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
MOHAMMAD
GHAEDI

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
STATE OF WASHINGTON, et al.,

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Plaintiffs,

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CIVIL ACTION NO. 2: 17-cv-00141-JLR
DONALD TRUMP, et al.,

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Defendants.

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Pursuant to 28 U.S.C.

1746(2), I, Mohammad Ghaedi, hereby declare as follows:

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l. I am over the age of eighteen and competent to testify herein.

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2. I live in Washington State and I am hugely impacted by travel ban 3.

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3. I am an Iranian PhD student and instructor at Washington State University School of

Politics, Philosophy and Public Affairs.
4. My dissertation for my PhD is on the impact of tribal structure of some countries and

its impact on committing terrorist activities.

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5. I have a valid multiple-entry visa issued from the US embassy in Germany. I have been

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vetted twice, first when I applied for my student visa at the US embassy in Turkey in
AVI*ORNEY
GENERALOF WASHINGTON

800FinliAvenue,Suite2000
Seattle,WA98104-3188
[phone]

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2014 and second time (aftct it expired) I applied for another student visa in Germany

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The second time it took 40 days to get vetted and get my visa issued.

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6. After travel ban 1, I cancelled my travel to Iran which was intended to collect data for
my dissertation, including in-depth interviews and a survey in the region. In addition. t

cancelled my presentation in two international conferences in which I had accepted
papers (WPSA in Canada and ISPP in Scotland) because I might not have been able to

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get back to US to finish my PhD due to travel ban. Attending these conferences is

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critical because I could present my papers and get feedback on my research from

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experts in my field. In addition, presenting in these conferences illustrates a scholar's
professionalism and commitment to the community of experts in the field and builds up

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one's resume. Moreover, at these conferences, researchers have opportunity to find
other scholars with similar research fields to cooperate on future common scientific
projects.
7. I have applied for my mother and adopted son to be able to travel to the United States.

Their appointment was cancelled twice after the first two executive orders. When the
appointment was rescheduled, they traveled from Iran to Dubai for the embassy's

interview. Neither of their visas were approved so I am still working on getting
documents together to support their applications. I hoped to schedule another

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appointment for my mother at the US embassy in Turkey soon but travel ban3

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destroyed our hopes. Neither of them will have their visas by October 18, 2017.

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8. I have not seen my mother from Aguste 2016 and due to my department's request (not

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to leave the country before the end of Ph.D.) I cannot travel to Iran to see her. The

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ATTORNEYGENERALOF WASHINGrON
800FifthAvenue.suiE 2000
Seattle, WA 9810-4-3188
[phone]

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other option is to have my mother travel herc for a visit and that requires her to get a

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visa which is not possible under tmvel ban3. Me and my mother arc very close and not

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being able to see her has a great impact on my life including my work and research.
9. My research is on ten•orism and has implication for counter-terrorism. I am born and

raised in the Middle East and I am familiar with cultural nuances and languages.

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Therefore, the research I am doing is beneficial for both academy and practitioners in

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the US.

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

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Executed on this 6thday of October, 2017

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Mohammad Gh

i

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AITORNEY GENERALOF WASHINGTON
800 Fifth Avenue. suite 2000
Seattle, WA 98104-3188

[phone]