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)

Index of Declarations Cited in Support of Motion for Leave to File
Third Amended Complaint
Docket No.

Declaration of

Position

Organization/Affiliation

Category

National Security
ECF 194-18 Joint Former
3d Am.
National Security
Compl. Ex. Officials
1

Former national
security, foreign
policy and
intelligence officials

United States
Government

National
Security

Dual U.S. and Iranian
citizen

Washington resident

Residents

Yemeni naturalized
U.S. citizen
Yemeni naturalized
U.S. citizen

New York resident

Residents

New York resident

Residents

Residents
ECF 194-19 Nima Ala
3d Am.
Compl. Ex.
16
ECF 118-4 Rabyaah
Althaibani
ECF 194-20 (Second) Rabyaah
3d Am.
Althaibani
Compl. Ex.
48
ECF 118-5 Sadaf Amin

Weill Cornell MedicineMedical College of
Cornell University
U.S. Legal Permanent Washington resident
Resident

Residents

Shervin Beygi

U.S. citizen

Washington resident

Residents

Bahareh Bina

Iranian citizen, U.S.
Legal Permanent
Resident

Washington resident

Residents

Brian Callaghan

Spouse of Iranian
immigrant
Iranian lawful
permanent resident
U.S. citizen

Washington resident

Residents

Washington resident

Residents

Washington resident

Residents

ECF 194-21
3d Am.
Compl. Ex.
51
ECF 194-22
3d Am.
Compl. Ex.
5
ECF 194-23
3d Am.
Compl. Ex.
22
ECF 118-6

Alireza Ayoubi

ECF 118-7

Somaye Dadgari

ECF 194-24 Ethan Devenport
3d Am.
Compl. Ex.
18

Iranian PhD Student

Residents

ECF 118-8

Abdo Elfgeeh

Yemeni naturalized
U.S. citizen
Iranian citizen, U.S.
Legal Permanent
Resident

New York resident

Residents

Washington resident

Residents

Iranian lawful
permanent resident
Assistant Professor

Washington resident

Residents

Washington State
University

Residents

ECF 194-26 Mahdi Hajiaghayi
3d Am.
Compl. Ex.
13
ECF 118-11 Eva Hassett

Iranian citizen, U.S.
Single Entry visa
holder

Washington resident

Residents

Executive Director

Residents

ECF 194-27
3d Am.
Compl. Ex.
9
ECF 194-28
3d Am.
Compl. Ex.
10
ECF 194-29
3d Am.
Compl. Ex.
23
ECF 194-30
3d Am.
Compl. Ex.
14
ECF 118-12

Mojdeh Jalali
Heravi

U.S. citizen

International Institute of
Buffalo
Washington resident

Vahid Jazayeri

Dual U.S. and Iranian
citizen

Washington resident

Residents

Mohammad
Shafiei Khadem

Dual U.S. and Iranian
citizen

Washington resident

Residents

Ahmad
Moghaddam

Dual Canadian and
Iranian citizen, U.S.
TN-1 visa holder

Washington resident

Residents

Chairman

ATM World Corp.

Residents

ECF 194-25 Yasaman Esmaili
3d Am.
Compl. Ex.
7
ECF 118-9 Navid Fallah
ECF 118-10 Hassan
Ghasemzadeh

Abdul Salam
Mubarez
ECF 194-31 Younes Nouri
3d Am.
Compl. Ex.
3
ECF 194-32 Proshat
3d Am.
Parsimoghadam
Compl. Ex.
53
ECF 118-13 Sana Parsian

Residents

U.S. Legal Permanent Washington resident
Resident

Residents

Iranian citizen
married to U.S.
citizen

Washington resident

Residents

Dual U.S. and Iranian
citizen

Washington resident

Residents

ECF 118-14 Zehra Rasouli

Iranian EB-visa
holder

Washington resident

Residents

ECF 118-15 Amin Shayegan

Iranian refugee

Washington resident

Residents

ECF 118-16 Jennifer Sime

International Rescue
Committee

Residents

Emad Soroush

Senior Vice
President, US
Programs
U.S. citizen

Washington resident

Residents

Tannaz Sattari
Tabrizi

Iranian citizen, U.S.
visa holder

Washington resident

Residents

Seyed Danial
Vaezi

U.S. Legal Permanent Washington resident
Resident

Residents

ECF 194-33
3d Am.
Compl. Ex.
8
ECF 194-34
3d Am.
Compl. Ex.
11
ECF 194-35
3d Am.
Compl. Ex.
6

Educational Institutions, Students and Faculty
ECF 194-36
3d Am.
Compl. Ex.
20
ECF 103

Banafsheh
Samareh
Abolhasani

PhD Student,
Industrial and
Systems Engineering

University of
Washington

Educational
Institutions

Ronald L. Adams

Interim Provost and
Executive Vice
President
Research Associate,
Paul Allen School for
Computer Science &
Engineering
Iranian PhD Student

Oregon State University

Educational
Institutions

University of
Washington

Educational
Institutions

Weill Cornell MedicineMedical College of
Cornell University
University of
Washington

Educational
Institutions

Washington State Board
for Community and
Technical Colleges
University of
Washington

Educational
Institutions

ECF 194-37 Armin Alaghi
3d Am.
Compl. Ex.
40
ECF 118-5 Sadaf Amin

ECF 194-38 Pegah Jalali
3d Am.
Asheghabadi
Compl. Ex.
15
ECF 17-3
John Boesenberg

ECF 66

Rovy Branon

PhD student,
Environmental and
Forest Sciences
Deputy Executive
Director for Business
Operations
Vice Provost for the
Continuum College

Educational
Institutions

Educational
Institutions

ECF 118-17 (Second) Rovy
Branon

Vice Provost for the
Continuum College

University of
Washington

Educational
Institutions

ECF 194-39 (Third) Rovy
3d Am.
Branon
Compl. Ex.
30
ECF 17-4
(Second) Asif
Chaudhry

Vice Provost for the
Continuum College

University of
Washington

Educational
Institutions

Vice President for
International
Programs

Washington State
University

Educational
Institutions

ECF 67

Vice President for
International
Programs

Washington State
University

Educational
Institutions

Vice President for
International
Programs
Vice President for
International
Programs

Washington State
University

Educational
Institutions

Washington State
University

Educational
Institutions

Maryam
Dadkhahan

Undergraduate
student, English

University of
Washington

Educational
Institutions

Jason Detwiler

Professor, Physics

University of
Washington

Educational
Institutions

(Third) Asif
Chaudhry

ECF 118-18 (Fourth) Asif
Chaudhry
ECF 194-40
3d Am.
Compl. Ex.
32
ECF 194-41
3d Am.
Compl. Ex.
35
ECF 194-42
3d Am.
Compl. Ex.
45
ECF 118-19

(Fifth) Asif
Chaudhry

David Eaton

Dean of Graduate
School

University of
Washington

Educational
Institutions

ECF 194-43
3d Am.
Compl. Ex.
29
ECF 194-44
3d Am.
Compl. Ex.
33
ECF 101

(Second) David
Eaton

Dean of Graduate
School

University of
Washington

Educational
Institutions

Kiana Ehsani

PhD Student,
Computer Science &
Engineering

University of
Washington

Educational
Institutions

Margaret Everett

Vice Provost for
Portland State University
International Affairs
and Dean of Graduate
Studies

Educational
Institutions

ECF 194-45
3d Am.
Compl. Ex.
39
ECF 194-46
3d Am.
Compl. Ex.
21
ECF 194-47
3d Am.
Compl. Ex.
19
ECF 96

Ali Farhadi

Associate Professor,
Computer Science

University of
Washington

Educational
Institutions

Hoda Farhadi

PhD Student and
Employee,
Rehabilitation
Medicine
PhD student,
Rehabilitation
Medicine

University of
Washington

Educational
Institutions

University of
Washington

Educational
Institutions

Vice Provost for
International Affairs,
Professor in Political
Science and
International Studies
Departments
Vice Provost for
International Affairs,
Professor in Political
Science and
International Studies
Departments
PhD student, Politics,
Philosophy and
Public Affairs

University of Oregon

Educational
Institutions

University of Oregon

Educational
Institutions

Washington State
University

Educational
Institutions

Anne Greenbaum

Professor of Applied
Mathematics

University of
Washington

Educational
Institutions

Hannaneh
Hajishirzi

Assistant Research
Professor of
Electrical
Engineering
General Counsel

University of
Washington

Educational
Institutions

University of
Massachusetts
University of
Massachusetts

Educational
Institutions
Educational
Institutions

Cancer Research Center
at Albert Einstein
College of Medicine

Educational
Institutions

Maryam Fayazi

Dennis Galvan

ECF 194-69 (Second) Dennis
3d Am.
Galvan
Compl. Ex.
52

ECF 194-48
3d Am.
Compl. Ex.
36
ECF 194-49
3d Am.
Compl. Ex.
44
ECF 194-50
3d Am.
Compl. Ex.
38
ECF 118-20

Mohammad
Ghaedi

Deirdre Heatwole

ECF 194-51 (Second) Deirdre
3d Am.
Heatwole
Compl. Ex.
46
ECF 118-21 Shayda Hemmati

General Counsel

Iranian Postdoctoral
Research Fellow

ECF 194-52 Parisa
3d Am.
Hosseinzadeh
Compl. Ex.
42
ECF 118-22 Ross D. Lewin

Postdoctoral
Researcher,
Department of
Biochemistry
Associate Vice
President for
International Affairs

University of
Washington

Educational
Institutions

University of Maryland
College Park

Educational
Institutions

ECF 118-23 Ali Mehrizi-Sani

Professor in School
of Electrical
Engineering and
Computer Science
Undergraduate
student, Civil and
Environmental
Engineering
PhD Student,
Electrical
Engineering

Washington State
University

Educational
Institutions

University of
Washington

Educational
Institutions

University of
Washington

Educational
Institutions

Executive Vice
Chancellor and
University Provost
Professor of Law,
Vice Provost for
Global Affairs
Professor of Law,
Vice Provost for
Global Affairs
Professor of Law,
Vice Provost for
Global Affairs
Professor of Law,
Vice Provost for
Global Affairs

The City University of
New York

Educational
Institutions

University of
Washington

Educational
Institutions

University of
Washington

Educational
Institutions

University of
Washington

Educational
Institutions

University of
Washington

Educational
Institutions

Trustee

United Automobile,
Aerospace and
Agricultural Implement
Workers of America,
Local 4121

Educational
Institutions

PhD student,
Ethnomusicology

University of
Washington

Educational
Institutions

ECF 194-53
3d Am.
Compl. Ex.
31
ECF 194-54
3d Am.
Compl. Ex.
34
ECF 118-24

Adam
Mokhalalati

ECF 9

Jeffrey Riedinger

ECF 17-2

(Second) Jeffrey
Riedinger

Shima Nofallah

Vita C.
Rabinowitz

ECF 118-25 (Third) Jeffrey
Riedinger
ECF 194-55 (Fourth) Jeffrey
3d Am.
Riedinger
Compl. Ex.
37
ECF 118-26 Viral P. Shah

ECF 194-56 Solmaz
3d Am.
Shakerifard
Compl. Ex.
43

ECF 194-57
3d Am.
Compl. Ex.
12
ECF 194-58
3d Am.
Compl. Ex.
17
ECF 118-27

Khadijeh
Sheikhan

PhD student,
Computer Science

New York University

Educational
Institutions

Ali Shojaie

Faculty, School of
Public Health

University of
Washington

Educational
Institutions

Judith N.
Wasserheit

Professor of
Medicine and Global
Health and William
H. Foege Endowed
Chair of Department

University of
Washington

Educational
Institutions

ECF 118-28 (Second) Judith
N. Wasserheit

Professor of
Medicine and Global
Health and William
H. Foege Endowed
Chair of Department

University of
Washington

Educational
Institutions

D. Mass.
ECF No.
52-91

Senior Vice President
for Academic Affairs,
Student Affairs, and
International
Relations
Senior Manager of
Program Operations
of Continuum
College
Associate Professor,
Foster School of
Business

University of
Massachusetts

Educational
Institutions

University of
Washington

Educational
Institutions

University of
Washington

Educational
Institutions

State University of New
York

Educational
Institutions

Marcellette G.
Williams, PhD.

ECF 118-29 Judith Wood

ECF 194-59 Hema
3d Am.
Yoganarasimhan
Compl. Ex.
41
ECF 118-30 Nancy L. Zimpher Chancellor

Economy and Businesses
ECF 102

Richard Birkel

Executive Director

ECF 6

Ayesha
BlackwellHawkins

Senior Manager of
Mobility and
Immigration

1

Louhghalam v. Trump, Case No. 1:17-cv-101154-NMG (D. Mass.)

Catholic Charities of
Oregon
Amazon.com, Inc.

Economy and
Businesses
Economy and
Businesses

ECF 118-31 Scott S. Buell

Senior Legal Counsel

MongoDB, Inc.

ECF 99

Lee Po Cha

Executive Director

Immigrant and Refugee
Economy and
Community Organization Businesses

ECF 7

Robert Dzielak

Executive Vice
President, General
Counsel, Secretary

Expedia, Inc.

Economy and
Businesses

ECF 118-32 Renee A.
Fullerton

J-1 Visa Waiver
Program Manager

Washington State
Department of Health

Economy and
Businesses

ECF 118-11 Eva Hassett

Executive Director

ECF 118-33 Paul Johnson

Senior Mortgage
Consultant

International Institute of
Buffalo
Guild Mortgage

Economy and
Businesses
Economy and
Businesses

ECF 118-34 Aaron O. Lavine

City Attorney

City of Ithaca

Economy and
Businesses

ECF 17-1

Assistant Director of
Research and Fiscal
Analyst
Assistant Director of
Research and Fiscal
Analyst

Washington State
Department of Revenue

Economy and
Businesses

Washington State
Department of Revenue

Economy and
Businesses

General Counsel

Meetup, Inc.

Economy and
Businesses

ECF 118-36 Michal Rosen

General Counsel

Kickstarter, PBC

Economy and
Businesses

ECF 118-37 Michael Saunders

Corporate Counsel

Redfin Corporation

ECF 118-38 Jill Simeone

General Counsel

Etsy, Inc.

ECF 118-39 Dave Soike

Chief Executive
Officer

Port of Seattle

Economy and
Businesses
Economy and
Businesses
Economy and
Businesses

ECF 194-61 (Second) Dave
3d Am.
Soike
Compl. Ex.
27

Chief Executive
Officer

Port of Seattle

Kathy Oline

ECF 194-60 (Second) Kathy
3d Am.
Oline
Compl. Ex.
26
ECF 118-35 David J. Pashman

Economy and
Businesses

Economy and
Businesses

ECF 118-40 Sajjad Topiwala

Treasurer

Noor360, Inc.

Economy and
Businesses

ECF 118-41 Jonathan
Truppman

General Counsel

Casper Sleep Inc.

Economy and
Businesses

ECF 118-42 Rita Zawaideh

Founder and Owner

Caravan-Serai, Inc.

Economy and
Businesses

ECF 194-62 (Second) Rita
3d Am.
Zawaideh
Compl. Ex.
28

Founder and Owner

Caravan-Serai, Inc.

Economy and
Businesses

Health Care
ECF 118-43 Mitra Akhtari

PhD Candidate

Harvard University

Health Care

ECF 194-63
3d Am.
Compl. Ex.
49
D. Mass.
ECF 52-22

(Second) Mitra
Akhtari

Founding
Member/Researcher

Immigrant Doctor’s
Project

Health Care

Michael F.
Collins, MC

Senior Vice President University of
for Health Sciences at Massachusetts
university,
Chancellor of
medical school

Health Care

ECF 118-44 Melanie de Leon

Executive Director

Health Care

ECF 194-64 (Second) Melanie
3d Am.
de Leon
Compl. Ex.
25
ECF 118-45 Roozbeh
Eskandari

Executive Director

Washington State
Medical Quality
Assurance Commission
Washington State
Medical Quality
Assurance Commission

Postdoctoral Scientist

Memorial Sloan
Kettering Cancer Center

Health Care

ECF 194-65 Payam
3d Am.
Fotouhiyehpour
Compl. Ex.
4
ECF 118-32 Renee A.
Fullerton

Quality Manager

Philips Healthcare

Health Care

J-1 Visa Waiver
Program Manager

Washington State
Department of Health

Health Care

2

Louhghalam v. Trump, Case No. 17.cv-101154-NMG (D. Mass.)

Health Care

ECF 118-21 Shayda Hemmati

Iranian Posdoctoral
Resarch Fellow

ECF 118-46 Tim Johnson

Senior Vice President
and Executive
Director of Center for
GME Policy and
Services
Director, Primary
Care Office
Director, Primary
Care Office

ECF 100

Marc Overbeck

ECF 194-66
3d Am.
Compl. Ex.
50
ECF 194-67
3d Am.
Compl. Ex.
2
ECF 118-47

(Second) Marc
Overbeck

Cancer Research Center
at Albert Einstein
College of Medicine
Greater New York
Hospital Association

Health Care

Oregon Health Authority

Health Care

Oregon Health Authority

Health Care

Seattle Cancer Care
Alliance

Health Care

Health Care

(Second) Sana
Parsian

Breast Imaging Sr.
Fellow / Acting
Instructor

Eric Scherzer

Executive Director of SEIU Healthcare
Committee of Interns
and Residents
Faculty Statistician,
Fred Hutchinson
HIV Prevention
Research Center
Network, Vaccine
and Infectious
Disease Division
Religious Organizations
Chief Executive
Jewish Family Service of
Officer
Seattle
Executive Director
Catholic Charities of
Oregon
President and Chief
Lutheran Community
Executive Officer
Services Northwest

Health Care

Chief Finance and
Operations Officer
Senior Vice
President, US
Programs
Mayor

Ecumenical Ministries of
Oregon
International Rescue
Committee

Religious
Organizations
Religious
Organizations

City of Rochester

Religious
Organizations

ECF 194-68 Sahar Z.
3d Am.
Zangenah
Compl. Ex.
24

ECF 118-48 Rabbi Will
Berkovitz
ECF 102
Richard Birkel
ECF 118-49 David Duea

ECF 97

Howard N.
Kenyon
ECF 118-16 Jennifer Sime

ECF 118-50 Lovely A. Warren

Health Care

Religious
Organizations
Religious
Organizations
Religious
Organizations