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
MOJDEH JALALI
HERAVI

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 MOJDEH
JALALI HERAVI

DONALD TRUMP, et al.,
Defendants.

15
16
17

Pursuant to 28 U.S.C. § 1746(2), I, Mojdeh Jalali Heravi, hereby declare as follows:
1. I am over the age of eighteen and competent to testify herein.

18
19
20

2. I am a United States citizen. I am originally from Iran.
3. I currently live in Washington State and work as a Software Engineer at MemSgl.

21

4. My parents are lecturers at California State University in LA teaching Chemistry. Although

22

it is not easy to immigrate to another country being almost 60, after teaching and researching

23

for more than 30 years in Iran, they immigrated to US just to be closer to all their children.

24

My father is an American citizen.

25
5. My brother is a Software Engineer in Redmond WA working for Microsoft.
26
1

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

1

6. My sister is a Process Engineer in Orange, CA.

2

7. 1 still have a sister living in Sweden. She is the most talented architect that I have ever seen.

3

Our family's accomplishments over the past ten years have been incomplete because we

4
need her to be with us before we can feel whole. My father applied for her green card more
5

6

than six years ago. We were so excited in August 2017 when her DS-260 was filed and !i
i

7

based on her priority date her final interview for issuing the immigration visa should get

8

scheduled in the next 3 months.

9
10
it

8. However, with the President's September 24, 2017 Proclamation, my sister will never be
able to join the rest of our family, not even for a short visit. She would not be able to join us
for any of our birthdays, Thanksgiving or New Years. I do not know how I can call a place

12
home when i am not allowed to invite my family members to it. Although I am an American
13
14
15
16
17

citizen, I feel discriminated against because I am not allowed to have my family members
in my home just because of my birth country.
9. With this travel ban it is going to be almost impossible for all of us to be able to get
vacations at the same time and travel abroad just for a family gathering.

18

19
20

1 declare under penalty of perjury that the foregoing is true and correct.
Executed on this —4th— day of October, 2017

21
22

Mojdeh Jalali He vi

23
24
25
26
2

ATTORNEY GENERAL OF WASHINGTON

800 Fifth Avenue, Suite 2000
Seattle, WA 98101-3188
(.061 464-7744
1