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
YASAMAN
ESMAILI

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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 YASAMAN
ESMAILI

DONALD TRUMP, et al.,
Defendants.

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

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

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2. I live in Washington State.

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3. I am an Iranian citizen and a US greencard holder. My parents are also US green card
holders and Iranian citizens and reside in the Seattle area.
4. I have lived in the US since 2008.
5. I am an architect and work for a private company Blokable. Our design philosophy and

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company mission is to make housing accessible and affordable to everyone in the US.

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We address the missing market through democratic design capabilities that are not met
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ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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by the current industry approach, trying to solve the housing crisis in the country –

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integrating technology, design and modular fabrication to build more quality affordable

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permanent housing for those who need it the most and are left out of the current
housing construction industry is our focus.
6. I am an associate of the American Institute of Architects. I have my Masters in

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Architecture in Design Computing from University of Washington, a Master of

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Architecture from University of Arizona and a Bachelor of Architectural Engineering

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from University of Tehran. I was able to pursue my studies in the US through

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scholarships that I could get from the University of Arizona and University of
Washington. I am the Founder of Studiochahar and a Founding Member of

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United4Design. My collaborations in these two studios has led to several national and
international recognitions including Lafargeholcim middle east Africa 2017 GOLD

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award, 2017 Northwest and Pacific American Institute of Architects Award of Honor,

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2016 Seattle American Institute of Architect Award of Merit and also in 2016 my work

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was selected for American Institute of Architects National Emerging ProfessionalS

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Exhibition. Right now I am the Architectural Designer for Blokable, Seattle. We are a
group of professionals from different disciplines joined together in this startup to shape
an architectural product that can solve the housing crisis in the US.
7. I am deeply troubled by the newest travel ban. If the President’s September 24, 2017

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Proclamation is implemented, my aunt and uncles and cousins can never come here to

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visit us which makes us very unhappy. This ban makes it so hard for me to call US my

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home, not being able to have my extended family visit us makes me feel that I don’t

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

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belong to this country and can’t trust this system to have me as a resident/future citizen

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with the same rights as the other residents of this country.

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

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Executed on this _09_ day of October, 2017

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________________________________________
Yasaman Esmaili

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