Case 2:20-cv-00887-RAJ Document 20-1 Filed 06/10/20 Page 1 of 3

The Honorable Richard A. Jones

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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BLACK LIVES MATTER SEATTLE-KING
COUNTY, ABIE EKENEZAR, SHARON
SAKAMOTO, MURACO KYASHNATOCHA, ALEXANDER WOLDEAB,
NATHALIE GRAHAM, AND ALEXANDRA
CHEN,

No.

2:20-CV-00887 RAJ

[PROPOSED] ORDER ENTERING
TEMPORARY RESTRAINING ORDER

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Plaintiffs,
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vs.
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CITY OF SEATTLE,
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Defendant.
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This matter having come before the Court on the Plaintiffs’ Motion for Temporary Restraining

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Order (“TRO”) and The City of Seattle’s (“City”) Notice of Intent to File Opposition with supporting

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Declarations:

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After consideration of the Plaintiffs’ Motion for TRO, the City’s counter-proposed language
for entry of a TRO, and recent decisions of other United States Federal District Courts in Denver,
Minneapolis, and Portland, and pursuant to Federal Rule of Civil Procedure 65 and Local Civil Rule

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65, the Court enters a temporary restraining order and ENJOINS the City of Seattle as follows:
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ORDER ENTERING TEMPORARY RESTRAINING ORDER
(20-cv-00887RAJ) - 1

Peter S. Holmes
Seattle City Attorney
701 5th Avenue, Suite 2050
Seattle, WA 98104-7095
(206) 684-8200

 Case 2:20-cv-00887-RAJ Document 20-1 Filed 06/10/20 Page 2 of 3

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The City of Seattle, including the Seattle Police Department and any other
officers, departments, agencies, or organizations under the Seattle Police
Department’s control (collectively, “the City”), is hereby enjoined from
employing chemical weapons or projectiles of any kind against persons
engaging in peaceful protests or demonstrations. This injunction includes: (1)
any chemical irritant such as and including CS Gas (“tear gas”) and OC Gas
(“pepper spray”) and (2) any projectile such as and including flash-bang
grenades, “pepper balls,” “blast balls,” and rubber bullets, unless the incident
commander or above-ranking member of command staff specifically authorizes
such use of force in response to specific acts of violence creating likely
imminent physical harm to an individual(s). This Order does not preclude
individual officers from taking reasonable, necessary, and proportional action
to protect against imminent threat of physical harm to themselves or identifiable
others, including the deployment of OC spray.

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Under Fed. R. Civ. P. 65(b)(2), this Order will expire fourteen days after entry unless extended
by the Court for good cause.

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DATED this ___________________ day of June, 2020.

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By:______________________________________
HON. RICHARD A. JONES
United States District Judge

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Presented by:
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PETER S. HOLMES
Seattle City Attorney

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By: /s/ Ghazal Sharifi
Ghazal Sharifi, WSBA# 47750
Carolyn Boies, WSBA# 40395
Assistant City Attorneys
E-mail: Ghazal.Sharifi@seattle.gov
E-mail: Carolyn.Boies@seattle.gov
Seattle City Attorney’s Office
701 Fifth Avenue, Suite 2050
Seattle, WA 98104
Phone: (206) 684-8200
Attorney for Defendant City of Seattle

ORDER ENTERING TEMPORARY RESTRAINING ORDER
(20-cv-00887RAJ) - 2

Peter S. Holmes
Seattle City Attorney
701 5th Avenue, Suite 2050
Seattle, WA 98104-7095
(206) 684-8200

 Case 2:20-cv-00887-RAJ Document 20-1 Filed 06/10/20 Page 3 of 3

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CERTIFICATE OF SERVICE

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I hereby certify that on June 10, 2020, I caused the preceding PROPOSED ORDER ENTERING
TEMPORARY RESTRAINING ORDER to be electronically filed with the Clerk of the Court using
the CM/ECF system, which will send notice of such filing to all known counsel of record.
DATED this 10th day of June, 2020.

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_s/Jennifer Liftin________
Jennifer Liftin, Legal Assistant

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ORDER ENTERING TEMPORARY RESTRAINING ORDER
(20-cv-00887RAJ) - 3

Peter S. Holmes
Seattle City Attorney
701 5th Avenue, Suite 2050
Seattle, WA 98104-7095
(206) 684-8200