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
TANNAZ SATTARI
TABRIZI

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
STATE OF WASHINGTON; STATE
OF CALIFORNIA; STATE OF
MARYLAND; COMMONWEALTH
OF MASSACHUSETTS; STATE OF
NEW YORK; and STATE OF
OREGON,
Plaintiffs,

CIVIL ACTION NO. 2:17-cv-00141-JLR
DECLARATION OF TANNAZ SATTARI
TABRIZI

V.

DONALD TRUMP, in his official
capacity as President of the United
States; U.S. DEPARTMENT OF
HOMELAND SECURITY; ELAINE
C. DUKE, in her official capacity as
Acting Secretary of the Department
of Homeland Security; REX
TILLERSON, in his official capacity
as Secretary of State; and the
UNITED STATES OF AMERICA,

Pursuant to 28 U.S.C: § 1746(2), I, Tannaz Sattari Tabrizi, hereby declare as follows:
lATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

1. I am originally from Iran.
2. I currently live in Washington State and work for Microsoft as part of my Option
Practical Training. As a Data Engineer I am working as part of Data science research
and strategy group on cutting edge data science algorithms to extract insight out of data
to add to organization's productivity, innovation and workplace health.
3. I came to the United States in 2014 to pursue my Master's degree in Computer Science
at Southern Illinois University, Carbondale.
4. I am living in the United States on a single-entry visa.
5. My older brother immigrated to the United States in 2004 on a single-entry student
visa. He has been a United States citizen since 2014. His wife and daughter are also
United States citizens. He is currently working as Hardware Engineering Manager for
Delta Tau Data Systems of California.
6. I have a sister who immigrated to the United States in 2010 on a single-entry student
visa. She is now a permanent legal resident. She is a Producer at Buck LA.
7. Our parents have attempted to visit us in the United States and we have had to wait
patiently to be reunited given the limits on our abilities to travel to Iran to see them.
8. In 2012, my parents planned on coming to the United States for my brother's wedding.
However, their visa was denied because they mistakenly stated they had not previously
applied for a visa when they had entered into the green card lottery system. (They had
not realized that a green card is a type of visa.) They were told to wait and apply in a
week and they assured them that they will get the visas and will be there for my
2ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA98104-3188
[phone]

brother's wedding. Unfortunately, my oldest sibling in Iran went into a Coma because
of long-term health complications chemotherapy had caused her. My parents canceled
their travel plan to take care of her and they did that for five years while she was in a
vegetative state. They have missed both of my sibling's weddings in the United States.
I have not seen them for over three years.
9. My brother's application for my parents' green cards was delayed because my parents
could not leave my sister alone while she was sick and bedridden. Last year, my sister
passed away and my parents went through severe depression having lost their eldest
daughter. I could not visit them because of my single-entry visa.
10. My brother started the green card application process for my parents in November 2016
and we submitted the final documents last week to get them in line to get an interview
appointment. Total cost of government processing fees and translations required have
totaled to over $2,000 so far. According to the process times that USCIS provided, their
visa appointment would probably be issued and dated after October 18, 2017, when the
President's September 24, 2017 Proclamationn goes into effect.
11. My father is now 74 years old, my mother is 65, and they have sacrificed their lives for
their children to give them a better chance at life. They have missed two of their
children's weddings and the birth of one granddaughter. My brother and sister are not
able to go back and live in Iran. My sister in law, niece and my brother in law are US
citizens and visiting Iran is a risk to their safety.
12. We were hoping to get my parents' green cards so they would not miss these special
moments anymore. If the President's September 24, 2017 Proclamation goes into
3ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

effect, our family will never be together. If being in the United States means that my
parents will never be able to visit me, then I would have to quit my job and move back
to Iran to take care of them, as my brother and sister cannot.

I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 8th day of October, 2017
fiDocuSigned by::

D 68FDB

J o.ff AVt

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Tannaz Sattari Tabrizi

4ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]