State of Hawaii v. Trump
Declaration re 369 MOTION for Leave to Proceed Under Psyeudonyms and for In Camera Review , 368 MOTION for Temporary Restraining Order of Deirdre Marie-Iha. (Attachments: # 1 Exhibit A, Decl. of John Doe 1, # 2 Exhibit B, Decl. of John Doe 2, # 3 Exhibit C, Decl. of Jane Doe 3, # 4 Exhibit D, Decl. of John Doe 4, # 5 Exhibit E, Decl. of John Doe 5, # 6 Exhibit F, Decl. of Straney, # 7 Exhibit G, Decl. of Chan, # 8 Exhibit H, Decl. of Sharma, # 9 Exhibit I, Decl. of Elshikh, # 10 Exhibit J, Decl. of Szigeti, # 11 Exhibit K, Decl. of Salaveria, # 12 Exhibit L, Decl. of Ouansafi, # 13 Certificate of Service)(Marie-Iha, Deirdre)
DECLARATION OF JOHN DOE 5
I, JOHN DOE 5, declare as follows:
I was born in Iran.
I am a dual citizen of Iran and Canada.
I am a lawful permanent resident of the United States and I live in
Hawaiʻi. I am currently in Dubai, but will soon be returning to Hawaiʻi.
I am a professor of Mechanical Engineering at the University of
I am aware that President Trump issued an executive order on January
27, 2017, which temporarily banned travel from seven Muslim-majority countries,
including Iran. I am also aware that on March 6, 2017, President Trump issued a
new executive order that temporarily banned travel from six Muslim-majority
countries, including Iran. I also understand that on September 24, 2017, President
Trump issued a “Presidential Proclamation Enhancing Vetting Capabilities and
Processes for Detecting Attempted Entry Into the United States by Terrorists or
Other Public-Safety Threats,” which imposes restrictions on entry into the United
States by nationals of eight countries, including Iran.
The University of Hawaiʻi’s college of engineering regularly hires
students from Iran as graduate research assistants. More than 50% of the
department of mechanical engineering’s PhD graduates in the last two years were
The President’s travel bans have hurt PhD recruitment efforts by the
University’s college of engineering, and the University’s overall competitiveness
in attracting students to the institution. I am personally involved in recruiting for a
research lab that I run, and I have noticed that fewer students are interested in
attending graduate programs in the United States, including at the University,
because of the uncertainty, burden, and inconvenience created by the President’s
travel bans. This past summer, I personally spoke with five Iranian students who
all expressed hesitation about studying at the University because of the President’s
prior travel bans. Many students are interested in attending programs in Canada or
Europe instead. This same harm to our recruitment will continue under the
President’s most recent proclamation. Even though there are some exemptions for
student visas from Iran, it is not clear that these students, once they come to
America, would be able to leave the country and come back (for example, if they
obtain only single-entry visas). Moreover, many of my Iranian graduate students
over the years have come to Hawaiʻi with spouses or partners during their studies,
or have received visits from family members during their years in the United
States. The President’s proclamation will make it much more difficult, if not
impossible, for close relatives to accompany or visit the students. PhD
recruitment is a highly competitive process for universities, and students tend to be
weary of barriers that force them to choose between their studies and their families.
As a result, I firmly believe that the President’s proclamation will continue to have
a terrible impact on the ability of my lab, and the college of engineering as a
whole, to recruit the best and brightest Iranian students.
The travel bans, by hampering the University’s recruitment efforts,
also negatively impact the engineering program’s research funding. Research
grants are highly competitive, and our competitiveness at the University is often
directly related to the quality of our graduate students. If we cannot bring in the
best students, many of whom have historically come from Iran, we may lose
competitive grants, which hurts our research funding.
The President’s travel bans have also affected me personally. As a
result of the uncertainty created by the first travel ban, including whether it would
be applied to legal permanent residents, I had to cancel a trip to Sri Lanka and a
trip to Europe to ensure that I would not be barred from reentering the country. I
also have many family members currently living in Iran, including my parents,
siblings, aunts, and uncles. They are all Iranian nationals. My mother and my
sister would like to visit me in Hawaiʻi. We have discussed plans for them to visit,
but the President’s various travel bans, including the recent proclamation, have
interfered with our plans. As a result of the President’s recent proclamation, which
bars the issuance of tourist visas to Iranian nationals entirely, my mother and my
sister will not be able to enter the United States to visit me.
The President’s recent proclamation separates me from my family. If
the proclamation remains in place, I intend to return to Canada. If I remain in the
United States, I will not be able to enjoy my family’s company.
I have requested that this declaration be filed anonymously because I
am afraid that if I identify myself, I may be subject to public reprisals.
I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.
Dubai, United Arab Emirates, October ___, 2017.
JOHN DOE 5
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