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

Filing 194

MOTION for Leave to File Third Amended Complaint, 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 Complaint 3rd Amended, # 2 Index of Exhibits, # 3 Index of Declarations, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Exhibit K, # 15 Exhibit L, # 16 Exhibit M, # 17 Exhibit N, # 18 Decl of Joint Former National Security Officials, # 19 Decl of Nima Ala, # 20 2nd Decl of Rabyaah Althaibani, # 21 Decl of Alireza Ayoubi, # 22 Decl of Shervin Beygi, # 23 Decl of Bahareh Bina, # 24 Decl of Ethan Devenport, # 25 Decl of Yasaman Esmaili, # 26 Decl of Mahdi Hajiaghayi, # 27 Decl of Mojdeh Jalali Heravi, # 28 Decl of Vahid Jazayeri, # 29 Decl of Mohammad Shafiei Khadem, # 30 Decl of Ahmad Moghaddam, # 31 Decl of Younes Nouri, # 32 Decl of Proshat Parsimoghadam, # 33 Decl of Emad Soroush, # 34 Decl of Tannaz Sattari Tabrizi, # 35 Decl of Seyed Danial Vaezi, # 36 Decl of Banafsheh Samareh Abolhasani, # 37 Decl of Armin Alaghi, # 38 Decl of Pegah Jalali Asheghabadi, # 39 3rd Decl of Rovy Branon, # 40 5th Decl of Asif Chaudhry, # 41 Decl of Maryam Dadkhahan, # 42 Decl of Jason Detwiler, # 43 2nd Decl of David Eaton, # 44 Decl of Kiana Ehsani, # 45 Decl of Ali Farhadi, # 46 Decl of Hoda Farhadi, # 47 Decl of Maryam Fayazi, # 48 Decl of Mohammad Ghaedi, # 49 Decl of Anne Greenbaum, # 50 Decl of Hannaneh Hajishirzi, # 51 2nd Decl of Deirdre Heatwole, # 52 Decl of Parisa Hosseinzadeh, # 53 Decl of Adam Mokhalalati, # 54 Decl of Shima Nofallah, # 55 4th Decl of Jeffrey Riedinger, # 56 Decl of Solmaz Shakerifard, # 57 Decl of Khadijeh Sheikhan, # 58 Decl of Ali Shojaie, # 59 Decl of Hema Yoganarasimhan, # 60 2nd Decl of Kathy Oline, # 61 2nd Decl of Dave Soike, # 62 2nd Decl of Rita Zawaideh, # 63 2nd Decl of Mitra Akhtari, # 64 2nd Decl of Melanie de Leon, # 65 Decl of Payam Fotouhiyehpour, # 66 2nd Decl of Marc Overbeck, # 67 2nd Decl of Sana Parsian, # 68 Decl of Sahar Z. Zangenah, # 69 2nd Decl of Dennis Galvan, # 70 Proposed Order) Noting Date 10/16/2017, (Melody, Colleen)

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1 THE HONORABLE JAMES L. ROBART 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 STATE OF WASHINGTON; STATE 10 OF CALIFORNIA; STATE OF MARYLAND; COMMONWEALTH 11 OF MASSACHUSETTS; STATE OF NEW YORK; and STATE OF 12 OREGON, 13 14 Plaintiffs, CIVIL ACTION NO. 2:17-cv-00141-JLR [PROPOSED] ORDER GRANTING MOTION FOR LEAVE TO FILE THIRD AMENDED COMPLAINT 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, 20 21 22 23 24 25 26 Defendants. Plaintiff States of Washington, California, Maryland, New York, Oregon, and the Commonwealth of Massachusetts (“States”) request leave to file a Third Amended Complaint. Having considered the motion and Third Amended Complaint, and Defendants’ response, if any, the Court GRANTS leave to amend. The Clerk is hereby directed to file the States’ Third Amended Complaint. [PROPOSED] ORDER GRANTING MOTION FOR LEAVE TO FILE THIRD AMENDED COMPLAINT 1 Attorney General of Washington 800 Fifth Avenue, Suite 2000 Seattle, WA 98104-3176 (206) 464-7744 1 IT IS SO ORDERED. 2 3 DATED this _____ day of October, 2017. 4 _______________________________ UNITED STATES DISTRICT JUDGE 5 6 7 8 Presented by: 9 10 11 12 13 14 15 16 17 18 19 _/s/ Noah G. Purcell_________________ BOB FERGUSON, WSBA #26004 Attorney General NOAH G. PURCELL, WSBA #43492 Solicitor General COLLEEN M. MELODY, WSBA #42275 Civil Rights Unit Chief ANNE E. EGELER, WSBA #20258 Deputy Solicitor MARSHA CHIEN, WSBA #47020 PATRICIO A. MARQUEZ, WSBA #47693 Assistant Attorneys General Office of the Attorney General 800 Fifth Avenue, Suite 2000 Seattle, WA 98104 (206) 464-7744 Noahp@atg.wa.gov 20 21 22 23 24 25 26 [PROPOSED] ORDER GRANTING MOTION FOR LEAVE TO FILE THIRD AMENDED COMPLAINT 2 Attorney General of Washington 800 Fifth Avenue, Suite 2000 Seattle, WA 98104-3176 (206) 464-7744

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