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
ETHAN
DEVENPORT

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
14

Plaintiffs,
v.

CIVIL ACTION NO. 2:17-cv-00141-JLR
DECLARATION OF ETHAN
DEVENPORT

DONALD TRUMP, et al.,
Defendants.

15
16
17

Pursuant to 28 U.S.C. § 1746(2), I, Ethan Devenport, hereby declare as follows:

18

1. I am over the age of eighteen and competent to testify herein.

19

2. I am a Washington State resident and currently reside in Washington State.

20
21
22
23

3. I am a United States citizen, born in rural Caldwell, Idaho and now living in Seattle where
I presently own a condo.
4. I am a co-founder and co-owner of a technology company registered in Washington

24

State. The incorporated company employs five Washington State residents including

25

myself, pays Washington State taxes, and organizes technology-related community

26
1

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

1

events in the Seattle area for the purpose of sharing knowledge on current and upcoming

2

technology.

3
4
5
6
7
8
9
10
11

5. My fiancé is an Iranian citizen currently residing in Tehran, Iran.
6. Since we met in October 2015, my fiancée and I have talked nearly everyday, mornings
and evenings. We schedule trips to meet each other whenever possible; Northern Cyprus,
Armenia, Turkey, Bosnia & Herzegovina, and Georgia.
7. We have shared cultural traditions by spending 2016 Christmas and 2017 New Year's in
Istanbul together and 2017 Nowruz in Sarajevo together.
8. We decided to marry early in 2017 and immediately began the K-1 visa process. The
Petition for Alien Fiancé was submitted September 7, 2017.

12
13
14

9. We spent a week in September 2017 in Tbilisi, Georgia where I bought my fiancée an
engagement ring.

15

10. The President’s September 24, 2017 Proclamation directly impacts our intentions to

16

marry and spend our lives together in Seattle, Washington. We are both very worried.

17

11. The newest travel ban will deny my fiancée travel to the United States and would deny

18
19
20
21
22

her family from visiting her in the United States when we are married. The ban would
also drastically impact my quality of life as well as my company and the technology
events organized in Washington State due to the burden of travel to be with the woman
I love.

23

12. If I am unable to live with my fiancé in the United States, I have been considering the

24

possibility of moving to another country where we can marry and live together. Many

25

countries where my fiancé can easily travel to and reside in are primarily Islamic

26
2

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

1

countries with Islamic values and laws. Living together in Iran, for example, would

2

require me to convert to Islam. I do not intend to change my religion and would

3
4
5
6

therefore be subject to possible religious persecution and criminal prosecution. Thus,
my fiancé and I want to marry and live together here in the United States.
I declare under penalty of perjury that the foregoing is true and correct.

7
8

Executed on this 9th day of October, 2017

9
10
11

________________________________________
Ethan Devenport

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
3

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