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)

Exhibit 1

From:
To:
Cc:
Subject:
Date:

Melody, Colleen (ATG)
[e-mail]
Clinton, Laura (ATG)
2:18-cv-939-MJP: Conference re: discovery motion
Friday, June 29, 2018 12:06:19 PM

Kerry:
I am counsel of record for Washington State in State of Washington v. United States, No. 2:18-cv-939-MJP, a suit
filed Tuesday and served Wednesday in the Western District of Washington. The suit challenges several policies
involving family separation and detention by federal immigration officials.
I write to confer regarding the Plaintiff States’ planned request to the Court for expedited discovery. The motion will
request that the Court set an expedited discovery schedule so that Plaintiffs may obtain discovery about separated
parents and children in our States, the processing of asylum applications at the southern border, and the current
process(es) ICE and HHS are using to reunify families. The motion will further request an order requiring that
Defendants cooperate with the Plaintiff States in providing access to detained parents in their respective
jurisdictions, if such parents wish to speak with State investigators, and an order setting weekly status conferences
during the period of expedited discovery. We plan to file the motion Monday.
After reaching out to the Western District of Washington yesterday and today, we understand that the case may be
handled out of D.C. and I may need to confer with counsel there.
I hope that DOJ would consider stipulating to this request. If DOJ is not open to stipulation, I request a statement of
the government’s position on the motion.
Sincerely,
Colleen
Colleen M. Melody
Civil Rights Unit Chief
Office of the Washington State Attorney General
800 Fifth Avenue, Suite 2000
Seattle, WA  98104
[phone]