Declaration, State of Washington v. DeVos, No. 2:20-cv-01119 (W.D. Wash.), Doc. 12 (July 23, 2020)
Summary
Declaration of Paul M. Crisalli, an Assistant Attorney General with the Complex Litigation Division of the Washington State Attorney General's Office, in support of the motion for preliminary injunction in State of Washington v. DeVos, Case 2:20-cv-01119-BJR, U.S. District Court, Western District of Washington, Document 12, filed July 23, 2020. It attaches Exhibit 1, Proclamation by the Governor 20-05, and Exhibit 2, Proclamation by the Governor 20-09.1 (closing schools). Exhibits 3 and 4 are news articles from KING5 News and the Seattle Times, and Exhibit 5 is U.S. Department of Education non-regulatory guidance on equitable services dated October 7, 2019. The declaration is signed /s/ Paul M. Crisalli.
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“Declaration, State of Washington v. DeVos, No. 2:20-cv-01119 (W.D. Wash.), Doc. 12 (July 23, 2020).”
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Case 2:20-cv-01119-BJR Document 12 Filed 07/23/20 Page 1 of 3
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6 UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
7 AT SEATTLE
8 STATE OF WASHINGTON, NO. 2:20-cv-01119-MLP
9 Plaintiff, DECLARATION OF
PAUL M. CRISALLI IN SUPPORT
10 v. OF MOTION FOR PRELIMINARY
INJUNCTION
11 BETSY DeVOS, in her official capacity as
Secretary of the United States Department of
12 Education; and the UNITED STATES
DEPARTMENT OF EDUCATION, a federal
13 agency,
14 Defendants.
15
16 I, PAUL M. CRISALLI, hereby declare as follows:
17 1. I am over the age of 18, competent to testify as to the matters herein, and make
18 this declaration based on my personal knowledge. I am currently employed as an Assistant
19 Attorney General with the Complex Litigation Division of the Washington State Attorney
20 General’s Office. I am one of the attorneys assigned to represent the Plaintiff in this matter.
21 2. Attached hereto as Exhibit 1 is a true and correct copy of the State of Washington
22 Office of the Governor, Proclamation by the Governor 20-05, available at
23 https://www.Governor.wa.gov/sites/default/files/proclamations/20-
24 05%20Coronavirus%20%28final%29.pdf (last visited July 22, 2020).
25 3. Attached hereto as Exhibit 2 is a true and correct copy of State of Washington
26 Office of the Governor, Proclamation by the Governor 20-09.1 (closing schools), available at
DECLARATION OF PAUL M. CRISALLI 1 ATTORNEY GENERAL OF WASHINGTON
Complex Litigation Division
NO. 2:20-CV-01119 800 5th Avenue, Suite 2000
Seattle, WA 98104-3188
(206) 464-7744
Case 2:20-cv-01119-BJR Document 12 Filed 07/23/20 Page 2 of 3
1 https://www.governor.wa.gov/sites/default/files/proclamations/20-09.1%20-%20COVID-
2 19%20School%20Closure%20Extension%20%28tmp%29.pdf 9 (last visited July 22, 2020).
3 4. Attached hereto as Exhibit 3 is a true and correct copy of an article authored by
4 Drew Mikkelsen, No school for Washington students, but districts are giving out free meals,
5 KING5 NEWS (5:43 PM PDT, March 16, 2020), available at
6 https://www.king5.com/article/news/local/no-school-for-washington-students-but-districts-are-
7 giving-out-free-meals/281-d90d37a3-b151-4494-9d6e-8a45da0aa970.
8 5. Attached hereto as Exhibit 4 is a true and correct copy of an article authored by
9 Gene Balk, More than 1 in 5 Seattle students are enrolled in private schools, among the highest
10 in the nation, Seattle Times (6:00 AM PDT, July 13, 2020), available at
11 https://www.seattletimes.com/seattle-news/data/more-than-1-in-5-seattle-students-are-enrolled-
12 in-private-schools-among-highest-in-nation/ (last accessed July 22, 2020).
13 6. Attached hereto as Exhibit 5 is a true and correct copy of U.S. Department of
14 Education, Title I, Part A of the Elementary and Secondary Education Act of 1965, as Amended
15 by the Every Student Succeeds Act: Providing Equitable Services to Eligible Private Schools
16 Children, Teachers, and Families Updated Non-Regulatory Guidance (October 7, 2019),
17 available at https://www2.ed.gov/about/inits/ed/non-public-education/files/equitable-services-
18 guidance-100419.pdf (last accessed July 23, 2020).
19 I declare under penalty of perjury under the laws of the State of Washington and the
20 United States that the foregoing is true and correct.
21 DATED this 23rd day of July 2020, at Seattle, Washington
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/s/ Paul M. Crisalli
23 PAUL M. CRISALLI, WSBA No. 40681
Assistant Attorney General
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DECLARATION OF PAUL M. CRISALLI 2 ATTORNEY GENERAL OF WASHINGTON
Complex Litigation Division
NO. 2:20-CV-01119 800 5th Avenue, Suite 2000
Seattle, WA 98104-3188
(206) 464-7744
Case 2:20-cv-01119-BJR Document 12 Filed 07/23/20 Page 3 of 3
1 DECLARATION OF SERVICE
2 I declare that I caused a copy of the foregoing document to be served by:
3 Hand-delivered:
4
U.S. Attorney’s Office
5 700 Stewart Street, Suite 5220
Seattle, WA 98101
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FedEx Overnight:
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Betsy DeVos
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Secretary of U.S. Department of Education
9 U.S. Department of Education
Department of Education Building
10 400 Maryland Avenue SW
Washington, DC 20202-1475
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12 U.S. Department of Education
Department of Education Building
13 400 Maryland Avenue SW
Washington, DC 20202-1475
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DATED this 23rd day of July 2020, at Seattle, Washington.
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16 /s/ Paul M Crisalli
PAUL M. CRISALLI, WSBA No. 40681
17 Assistant Attorney General
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DECLARATION OF PAUL M. CRISALLI 3 ATTORNEY GENERAL OF WASHINGTON
Complex Litigation Division
NO. 2:20-CV-01119 800 5th Avenue, Suite 2000
Seattle, WA 98104-3188
(206) 464-7744
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