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 ABDO ELFGEEH 1 The Honorable James L. Robart 2 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 3 4 STATE OF WASHINGTON and STATE OF MINNESOTA, 5 Plaintiffs, 6 CIVIL ACTION NO. 2:17-cv-00141-JLR v. 7 8 9 10 11 12 13 14 15 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 Acting Secretary of State; and the UNITED STATES OF AMERICA, Defendants. Pursuant to 28 U.S.C. § 1746(2), I Abdo Elfgeeh, hereby declare as follows: 1. I am a resident of Mohegan Lake, in Westchester County, New York State. I am a United 16 States (“U.S.”) citizen, and a Yemeni-American. 17 18 2. I came to the U.S. in 2001, as a legal permanent resident. My father came in the first wave 19 of Yemeni immigrants to the U.S. in 1966, and became a U.S. citizen in 1972. When I came to 20 the U.S., I joined my siblings and many of my cousins who reside in New York State, and who 21 are also business owners. 22 3. I studied and graduated from Empire State College and obtained a Bachelor of Science 23 degree in Business Administration in 2004. I am forty-two years old, and am currently 24 employed as an Automated Teller Machine (“ATM”) sales representative. 25 26 1 ATTORNEY GENERAL OF NEW YORK 120 Broadway New York, NY 10271-0332 1 4. The Executive Order issued on January 27, 2017, entitled “Protecting the Nation from 2 Foreign Terrorist Entry into the United States,” has left me fearful and uncertain about whether 3 I can re-unite with my wife and four children, who are stranded in Sana’a, Yemen. The new 4 Order issued on March 6, 2017, did not change any of this uncertainty. 5 6 5. Respectively, my children are, 19 years old, 17 years old, 16 years old, and 9 years 7 old. They are all currently living in Sana’a, until they hear about the status of visa applications. 8 6. My wife and first three children are waiting for their I-130 (Petition for Alien Relative) visa 9 applications to be approved so that our family can be re-united, and everyone can be safe. My 10 wife and the 16-year old’s applications were submitted in June 2014, while the 17 and 19 year 11 olds’ applications were submitted in April 2016. The 9-year-old is a U.S. citizen, because she 12 13 14 was born in 2008, after I became a U.S. citizen. 7. My wife and the 16-year old’s visas were partially processed since they were submitted in 15 2014. I attended an interview with United States Citizenship and Immigration Services 16 (“USCIS”), as part of the processing of their applications – and was told that their applications 17 would not be approved until the applications for my other two children were approved. 18 8. Since the passage of the Orders I have been trying to contact appropriate agencies to 19 get information on the status of my family’s visa applications. I have not been able to get in 20 21 22 23 contact with anyone. The 90-day ban on Yemeni-nationals entering the U.S., which is in both Executive Orders, has left me with no guarantee that my family’s visa applications will even continue to be processed. 24 25 26 2 ATTORNEY GENERAL OF NEW YORK 120 Broadway New York, NY 10271-0332 10 Scanned by CamScanner

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