State of Washington, et al., v. Trump., et al

Filing 194

MOTION for Leave to File Third Amended Complaint, filed by Plaintiffs Commonwealth of Massachusetts, State of California, State of Maryland, State of New York, State of Washington, Intervenor Plaintiff State of Oregon. (Attachments: # 1 Complaint 3rd Amended, # 2 Index of Exhibits, # 3 Index of Declarations, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Exhibit K, # 15 Exhibit L, # 16 Exhibit M, # 17 Exhibit N, # 18 Decl of Joint Former National Security Officials, # 19 Decl of Nima Ala, # 20 2nd Decl of Rabyaah Althaibani, # 21 Decl of Alireza Ayoubi, # 22 Decl of Shervin Beygi, # 23 Decl of Bahareh Bina, # 24 Decl of Ethan Devenport, # 25 Decl of Yasaman Esmaili, # 26 Decl of Mahdi Hajiaghayi, # 27 Decl of Mojdeh Jalali Heravi, # 28 Decl of Vahid Jazayeri, # 29 Decl of Mohammad Shafiei Khadem, # 30 Decl of Ahmad Moghaddam, # 31 Decl of Younes Nouri, # 32 Decl of Proshat Parsimoghadam, # 33 Decl of Emad Soroush, # 34 Decl of Tannaz Sattari Tabrizi, # 35 Decl of Seyed Danial Vaezi, # 36 Decl of Banafsheh Samareh Abolhasani, # 37 Decl of Armin Alaghi, # 38 Decl of Pegah Jalali Asheghabadi, # 39 3rd Decl of Rovy Branon, # 40 5th Decl of Asif Chaudhry, # 41 Decl of Maryam Dadkhahan, # 42 Decl of Jason Detwiler, # 43 2nd Decl of David Eaton, # 44 Decl of Kiana Ehsani, # 45 Decl of Ali Farhadi, # 46 Decl of Hoda Farhadi, # 47 Decl of Maryam Fayazi, # 48 Decl of Mohammad Ghaedi, # 49 Decl of Anne Greenbaum, # 50 Decl of Hannaneh Hajishirzi, # 51 2nd Decl of Deirdre Heatwole, # 52 Decl of Parisa Hosseinzadeh, # 53 Decl of Adam Mokhalalati, # 54 Decl of Shima Nofallah, # 55 4th Decl of Jeffrey Riedinger, # 56 Decl of Solmaz Shakerifard, # 57 Decl of Khadijeh Sheikhan, # 58 Decl of Ali Shojaie, # 59 Decl of Hema Yoganarasimhan, # 60 2nd Decl of Kathy Oline, # 61 2nd Decl of Dave Soike, # 62 2nd Decl of Rita Zawaideh, # 63 2nd Decl of Mitra Akhtari, # 64 2nd Decl of Melanie de Leon, # 65 Decl of Payam Fotouhiyehpour, # 66 2nd Decl of Marc Overbeck, # 67 2nd Decl of Sana Parsian, # 68 Decl of Sahar Z. Zangenah, # 69 2nd Decl of Dennis Galvan, # 70 Proposed Order) Noting Date 10/16/2017, (Melody, Colleen)

DECLARATION OF
ALIREZA AYOUBI

1
2
3
4
5
6
7
8

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

9
10

STATE OF WASHINGTON, et al.,

11
12
13

Plaintiffs,
v.

CIVIL ACTION NO. 2:17-cv-00141-JLR

DONALD TRUMP, et al.,

14

DECLARATION OF ALIREZA
AYOUBI

Defendants.

15
16
17
18
19
20

Pursuant to 28 U.S.C. § 1746(2), I, Alireza Ayoubi, hereby declare as follows:
1. I am over the age of eighteen and competent to testify herein.
2. I live in Washington State.

21

3. I am a Medical Doctor and trying to pass USMLE exames.

22

4. I am originally from Iran and went to medical school in Iran. I came to the United States

23
24

in 2014.
5. I have had a green card for the United States since 2014.

25
26
1

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

1
2
3
4
5
6
7
8
9
10
11

6. In January 2015, I got married with love and passion to one of my classmates from
medical school. We are both medical doctors. My wife lives in Iran and has never been
to the United States.
7. I applied for a green card for my wife in April 2015. She had her immigration interview
at Abudhabi in March 2017, but her case is still under administrative processing. I do
not expect her to have her green card by October 18, 2017.
8. My wife and I have been patient while we have never had enough time to start our real
life together and run our small family. She does not have a visa to come to the United
States to visit or live with me. I have travelled several times to Iran to visit her and my
family, but every goodbye has too much stress and frustration.

12
13
14

9. Me and my wife have sent emails separately to the US embassy in Abudhabi trying to
get her a visa to come to the United States, but we have not received any response.

15

10. This new travel ban would impact and separate us from each other and make everything

16

more complicated. We do not know how we can start our family if she is barred from

17

ever coming to live with me here in the United States

18

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

19
20
21

Executed on this _10th_ day of October, 2017

22
23
24
25

________________________________________
Alireza Ayoubi

26
2

ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]