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
SHERVIN BEYGI

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON, et al.,

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Plaintiffs,
v.

CIVIL ACTION NO. 2:17-cv-00141-JLR
DECLARATION OF SHERVIN BEYGI

DONALD TRUMP, et al.,

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Defendants.

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

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3. I am a US citizen.

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4. I am personally impacted and deeply hurt by the President’s September 24, 2017

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Proclamation.

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5. I came to the US in 2002 to pursue my graduate studies. I received my Ph.D. in
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engineering from the University of Michigan in 2008. I now work in Seattle as a Data

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

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Scientist for Boeing, creating cutting-edge aviation solutions that benefits our nation’s

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safety and economy. Prior to that, I worked for the Department of Veterans Affairs,

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focusing on improving the system of care for our nation’s veterans.

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6. My aging parents still live in Iran. They were both negatively impacted by Iran’s

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Islamic revolution in 1979, my father lost his job because he allegedly was not Islamic

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enough, and my mother could not get promoted for about 15 years because she was a

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woman. They struggled for years to make ends meet in order to raise me and my sister.

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I was hoping I could finally bring my parents here to live with me after all they went

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through. Now with the new travel ban, my hopes are fading. Neither they nor my sister
would ever be able to come visit me here, because they are considered a threat to our

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national security. Such a painful irony. Even though I have worked hard, played by the
rules, used my advanced skills to serve this country and paid taxes, I do not get to enjoy
the same rights as other citizens.

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7. When the prior versions of the travel ban were blocked, it reinstated my confidence in

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the American judicial system. This new version is inhumane, discriminatory, and

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indefinite. It discriminates based on people’s place of birth. I am deeply disappointed.

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How can I call this country my home when my immediate family is banned from it

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indefinitely while neither they nor I have done anything wrong?
8. I am deeply disturbed by this new draconian travel ban. It impacts me, my work, and

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my future plans to stay in the US, contribute and serve. I am worried that I will not be

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able to take care of my parents if something happens to them. I am not sure if they can

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stay in a safe and healthy environment back in Iran. For the past 12 years, I called the

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

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US home, and felt proud of it. I don’t want to leave it. But once this new ban takes

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effect, I will be left with no choice other than leaving. Even thinking about this breaks

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my heart.

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

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Executed on this 6th day of October, 2017
________________________________________
Shervin Beygi

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