State of Washington, et al., v. Trump., et al
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)
The Honorable James Robart
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
10 STATE OF WASHINGTON and
STATE OF MINNESOTA,
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,
CIVIL ACTION NO. 2:17-cv-00141-JLR
DECLARATION OF SAJJAD
Pursuant to 28 U.S.C. § 1746(2), I, SAJJAD TOPIWALA, hereby declare as follows:
1. I am over the age of 18 and competent to be a witness. I am a resident of the State of
2. I am the Treasurer of Noor360, Inc.
3. Noor360 is a travel company that arranges pilgrimages to Iraq. For the Shiite people of
Islam, the pilgrimage is meant to pay our respect to the grandson of the prophet of
DECLARATION OF SAJJAD TOPIWALA
Mohamad. On the trip, Noor360 arranges visits to approximately seven to eight shrines
located in Najaf, Karbala, and other cities in Iraq.
4. In 2015 and 2016, Noor360 arranged trips for approximately fifty people each year taking
pilgrimages to Iraq. At the time the Executive Order issued on January 27, 2017, Noor360
was accepting registration for the 2017 trip, which was planned to depart on March 31,
5. At the time the Executive Order issued, the company had more than twenty people signed
up for the trip leaving on March 31, 2017. As far as I know, the people who had signed up
were U.S. citizens and legal permanent residents from Pakistan and India.
6. When the Executive Order issued, however, many people were afraid to leave the United
States and cancelled their registration. So many people cancelled their registration that our
company had to cancel the trip altogether.
7. At the time the Executive Order issued, the company had purchased four non-refundable
tickets for its management. I was planning to take the March 31, 2017, trip as a manager.
Many of the people signed up for the trip had also purchased their ticket. Each ticket cost
8. As I stated above, Noor360 is a company that arranges pilgrimages to Iraq.
President’s Executive Order prevented at least 20 Muslims from traveling to conduct their
religious pilgrimage and has prevented them and me of Noor360 from practicing our faith.
9. In addition, by forcing Noor360 to cancel our pilgrimage to Iraq, the Executive Order has
also had a significant negative financial impact on Noor360, as Noor360 had already paid
for the trips of its managers and lost money it anticipated from the March 2017
I declare under penalty of perjury that the foregoing is true and correct.
DECLARATION OF SAJJAD TOPIWALA