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)

DECLARATION OF
SCOTT BUELL

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The Honorable James L. Robart

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

4 STATE OF WASHINGTON and
STATE OF MINNESOTA,
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Plaintiffs,
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v.
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DONALD TRUMP, in his official
8 capacity as President of the United
States; U.S. DEPARTMENT OF
9 HOMELAND SECURITY; JOHN F.
KELLY, in his official capacity as
10 Secretary of the Department of
Homeland Security; REX W.
11 TILLERSON, in his official capacity
as Acting Secretary of State; and the
12 UNITED STATES OF AMERICA,
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CIVIL ACTION NO. 2:17-cv-00141-JLR

Defendants.
Pursuant to 28 U.S.C. § 1746(2), I, Scott S. Buell, hereby declare as follows:
1. I am over the age of 18. I have personal knowledge of the matters stated herein, and if

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called as a witness, I could and would testify competently thereto.
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2. I am Senior Legal Counsel at MongoDB, Inc. (“MongoDB”).

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3. MongoDB provides database software that combines the best of traditional databases with

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the flexibility, scale and performance modern applications need. MongoDB builds the database

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and its drivers, offers software and services, provides MongoDB University, and sponsors the

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MongoDB community. MongoDB has thousands of customers across the world and its database

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has been downloaded more than 25 million times.

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4. MongoDB was founded in 2007 and has headquarters in New York, New York and Palo
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Alto, California. We have more than 700 employees worldwide, across 27 offices in 13 countries.

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ATTORNEY GENERAL OF NEW YORK
120 Broadway
New York, NY 10271-0332

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5. MongoDB is organized around and driven by its core values. We are dedicated to

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fostering a diverse workforce and an inclusive culture, and we believe having employees from

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around the world brings out the best ideas, broadens our perspectives, and spurs innovation.
6. Hundreds of MongoDB’s employees are citizens of countries other than the United States,

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including many who are in the United States on a visa. These employees regularly travel
internationally for business and for personal reasons.

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7. MongoDB is at its core an international company. We have customers, users and

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employees around the world. We frequently host events in the United States and in foreign

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countries. MongoDB also recruits internationally in order to hire and retain our talented

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employees.

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8. MongoDB firmly believes that the Executive Order signed by President Trump on March
6, 2017, “Protecting The Nation From Foreign Terrorist Entry Into The United States,” presently

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harms and will continue to harm its ability to continue to conduct its business on this international

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scale. The Executive Order has created uncertainty regarding our international employees’

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immigration status and their ability to travel to and from the United States; it impedes our ability

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to serve our customers and users around the world and to recruit internationally; and it runs
counter to the values at the core of our company.

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9. I declare under penalty of perjury that the foregoing is true and correct.

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ATTORNEY GENERAL OF NEW YORK
120 Broadway
New York, NY 10271-0332

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Executed on this 11th day of March, 2017

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Scott S. Buell, Esq.

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ATTORNEY GENERAL OF NEW YORK
120 Broadway
New York, NY 10271-0332