State of Washington et al v. United States of America et al

Filing 16

DECLARATION of Laura K. Clinton filed by Plaintiff State of Washington re #15 MOTION to Expedite Discovery and Regular Staus Conferences (Attachments: #1 Exhibit A-P)(Clinton, Laura)

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The Honorable Marsha J. Pechman

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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STATE OF WASHINGTON, et al.,

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Plaintiffs,

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v.

NO. 2:18-cv-00939-MJP
DECLARATION OF LAURA K.
CLINTON IN SUPPORT OF MOTION
TO EXPEDITE

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THE UNITED STATES OF AMERICA;
DONALD TRUMP, in his official capacity as
President of the United States of America,
et al.,

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Defendants.

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I, Laura K. Clinton, declare as follows:

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1.

I am over the age of 18 and have personal knowledge of all the facts stated herein.

2.

I am an Assistant Attorney General and counsel of record for the State of

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Washington in this matter.
3.

Attached hereto as Exhibit A is a true and correct copy of the June 7, 2018 letter

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of Governor Jay Inslee and Washington State Attorney General Bob Ferguson to Annette L.

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Hayes, Acting United States Attorney; Dan Sprout, Warden, Federal Detention Center-Sea Tac;

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DECLARATION OF LAURA K.
CLINTON
2:18-cv-00939-MJP

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

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and Bryan Wilcox, Acting Seattle Field Officer Director for

Immigration and Customs

Enforcement.
4.

Attached hereto as Exhibit B is a true and correct copy of the June 18, 2018,

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letter of Governor Jay Inslee and Washington State Attorney General Bob Ferguson to U.S.

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Attorney General Jefferson Sessions and Department of Homeland Security (DHS) Secretary

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Kirstjen Nielsen.

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5.

Attached hereto as Exhibit C is a true and correct copy of the June 19, 2018,

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letter to U.S. Attorney General Sessions and DHS Secretary Nielsen, signed by the Attorneys

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General of New Mexico, California, Connecticut, Delaware, District of Columbia, Hawaii,

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Illinois, Iowa, Maine, Maryland, Massachusetts, Minnesota, New Jersey, New York, North

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Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, Virginia, and Washington.

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6.

Attached as Exhibit D is a true and correct copy of the June 25, 2018, Department

of Health and Human Services (HHS) Assistant Secretary of Preparedness and Response’s map

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entitled “Separated UAC Count by State.”
7.

Attached as Exhibit E is a true and correct copy of the June 21, 2018, Temporary

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Restraining Order and Order to Show Cause [4] entered in Gustavo Rodriguez Castillo, et al. v.

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Kirstjen Nielsen, et al., Case No. CV 5:18-01317-ODW-MAA (C.D. Cal.), Dkt. 10.

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8.

Attached as Exhibit F is a true and correct copy of the June 24, 2018, New York

Times article, More Than 500 Migrant Children Reunited With Adults, Government Says,

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authored by Jennifer Jett and Mihir Zaveri.
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Attached as Exhibit G is a true and correct copy of the June 21, 2018, Politico

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article, Feds don’t have enough beds for migrant families, authored by Ted Hesson and Wesley

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Morgan.

DECLARATION OF LAURA K.
CLINTON
2:18-cv-00939-MJP

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

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10.

Attached as Exhibit H is a true and correct copy of the June 25, 2018, Bloomberg

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article, Border Patrol Halts Prosecution of Families Crossing Illegally, authored by Shannon

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Pettypiece and Toluse Olorunnipa.

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11.

Attached as Exhibit I is a true and correct copy of the June 25, 2018, Press

Briefing by Press Secretary Sarah Sanders.
12.

Attached as Exhibit J is a true and correct copy of the June 24, 2018, tweet of

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President Donald Trump.
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Attached as Exhibit K is a true and correct copy of the June 22, 2018, letter to

Inspectors General Kelly and Levinson signed by more than 120 Democratic lawmakers.
14.

Attached as Exhibit L is a true and correct copy of the June 22, 2018, letter from

Representative Elijah Cummings and several other members from the House Oversight
Committee to DHS Secretary Kirstjen Nielsen, HHS Secretary Alex Azar, and Attorney General
Jeff Sessions.

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15.

Attached as Exhibit M is a true and correct copy of the June 27, 2018, letter from

over 75 lawmakers to HHS Secretary Alex Azar and Director of Office of Refugee Resettlement
Scott Lloyd.
16.

Attached as Exhibit N is a true and correct copy of the June 21, 2018, Washington

Post article, The chaotic effort to reunite immigrant parents with their separated kids, authored
by Kevin Sieff.

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17.

Attached as Exhibit O is a true and correct copy of the June 24, 2018, New York

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Times Article, Teenager Is Missing After Walking Away From Migrant Children’s Center in
Texas, authored by Mihir Zaveri and Manny Fernandez.

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DECLARATION OF LAURA K.
CLINTON
2:18-cv-00939-MJP

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

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18.

Attached as Exhibit P is a true and correct copy of the June 29, 2018, Notice of

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Compliance filed by Defendants in Flores, et al. v. Sessions, et al., Case No. CV 85-4544-DMG

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(C.D. Cal.), Dkt. 447.

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I declare under penalty of perjury under the laws of the State of Washington and the
United States of America that the foregoing is true and correct.
DATED this 2nd day of July, 2018, at Seattle, Washington.

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/s/ Laura K. Clinton
LAURA K. CLINTON
Assistant Attorney General

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DECLARATION OF LAURA K.
CLINTON
2:18-cv-00939-MJP

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