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
ADAM
MOKHALALATI

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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 ADAM ABO
RYAN MOKHALALATI

Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Adam Abo Ryah Mokhalalati, hereby declare as follows:
1. I am over the age of eighteen and competent to testify herein.

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2. I live in Washington State.
3. I am a junior international student at the University of Washington-Seattle. Majoring in

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Civil and Environmental Engineering, with an intending graduation date of June 2019.

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As well as, having research positions for the aerospace department at UW.

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4. I am originally from Syria.
5. I came to the United States in 2015 on an F1 multiple-entry visa that expired in mid 2017.
I still have F1 status, but no travel visa to re-enter the United States if I leave. I recently

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

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received Temporary Protected Status (TPS), but must get that renewed every year. In

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order to travel on my TPS status, I must have prior authorization. If the President’s

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September 24, 2017 Proclamation is implemented, my ability to renew my F-1 travel visa
will continue to be affected and makes my traveling insecure, even if I had the
authorization from my TPS. This is why currently I’m under the uncertainty of whether

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I’m legally allowed to leave the US and re-enter, due to having two different statuses

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(both TPS and F-1), because whatever step or measure I take, I need to make sure it does

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not violate any of these statuses. This means that I will also be indefinitely prevented

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from traveling out of the United States if I want to continue living here because I will not
be able to re-enter using my F-1 status due to my travel visa expiration, and the ability

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of the border security to deny my re-entry under my TPS status. This Proclamation, is
and will make it even harder for my family to visit me while I live in the US, for example

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my sister was denied a tourist visa, in which she was planning on using to visit me.

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6. My future goals after graduation is to be able to work in the US and gain some experience

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before returning home, without the feeling of being pressured or scared of being kicked

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out at any moment. In addition, to my ability to freely leave and enter this country like
everyone else does, to either visit family or friends or even to do work abroad.
7. If the President’s September 24, 2017 Proclamation is implemented, this will place me

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under the mercy of my TPS status, since the fact that I could be asked to leave the US

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whenever Syria gets removed from the list of temporary protected countries. It also limits

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the number of admitted refugees, which reduces my chances of claiming such a status.

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All of that reduces my ability to work as a Syrian national in the US, due to the fact that

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

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companies would not risk employing someone, who could potentially be asked to leave

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the country suddenly.

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

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Executed on the 9th of October, 2017

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________________________________________
Adam Abo Ryah Mokhalalati

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