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 MICHAEL SAUNDERS 1 2 The Honorable James Robart 3 4 5 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 10 STATE OF WASHINGTON and STATE OF MINNESOTA, 11 Plaintiffs, 12 CIVIL ACTION NO. 2:17-cv-00141-JLR v. 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 TILLERSON, in his official capacity as Secretary of State; and the UNITED STATES OF AMERICA, 19 20 21 DECLARATION OF MICHAEL SAUNDERS Defendants. Pursuant to 28 U.S.C. § 1746(2), I, Michael Saunders, hereby declare as follows: 1. I am over the age of eighteen and competent to testify. 2. I am Corporate Counsel for Redfin Corporation (“Redfin”). I work at Redfin’s 22 23 24 25 Seattle headquarters. I have personal knowledge of the matters stated herein, and if called as a witness, I could and would testify competently thereto. 26 DECLARATION OF MICHAEL SAUNDERS 1 2 3 3. Redfin is a Seattle-based technology-powered residential real estate brokerage representing homebuyers and sellers in over 80 markets throughout the United States. 4. Redfin has helped customers buy or sell more than 75,000 homes worth more 4 than $40 billion since its inception. 5 6 7 The Executive Orders Run Contrary to Redfin’s Values 5. Redfin’s mission is to serve others in their search for a new home, including 8 those who have traveled the farthest to do so. This is consistent with Redfin’s culture of 9 respecting one another’s differences, including differences in national origin and religion. As 10 11 Redfin’s CEO, Glenn Kelman, stated in response to President Trump’s January 27, 2017 Executive Order on foreign travel: “No one will make you feel unwelcome here [at Redfin].” 12 13 14 15 16 17 18 6. Because of these values, Redfin has chosen to join with others in the real estate and technology industries in opposing President Trump’s January 27, 2017 and March 6, 2017 Executive Orders on foreign travel (collectively “the Executive Orders”). The Executive Orders are Harmful to Redfin’s Business 7. Not only do the Executive Orders run contrary to Redfin’s mission and culture, they are also harmful to Redfin’s business. We are aware of at least five potential Redfin 19 customers who have decided not to purchase a house due to concerns about U.S. immigration 20 21 policy arising from President Trump’s Executive Orders on foreign travel. Redfin loses 22 potential revenue each time a customer ends his or her homebuying search before buying a 23 home. 24 25 8. In January 2017 a Redfin agent in Orange County, California was assisting a United Arab Emirates (“UAE”) citizen, and former contract worker for the U.S. government 26 DECLARATION OF MICHAEL SAUNDERS 1 in Afghanistan, in making a cash offer to buy a home listed for $1,000,000. After the offer was 2 accepted and the buyer was arranging to close the sale, he learned he would need to appear in 3 the UAE to initiate the money transfer. He cancelled his home purchase, worried he could not 4 return to the United States if he left to complete the money transfer. 5 6 9. Another Redfin agent in Los Angeles was working with a customer interested in 7 purchasing a home listed for $775,000. On January 30, 2017 this customer cancelled her home 8 search by sending the following email: 9 10 11 12 13 14 15 We are deeply shaken with the way Trump is alienating immigrants in this country. … Me and my husband are from Turkey which is also a muslim majority country. We are currently on L-1 visa and in the process of getting our green card. And we just received news claiming that Trump's policy will also cover L-1 visa owners as well. In that case, we are not even sure how this is going to impact our green card application process.… We love the home and we want to make the offer, but under the light of current events, we can't decide the next steps before making sure that Trump’s policy won't impact us. 10. In January 2017 a Redfin real estate agent was helping a husband and wife find a home near Boston. These Redfin customers immigrated to the United States from India and 16 17 18 have lived in the United States for more than four years. With Redfin’s help they made an offer, which was accepted, to purchase a $570,000 home. These homebuyers withdrew their 19 offer after President Trump’s January 27 Executive Order. They were concerned about the 20 federal government’s immigration policies. 21 22 11. A Redfin agent in Seattle had been assisting a homebuyer customer from Bangladesh since November 2016 with his search to find a condominium in the $300,000 to 23 $400,000 range. On February 1, 2017, this customer told the agent he was canceling his 24 25 26 search due to concerns he might be deported under a possible expansion of President Trump’s Executive Order. DECLARATION OF MICHAEL SAUNDERS

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