State of Washington, et al., v. Trump., et al

Filing 118

Second MOTION to Amend Complaint, filed by Plaintiff State of Washington. (Attachments: # 1 Complaint Second Amended, # 2 Exhibit Exhibits to Second Amended Complaint, # 3 Index of Declarations, # 4 Decl. of R. Althaibani, # 5 Decl. of S. Amin, # 6 Decl. of B. Callaghan, # 7 Decl. of S. Dadgari, # 8 Decl. of A. Elfgeeh, # 9 Decl. of N. Fallah, # 10 Decl. of H. Ghasemzadeh, # 11 Decl. of E. Hassett, # 12 Decl. of A. Mubarez, # 13 Decl. of S. Parsian, # 14 Decl. of Z. Rasouli, # 15 Decl. of A. Shayegan, # 16 Decl. of J. Sime, # 17 Decl. of R. Branon, # 18 Decl. of A. Chaudhry, # 19 Decl. of D. Eaton, # 20 Decl. of D. Heatwole, # 21 Decl. of S. Hemmati, # 22 Decl. of R. Lewin, # 23 Decl. of A. Mehrizi-Sani, # 24 Decl. of V. Rabinowitz, # 25 Decl. of J. Riedinger, # 26 Decl. of V. Shah, # 27 Decl. of J. Wasserheit, # 28 Decl. of J. Wasserheit, # 29 Decl. of J. Wood, # 30 Decl. of N. Zimpher, # 31 Decl. of S. Buell, # 32 Decl. of R. Fullerton, # 33 Decl. of P. Johnson, # 34 Decl. of A. Lavine, # 35 Decl. of D. Pashman, # 36 Decl. of M. Rosenn, # 37 Decl. of M. Saunders, # 38 Decl. of J. Simeone, # 39 Decl. of D. Soike, # 40 Decl. of S. Topiwala, # 41 Decl. of J. Truppman, # 42 Decl. of R. Zawaideh, # 43 Decl. of M. Akhtari, # 44 Decl. of M. de Leon, # 45 Decl. of R. Eskandari, # 46 Decl. of T. Johnson, # 47 Decl. of E. Scherzer, # 48 Decl. of W. Berkovitz, # 49 Decl. of D. Duea, # 50 Decl. of L. Warren, # 51 Proposed Order) Noting Date 3/31/2017, (Melody, Colleen)

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DECLARATION OF ZEHRA RASOULI 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 10 11 STATE OF WASHINGTON, and STATE OF MINNESOTA, Plaintiffs, 12 13 14 15 16 17 18 DONALD TRUMP, in his official capacity as President of the United States; U.S. DEPARTMENT OF HOMELAND SECURITY; JOHN F. KELLY, in his official capacity as Secretary of the Department of Homeland Security; REX W. TILLERSON, in his official capacity as Secretary of State; and the UNITED STATES OF AMERICA, 19 20 21 22 23 24 25 26 CIVIL ACTION NO. 2:17-cv-00141-JLR v. DECLARATION OF ZEHRA RASOULI Defendants. Pursuant to 28 U.S.C. § 1746(2), I, Zehra Rasouli, hereby declare as follows: 1. 2. 3. 4. 5. 6. I am over the age of eighteen and competent to testify herein. I am a Washington State resident. I came to the United States from Iran on an EB-1 visa in September 2015. My EB-1 visa means that I am allowed to remain permanently in the United States. I have a husband and a fourteen-year-old daughter, but no other family here. My sister was approved for an EB-1 visa in December 2016, but she is waiting on the embassy to schedule her. 7. The President’s executive orders prevent my sister from moving to Washington on her approved EB-1 visa. DECLARATION OF ZEHRA RASOULI 1 ATTORNEY GENERAL OF WASHINGTON 800 Fifth Avenue, Suite 2000 Seattle, WA 98104-3188 (206) 464-7744 1 2 8. My sister is supposed to be moving to Washington and will live with me when she gets here. My daughter is very attached to my sister. The delay in my sister’s move is impacting me and my family. 3 4 I declare under penalty of perjury that the foregoing is true and correct. Executed on this 5 day of March, 2017 6 ___________________________________ ZEHRA RASOULI 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 DECLARATION OF ZEHRA RASOULI 2 ATTORNEY GENERAL OF WASHINGTON 800 Fifth Avenue, Suite 2000 Seattle, WA 98104-3188 (206) 464-7744

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