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

Filing 4

DECLARATION OF NOAH PURCELL re 3 Emergency MOTION for Temporary Restraining Order by Plaintiff State of Washington (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit)(Purcell, Noah)

1 ROBERT W. FERGUSON
WSBA #26004
2 Attorney General
3 NOAH G. PURCELL
WSBA #43492
4 Solicitor General
COLLEEN M. MELODY
5 WSBA #42275
Civil Rights Unit Chief
6 Office of the Attorney General
7 800 Fifth Avenue, Suite 2000
Seattle, WA 98104
8 206-464-7744
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON,
Plaintiff,
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v.
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CIVIL ACTION NO.

DONALD TRUMP, in his official
capacity as President of the United
States; U.S. DEPARTMENT OF
HOMELAND SECURITY; JOHN F.
KELLY, in his official capacity as
Secretary of the Department of
Homeland Security; TOM
SHANNON, in his official capacity
as Acting Secretary of State; and the
UNITED STATES OF AMERICA,

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DECLARATION OF NOAH G.
PURCELL IN SUPPORT OF MOTION
FOR TEMPORARY RESTRAINING
ORDER

Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Noah G. Purcell, hereby declare as follows:
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1.

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 as a

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representative of the State of Washington (“State”) in support of the Motion for
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Temporary Restraining Order filed concurrently herewith.
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ATTORNEY GENERAL OF WASHINGTON
Civil Rights Unit
800 Fifth Avenue, Suite 2000
Seattle, WA 98104
[phone]

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3.

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caused an attorney on my staff to call the offices of the United States Attorney for the

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Western District of Washington to provide notice of the State’s intent to file a Motion

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for Temporary Restraining Order later that afternoon, and to note it for hearing on

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January 30, 2017, the same day.
4.

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Washington 98101, [phone].
5.

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6.

No one from the Federal Programs Division has contacted counsel for the State.

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A member of my staff queried and downloaded publicly available data from the U.S.
Census website regarding the number of non-citizen immigrants from Iran, Iraq, Libya,

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Somalia, Sudan, Syria, and Yemen (the seven (7) countries listed in the President’s

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Executive Order on immigration) residing in the State of Washington. Attached hereto

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as Purcell Declaration Exhibit A is a table prepared by my staff member reflecting

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that data.
8.

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Attached hereto as Purcell Declaration Exhibit B is a true and correct copy of an
online printout of a news article from NPR dated January 27, 2017 titled “Trump’s

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Ms. Keef advised that Defendants will be represented by attorneys within the Federal
Programs Division of the United States Department of Justice in Washington, D.C.

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Counsel for the State spoke with Kerry Keef, Civil Chief, United States Attorney’s
Office, Western District of Washington, 700 Stewart Street, Suite 5220, Seattle,

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Pursuant to Western District of Washington Local Rule 65(b)(1), on January 30, 2017, I

Immigration Freeze Omits Those Linked To Deadly Attacks in U.S.”
9.

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Attached hereto as Purcell Declaration Exhibit C is a true and correct copy of an
online printout of a news article dated December 9, 2015 titled “Trump spokeswoman:

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‘So What? They’re Muslim.”

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I declare under penalty of perjury that the foregoing is true and correct.
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ATTORNEY GENERAL OF WASHINGTON
Civil Rights Unit
800 Fifth Avenue, Suite 2000
Seattle, WA 98104
[phone]

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Executed this 30th day of January, 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
[phone]

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ATTORNEY GENERAL OF WASHINGTON
Civil Rights Unit
800 Fifth Avenue, Suite 2000
Seattle, WA 98104
[phone]