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
ARMIN ALAGHI

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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

DONALD TRUMP, et al.,

DECLARATION OF ARMIN ALAGHI

Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Armin Alaghi, 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 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

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have received multiple awards for my research. I also mentor many students and have

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been nominated for mentoring awards. My research focuses on building better and

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efficient hardware that can be used in smart sensors. Such small and efficient sensors

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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.

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

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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

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of a future visit from them. The newest travel ban came as a shock. I still cannot

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believe that my parents will not be able to visit me here ever! My brain is not able

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process this. It means that if I have kids in the future, I will not be able to have my

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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

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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

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in any way possible. I do not even have a single traffic violation. I do not understand

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how the US finds me and my parents dangerous. It is disappointing.

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9. Because of the newest travel ban, I am considering leaving the United States, the
country I have been calling my second home.

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

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Executed on this ___ day of October, 2017

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________________________________________
Armin Alaghi

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