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

Filing 17

CERTIFICATE of Colleen M. Melody re #15 MOTION to Expedite Discovery and Regular Staus Conferences by Plaintiff State of Washington (Attachments: #1 Exhibit 1)(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,

NO. 2:18-cv-00939-MJP
CERTIFICATION OF COMPLIANCE

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v.
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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, Colleen M. Melody, 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.

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I am counsel of record for the State of Washington. On June 28 and June 29, 2018,

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I attempted to confer by phone with attorneys in the U.S. Attorney’s Office for the Western District

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of Washington, to advise Defendants of Plaintiffs’ forthcoming Motion to Expedite Discovery.

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On June 29, 2018, I conferred with Kerry Keefe. Ms. Keefe indicated that Defendants were likely

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to be represented by Department of Justice counsel based in Washington, DC, but that she did not

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have the contact information for counsel who would be appearing.

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CERTIFICATION OF COMPLIANCE
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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3.

Ms. Keefe requested that I send an e-mail containing information about Plaintiffs’

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forthcoming Motion. I sent the e-mail as requested, and a true and correct copy is attached as

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Exhibit 1 to this Certificate of Compliance.

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4.

As of 2:00 p.m. Pacific Time (5:00 p.m. Eastern) on July 2, 2018, I have not

received any further contact from Department of Justice counsel to provide Defendants’ position
with respect to Plaintiffs’ Motion.

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DATED this 2nd day of July, 2018, at Seattle, Washington.
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/s/ Colleen M. Melody
COLLEEN M. MELODY
Division Chief, Civil Rights Unit

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CERTIFICATION OF COMPLIANCE
2:18-cv-00939-MJP

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