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)

Third Amended
Complaint
Exhibit D

The Latest: Protest at Seattle-Tacoma airport continues - Washington Times

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The Latest: Protest at SeattleTacoma airport continues

Demonstrators sit down in the concourse and hold a sign that reads “We are America,” as more than 1,000 people
gather at Seattle-Tacoma International Airport, to protest President Donald Trump’s order that restricts immigration to
the U.S., Saturday, Jan. 28, ... more >

By - Associated Press - Sunday, January 29, 2017

SEATTLE (AP) - The Latest on a protest in Seattle against President Donald
Trump’s travel ban barring citizens of seven predominantly Muslim nations
entry into the U.S. (all times local):
1:45 a.m.

http://www.washingtontimes.com/news/2017/jan/29/the-latest-protest-at-seattle-tacoma-air... 10/9/2017

The Latest: Protest at Seattle-Tacoma airport continues - Washington Times

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At Seattle-Tacoma International Airport, about 3,000 protesters holding signs
and chanting “no hatred, no fear, immigrants are welcome here” and “let
them in” continued demonstrating into early Sunday morning.
Aayah Khalaf, a Muslim American, was sitting at home watching the protest
on television when she and her friend studying from Egypt decided to join
the rally. It was her second time joining a protest. The first one was the
Women’s March.
“It’s not just against Muslims. It against environmental rights and human
rights overall. I think everybody has to stand up against this,” said Khalaf, 29.
The Port of Seattle Commissioners, which oversees the airport, issued a
statement criticizing the executive order.
“The Port of Seattle Commissioners, Tom Albro, Courtney Gregoire,
Stephanie Bowman, Fred Felleman and John Creighton are here today to
express our concerns over the immigration ban executive order that was
issued late last night. As the government that operates this airport, this
executive order runs counter to our values. America is great because we are
a land of immigrants and that is what made us great to begin with,” the
statement said.
___
1:30 a.m.
Washington Gov. Jay Inslee blasted President Donald Trump’s executive
order banning people from certain Muslim-majority nations as “unjustifiable
cruelty,” and about 1,000 pro-immigration protesters gathered Saturday at
Seattle-Tacoma Airport.
Attorneys from the ACLU and the Northwest Immigrant Rights Project said a
Somali national was not allowed to enter and two other people were
detained at the airport.

http://www.washingtontimes.com/news/2017/jan/29/the-latest-protest-at-seattle-tacoma-air... 10/9/2017

The Latest: Protest at Seattle-Tacoma airport continues - Washington Times

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U.S. District Judge Thomas Zilly in Seattle issued an order Saturday halting
any deportations related to Trump’s order after immigration advocates filed
an emergency motion arguing that the president’s actions violated the due
process rights of the immigrants.
Doug Honig, a spokesman for the ACLU of Washington state, told The Seattle
Times Zilly granted a motion for an emergency stay to prevent the two
people who were detained at Sea-Tac Airport from being sent out of the
country on a flight to Dubai.
Trump signed an executive order Friday that bans legal U.S. residents and
visa-holders from seven Muslim-majority nations from entering the U.S. for
90 days and puts an indefinite hold on a program resettling Syrian refugees.
At a fiery news conference denouncing Trump’s order, Inslee said he had met
with a woman, a U.S. citizen, whose husband was denied entry at Sea-Tac
airport after flying from Vienna. It wasn’t clear if Inslee was speaking about
the same traveler or if multiple people were detained.
The United States “allowed her husband to get on a plane in Vienna but didn’t
let him go the six feet across this gate to embrace his wife,” Inslee said of the
man.

http://www.washingtontimes.com/news/2017/jan/29/the-latest-protest-at-seattle-tacoma-air... 10/9/2017