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)

Download PDF
DECLARATION OF ARMIN ALAGHI 1 2 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 3 4 STATE OF WASHINGTON, et al., 5 6 7 8 Plaintiffs, v. CIVIL ACTION NO. 2:17-cv-00141-JLR DONALD TRUMP, et al., DECLARATION OF ARMIN ALAGHI Defendants. 9 10 11 Pursuant to 28 U.S.C. ยง 1746(2), I, Armin Alaghi, hereby declare as follows: 12 1. I am over the age of eighteen and competent to testify herein. 13 2. I live in Washington State. 14 15 16 17 18 3. I am an Iranian citizen and an American legal permanent resident. 4. I am a Research Associate at the University of Washington (UW) Paul Allen School for Computer Science & Engineering. 5. I am involved in multiple research projects that help the community and the industry. I 19 have received multiple awards for my research. I also mentor many students and have 20 been nominated for mentoring awards. My research focuses on building better and 21 efficient hardware that can be used in smart sensors. Such small and efficient sensors 22 23 24 25 are useful in building smart cities. 6. I moved to the United States in 2009 in pursuit of a PhD. I got my PhD from the University of Michigan in 2015, and moved to Seattle to work at UW. 26 1 ATTORNEY GENERAL OF WASHINGTON 800 Fifth Avenue, Suite 2000 Seattle, WA 98104-3188 (206) 464-7744 1 2 3 4 5 6 7. I am the first and the only member of my family that has immigrated to the United States. My parents and my siblings live and work in Iran. Because of my job situation, I am not able to travel home frequently. My parents, on the other hand, are old and retired. They are able and have the time to travel to be with their children. Everything I do here, from renting a home with extra rooms to buying larger cars, is in preparation 7 of a future visit from them. The newest travel ban came as a shock. I still cannot 8 believe that my parents will not be able to visit me here ever! My brain is not able 9 process this. It means that if I have kids in the future, I will not be able to have my 10 11 parents come visit their grandchildren. This is not something that I can live with. 8. It just feels like there is no hope. My parents are in their 60s and are not a threat to this 12 13 14 country. I have been in the United States for over 8 years now. I am a Washington State employee. I have always obeyed the rules, paid my taxes, helped everyone around me 15 in any way possible. I do not even have a single traffic violation. I do not understand 16 how the US finds me and my parents dangerous. It is disappointing. 17 18 9. Because of the newest travel ban, I am considering leaving the United States, the country I have been calling my second home. 19 20 I declare under penalty of perjury that the foregoing is true and correct. 21 22 Executed on this ___ day of October, 2017 23 24 25 ________________________________________ Armin Alaghi 26 2 ATTORNEY GENERAL OF WASHINGTON 800 Fifth Avenue, Suite 2000 Seattle, WA 98104-3188 (206) 464-7744

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?