Supreme Court.

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On March 6, 2017, President Trump issued Executive Order No. 13780 (“EO2”), which

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revoked EO1. Two days later, Defendants withdrew their Ninth Circuit appeal in this case.

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ECF 111. Following the issuance of EO2, Washington, California, Maryland, Massachusetts,

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New York, and Oregon (“States”)2 filed an amended complaint challenging EO2. ECF 152.

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The States moved for a TRO to enjoin sections 2(c) and 6(a) of EO2. ECF 148.

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On March 15, 2017, in a separate suit against EO2, the district court in Hawai‘i

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enjoined Sections 2 and 6 nationwide. Hawai‘i v. Trump, 241 F. Supp. 3d 1119, 1140 (D. Haw.

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2017). The next day, in a third lawsuit, the district court in Maryland issued a nationwide

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injunction against Section 2(c). Int’l Refugee Assistance Project (“IRAP”) v. Trump, 241 F.

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Supp. 3d 539, 566 (D. Md. 2017). In light of the Hawai‘i ruling, this Court stayed

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consideration of the States’ motion for a TRO. ECF 164. The Court then granted Defendants’

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request for a stay of this case pending the Ninth Circuit’s resolution of the Hawai‘i appeal.

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ECF 175, 189.

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The Ninth Circuit issued its opinion in Hawai‘i on June 12, 2017, largely affirming the

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injunction. Hawai‘i v. Trump, 859 F.3d 741 (9th Cir. 2017) (per curiam). Defendants

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motions by 6:00 a.m. HST on October 14, 2017. Each of those deadlines is one day prior to the
dates proposed by the States here.
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The Court had previously granted Oregon’s motion to intervene on March 9, 2017.
ECF 112.

MOTION TO LIFT STAY OF PROCEEDINGS

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Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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petitioned the Supreme Court for a writ of certiorari, applied for a stay pending appeal, and

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requested that the Hawai‘i case be consolidated with IRAP, where the Fourth Circuit had

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largely affirmed the injunction entered by the district court. IRAP v. Trump, 857 F.3d 554 (4th

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Cir. 2017) (en banc). The Supreme Court granted certiorari, granted the stay application “to the

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extent the injunctions prevent enforcement of § 2(c) with respect to foreign nationals who lack

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any bona fide relationship with a person or entity in the United States,” consolidated the two

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cases, and set the case for argument. Trump v. IRAP, 137 S. Ct. 2080, 2087 (U.S. 2017). The

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parties in this case agreed that the stay should remain in place pending the outcome of the

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Supreme Court proceedings, but that any party could move to lift the stay if circumstances

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changed. ECF 192.

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On June 28, 2017, Defendants began to enforce the non-enjoined parts of EO2 and

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published guidance interpreting the Supreme Court’s definition of “bona fide relationship” to

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exclude many family members and most refugees. See Hawai‘i v. Trump, __ F. Supp. 3d __,

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CV No. 17-00050 DKW-KSC, 2017 WL 2989048, at *5-6 (D. Haw. July 13, 2017)

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(summarizing guidance). Plaintiffs in the Hawai‘i litigation successfully challenged

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Defendants’ interpretation of “bona fide relationship,” and the Ninth Circuit upheld the lower

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court’s injunction preventing Defendants from enforcing EO2 against grandparents and other

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family members or refugees who have formal assurances from resettlement agencies or are in

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the U.S. Refugee Admissions Program. Hawai‘i v. Trump, __ F.3d __, No. 17-16426, 2017

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WL 3911055, at *14 (9th Cir. Sept. 7, 2017). The Supreme Court stayed the Ninth Circuit

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mandate with respect to refugees covered by a formal assurance. Trump v. Hawai‘i, __ S. Ct.

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__, Nos. 17A275, 16-1540, 2017 WL 4014838, at *1 (U.S. Sept. 12, 2017).

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On September 24, 2017, EO2 expired, and President Trump issued EO3, a Presidential

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Proclamation titled, “Enhancing Vetting Capabilities and Processes for Detecting Attempted

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Entry into the United States by Terrorists or Other Public-Safety Threats.” 82 Fed. Reg. 45,161

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(Sept. 27, 2017). EO3 again suspends immigration by hundreds of millions of people from six

MOTION TO LIFT STAY OF PROCEEDINGS

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Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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Muslim-majority countries, and applies “additional scrutiny” to immigrants from Iraq, another

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Muslim-majority country. EO3 §§ 1(g), 2(a)–(c), (e), (g)-(h).3 The order also suspends large

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classes of non-immigrants like students, businesspeople, and tourists. EO3 §§ 2(a)-(h). The

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non-immigrant restrictions vary by country and by type of visa. Id. EO3’s restrictions contain

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no sunset date—they apply indefinitely. The new entry restrictions and limitations go into

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effect at 12:01 a.m. EST on October 18, 2017. EO3 § 7(b).

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Following the issuance of EO3, the Supreme Court removed the Hawai‘i and IRAP

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cases from the oral argument calendar and directed the parties to file letter briefs addressing

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whether, or to what extent, EO3 rendered the cases moot. Trump v. Hawai‘i, __ S. Ct. __, No.

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16-1540, 2017 WL 2734554, at *1 (U.S. Sept. 25, 2017). On October 10, 2017, the Supreme

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Court dismissed IRAP as moot and directed the Fourth Circuit to vacate its opinion, finding

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that there was no longer a live controversy because the only section of EO2 enjoined in IRAP

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had “expired by its own terms on September 24, 2017.” Trump v. IRAP, __ S. Ct. __, No. 16-

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1436, 2017 WL 4518553 (U.S. Oct. 10, 2017). The Court “express[ed] no view on the merits.”

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Id.

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III.
A.

ARGUMENT

Circumstances Have Changed and Lifting the Stay Is Warranted

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“ ‘When circumstances have changed such that the court’s reasons for imposing [a] stay

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no longer exist or are inappropriate, the court may lift the stay.’” Hawai‘i v. Trump, 233 F.

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Supp. 3d 850, 854 (D. Haw. 2017) (quoting Crawford v. Japan Airlines, No. 03-00451 LEK-

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KSC, 2013 WL 2420715, at *6 (D. Haw. May 31, 2013)); accord CMAX, Inc. v. Hall, 300

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F.2d 265, 270 (9th Cir. 1962) (“Should there be substantial change in circumstances indicating

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The order also suspends all entry by North Koreans and entry by certain nonimmigrants from Venezuela. EO3 §§ 2(d)(ii), 2(f)(ii). These provisions will affect very few
travelers. In 2015, for example, 55 immigrants were admitted from North Korea, compared to
13,114 immigrants from Iran. 3d Am. Compl. ¶ 204. The provision affecting Venezuelans
applies only to certain government officials and their families.

MOTION TO LIFT STAY OF PROCEEDINGS

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Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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that the trial should not be further delayed, [the party opposing the stay] may seek a district

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court order resetting the case for trial.”). “Logically, the same court that imposes a stay of

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litigation has the inherent power and discretion to lift the stay.” Canady v. Erbe Elektromedizin

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GmbH, 271 F. Supp. 2d 64, 74 (D.D.C. 2002).

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Here, there can be no question that Defendants have significantly changed the

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circumstances. In allowing EO2 to expire and in issuing EO3 with new terms, changed banned

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countries, and no expiration date, Defendants have shifted the facts and legal standards at play.

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In light of these changed circumstances, the federal district courts in Hawai‘i and Maryland

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have already allowed plaintiffs to move to amend their complaints and seek injunctive relief

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concerning EO3. See Hawai‘i v. Trump, No. 1:17-cv-00050-DKW-KSC (D. Haw.), ECF 366

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(Oct. 6, 2017) (lifting stay of proceedings to allow Plaintiffs to move to amend their complaint

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and move for a TRO against EO3); IRAP v. Trump, No. 8:17-cv-00361-TDC (D. Md.), ECF

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201 (Oct. 4, 2017) (granting Plaintiffs leave to amend their complaint and move for a

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preliminary injunction against EO3).4 Defendants invited these developments by informing the

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Supreme Court that, “[i]f respondents (or anyone else) believes [EO3] violates their rights,

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they can file new challenges and those claims will not evade review . . . .” Suppl. Brief of

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Petitioners at 6, Trump v. IRAP, __ S. Ct. __ (U.S. Oct. 5, 2017) (No. 16-1436, 16-1540). This

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Court should also lift the stay.

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B.

The States Will Suffer Significant Harm if the Stay is Not Lifted

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In considering whether to lift the stay, the Court should consider the possible damage

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that may result from leaving the stay in place. CMAX, 300 F.2d at 268 (identifying factors

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Defendants did not oppose the plaintiffs’ request to resume proceedings or challenge
EO3 in either case. Hawai‘i v. Trump, ECF 363 (Oct. 16, 2017) (“[T]he Government consents
to Plaintiffs’ request to lift the stay in order to challenge EO-3.”); IRAP v. Trump, ECF 198
(Sep. 29, 2017) (noting “Defendants do not oppose the motion for leave to amend the
complaint” but request not to file a response “until the Plaintiffs’ preliminary injunction
motion is resolved”).

MOTION TO LIFT STAY OF PROCEEDINGS

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Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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weighed by the court in determining the propriety of a stay, including possible damage that

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may result). If EO3 takes effect, the imminent harms to the States and their residents will be

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significant. The States have detailed those harms in the proposed Third Amended Complaint

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and accompanying declarations. 3d Am. Compl. ¶¶ 16-129 (citing relevant declarations). The

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States wish to amend their complaint and seek emergency relief against EO3 before it takes

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effect on October 18, 2017. If the stay is not lifted to allow the States to challenge EO3 and

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seek emergency relief, the States will suffer irreparable harm. Accordingly, this factor weighs

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in favor of lifting the stay.

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C.

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Allowing the States to Amend the Complaint and Seek Emergency Relief From
Unlawful EO3 Poses No Hardship or Inequity to Defendants
In contrast to the significant and widespread harm and inequity that the States will

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suffer if the stay is not lifted, Defendants will not suffer any hardship or inequity from having
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to respond to a legal challenge and request for injunctive relief concerning EO3. This factor
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also weighs in favor of lifting the stay. CMAX, 300 F.2d at 268 (identifying hardship or
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inequity which a party may suffer as additional factor weighed by the court in determining
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propriety of a stay).
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As both the Supreme Court and the Ninth Circuit have cautioned, “‘if there is even a
fair possibility that the stay . . . will work damage to someone else,’ the stay may be
inappropriate absent a showing by the moving party of ‘hardship or inequity.’” Dependable

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Highway Express, Inc., v. Navigators Ins. Co., 498 F.3d 1059, 1066 (9th Cir. 2007) (quoting
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Landis v. North Am. Co., 299 U.S. 248, 255 (1936)); Lockyer v. Mirant Corp., 398 F.3d 1098
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(9th Cir. 2005). A stay is particularly inappropriate where the party is seeking injunctive relief
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against ongoing and future harm. See Lockyer, 398 F.3d at 1112 (holding that a stay is
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inappropriate where the plaintiff seeks injunctive relief against ongoing and future harm as
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opposed to damages for past harm).
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MOTION TO LIFT STAY OF PROCEEDINGS

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Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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Here, there is more than just a “fair possibility” that the stay will “work damage” to the

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States and to the residents, employers, health care systems, and educational institutions that

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they seek to protect. If the States’ claims have merit, which the accompanying proposed Third

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Amended Complaint and Motion for a Temporary Restraining Order show that they do,

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Defendants’ unlawful actions threaten widespread harm that is certain to commence on

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October 18, 2017.

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Furthermore, Defendants have not filed a responsive pleading in this case yet and will

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have the opportunity to oppose the States’ request for emergency relief. The fact that

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Defendants will be required to respond to these pleadings does not, by itself, constitute a

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hardship. Washington v. Trump, No. C17-0141JLR, 2017 WL 1050354, *4 (W.D. Wash. Mar.

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17, 2017) (“‘[B]eing required to defend a suit, without more, does not constitute a clear case of

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hardship or inequity’ for purposes of a stay.”) (quoting Lockyer, 398 F.3d at 1112). In fact,

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Defendants already have to respond to similar legal claims in other litigation challenging EO3,

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so they can make no claim of prejudice from being required to go forward here.

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Lastly, Defendants themselves fully controlled the decision and timing surrounding the

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issuance of EO3, and those decisions gave rise to the States’ need to amend their complaint

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and seek emergency relief. It would be extraordinarily unfair to prevent the States from taking

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necessary action to respond to the change in circumstances that Defendants created.

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Defendants take the position that:

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“The Government does not oppose lifting the stay, but the Government

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does not believe it is either necessary or appropriate for the Court to

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decide Plaintiffs’ TRO motion before October 18. There will be no

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irreparable injury to Plaintiffs from a brief delay in entry from the

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Proclamation while the issues are adjudicated on a reasonable briefing

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schedule. Moreover, the Government believes it should be given at least

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14 days to file its opposition to plaintiffs’ TRO motion. Any less time

MOTION TO LIFT STAY OF PROCEEDINGS

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Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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would be prejudicial, especially since Plaintiffs have created any urgency

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by waiting 17 days after the Proclamation was issued before filing their

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TRO motion, despite knowing the Proclamation would take effect after 23

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days. The Government should not be disadvantaged, nor the Court

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burdened, by Plaintiffs’ delay.”5

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Defendants’ proposed schedule for the timing and briefing of the State’s accompanying motion

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for a temporary restraining order is untenable in light of the irreparable harm the States will

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face if EO3 is allowed to take effect on October 18. Defendants’ position conveniently ignores

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that Defendants had 90 days to announce EO3 but waited until the very evening that EO2

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expired before doing so. Furthermore, EO3 announces large-scale changes to immigration law

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with less than one month between the announcement and its implementation. The States moved

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expediently in evaluating the legality of EO3 and assessing the impacts it would have on their

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residents, employers, health care systems, and educational institutions. The States’ motion to

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lift the stay in order to seek leave to amend the complaint, and a temporary restraining order

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against EO3, is made promptly to avoid the irreparable harm the States’ will face as a result of

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Defendants’ unlawful actions.

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Thus, the equities weigh in favor of lifting the stay.
D.

Lifting the Stay Will Benefit the Orderly Course of Justice

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Lifting the stay furthers the course of justice, and the pending Supreme Court appeal

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does not alter this outcome. It is true that courts often stay proceedings where resolution of an

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appeal in another matter is likely to provide guidance to the court in deciding the issues before

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it. See Landis, 299 U.S. at 254; see also Leyva v. Certified Grocers of California, Ltd., 593

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F.2d 857, 863 (9th Cir. 1979). Indeed, this Court stayed these proceedings due to the fact that

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E-mail from Michelle Bennett, Trial Attorney, U.S. Department of Justice, Civil
Division, Federal Programs Branch, to Colleen Melody, Civil Rights Unit Chief, Washington
State Attorney General’s Office (Oct. 11, 2017, 08:49 PDT) (on file with author).

MOTION TO LIFT STAY OF PROCEEDINGS

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Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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both this lawsuit and Hawai‘i involved similar challenges to sections 2 and 6 of EO2. See ECF

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189 at 4-5. However, the Supreme Court proceedings in Hawai‘i and IRAP involve only the

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legality of EO2, and Defendants have now argued that even those appeals are moot. Suppl.

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Brief of Petitioners at 1, Trump v. IRAP, __ S. Ct. __ (U.S. Oct. 5, 2017) (No. 16-1436, 16-

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1540). The Supreme Court has not requested briefing on, and no party has argued, the legality

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of EO3. Trump v. Hawai‘i, __ S. Ct. __, No. 16-1540, 2017 WL 2734554, at *1 (U.S. Sept. 25,

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2017); Suppl. Brief of Petitioners, Trump v. IRAP, __ S. Ct. __ (U.S. Oct. 5, 2017) (No. 16-

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1436, 16-1540); Suppl. Brief of Respondents, Trump v. IRAP, __ S. Ct. __ (U.S. Oct. 5, 2017)

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(No. 16-1436, 16-1540). In fact, the Supreme Court has now dismissed IRAP as moot and

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directed the Fourth Circuit to vacate its opinion, finding that there was no longer a live

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controversy because the only section of EO2 enjoined in IRAP had “expired by its own terms

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on September 24, 2017.” Trump v. IRAP, __ S. Ct. __, No. 16-1436, 2017 WL 4518553 (U.S.

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Oct. 10, 2017). The Court “express[ed] no view on the merits.” Id. Because the Supreme Court

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appeal in IRAP did not consider the legality of EO3, nor is the appeal in Hawai‘i likely to

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(even if the Court addresses it), this Court should lift the stay and allow the States’ challenge to

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EO3 to proceed.

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IV.

CONCLUSION

The Court should lift the stay to allow the States to file an amended complaint and seek

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emergency relief against EO3 before it takes effect on October 18, 2017.

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RESPECTFULLY SUBMITTED this 11th day of October, 2017.

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BOB FERGUSON, WSBA #26004
Attorney General of Washington

XAVIER BECERRA
Attorney General of California

/s/ Noah G. Purcell________________
NOAH G. PURCELL, WSBA #43492
Solicitor General
COLLEEN M. MELODY, WSBA #42275
Civil Rights Unit Chief
ANNE E. EGELER, WSBA #20258
Deputy Solicitor General
MARSHA CHIEN, WSBA #47020

ANGELA SIERRA
Senior Assistant Attorney General
THOMAS S. PATTERSON
Senior Assistant Attorney General
TAMAR PACHTER
Supervising Deputy Attorney General
ENRIQUE A. MONAGAS
Deputy Attorney General

MOTION TO LIFT STAY OF PROCEEDINGS

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Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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PATRICIO A. MARQUEZ, WSBA #47693
Assistant Attorneys General
Office of the Attorney General
800 Fifth Avenue, Suite 2000
Seattle, WA 98104
[phone]
[e-mail]
[e-mail]

/s/ Alexandra Robert Gordon_________
ALEXANDRA ROBERT GORDON
Deputy Attorney General
Office of the Attorney General
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
Telephone: [phone]
E-mail:
[e-mail]

BRIAN E. FROSH
Attorney General of Maryland

MAURA HEALEY
Attorney General of Massachusetts

/s/ Steven M. Sullivan
STEVEN M. SULLIVAN, Federal Bar #24930
Solicitor General
ROBERT A. SCOTT, Federal Bar #24613
Assistant Attorney General
MEGHAN K. CASEY, Federal Bar #28958
Assistant Attorney General
Office of the Attorney General of Maryland
200 St. Paul Place, 20th Floor
Baltimore, Maryland 21202
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]

/s/ Jesse M. Boodoo
JESSE M. BOODOO
Assistant Attorney General
GENEVIEVE C. NADEAU
Chief, Civil Rights Division
ELIZABETH N. DEWAR
State Solicitor
One Ashburton Place
Boston, MA 02108
617-963-2204
[e-mail]
[e-mail]
[e-mail]

ERIC T. SCHNEIDERMAN
Attorney General of the State of New York

ELLEN F. ROSENBLUM
Attorney General of Oregon

/s/ Lourdes M. Rosado
LOURDES M. ROSADO
Bureau Chief, Civil Rights Bureau
ANISHA DASGUPTA
Deputy Solicitor General
Office of the New York State Attorney General
120 Broadway
New York, New York 10271
[phone]
[e-mail]

/s/ Scott J. Kaplan
SCOTT J. KAPLAN, WSBA #49377
Senior Assistant Attorney General
Oregon Department of Justice
100 Market Street
Portland, OR 97201
971-673-1880
[e-mail]

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MOTION TO LIFT STAY OF PROCEEDINGS

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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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October 11, 2017

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

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MOTION TO LIFT STAY OF PROCEEDINGS

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Attorney General of Washington
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]