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
SAJJAD TOPIWALA

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The Honorable James Robart
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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10 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
14 capacity as President of the United
States; U.S. DEPARTMENT OF
15 HOMELAND SECURITY; JOHN F.
KELLY, in his official capacity as
16 Secretary of the Department of
Homeland Security; TOM SHANNON,
17 in his official capacity as Acting
Secretary of State; and the UNITED
18 STATES OF AMERICA,
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CIVIL ACTION NO. 2:17-cv-00141-JLR

DECLARATION OF SAJJAD
TOPIWALA

Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, SAJJAD TOPIWALA, hereby declare as follows:
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1. I am over the age of 18 and competent to be a witness. I am a resident of the State of
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Washington.
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2. I am the Treasurer of Noor360, Inc.
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3. Noor360 is a travel company that arranges pilgrimages to Iraq. For the Shiite people of
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Islam, the pilgrimage is meant to pay our respect to the grandson of the prophet of
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DECLARATION OF SAJJAD TOPIWALA

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Mohamad. On the trip, Noor360 arranges visits to approximately seven to eight shrines

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located in Najaf, Karbala, and other cities in Iraq.

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4. In 2015 and 2016, Noor360 arranged trips for approximately fifty people each year taking

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pilgrimages to Iraq. At the time the Executive Order issued on January 27, 2017, Noor360

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was accepting registration for the 2017 trip, which was planned to depart on March 31,

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2017.

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5. At the time the Executive Order issued, the company had more than twenty people signed

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up for the trip leaving on March 31, 2017. As far as I know, the people who had signed up

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were U.S. citizens and legal permanent residents from Pakistan and India.

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6. When the Executive Order issued, however, many people were afraid to leave the United

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States and cancelled their registration. So many people cancelled their registration that our

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company had to cancel the trip altogether.

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7. At the time the Executive Order issued, the company had purchased four non-refundable

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tickets for its management. I was planning to take the March 31, 2017, trip as a manager.

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Many of the people signed up for the trip had also purchased their ticket. Each ticket cost

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approximately $1,200.

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8. As I stated above, Noor360 is a company that arranges pilgrimages to Iraq.

The

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President’s Executive Order prevented at least 20 Muslims from traveling to conduct their

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religious pilgrimage and has prevented them and me of Noor360 from practicing our faith.

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9. In addition, by forcing Noor360 to cancel our pilgrimage to Iraq, the Executive Order has

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also had a significant negative financial impact on Noor360, as Noor360 had already paid

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for the trips of its managers and lost money it anticipated from the March 2017

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pilgrimage.

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

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DECLARATION OF SAJJAD TOPIWALA