State of Hawaii v. Trump

Filing 370

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)

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DECLARATION OF NANDITA SHARMA I, NANDITA SHARMA, do declare and would competently testify as follows: 1. I am an Associate Professor in the Department of Sociology at the University of Hawai’i at M~noa. I have served in this role since August 2008. From August 2006 to July 2008, I was an Assistant Professor jointly in Sociology and Ethnic Studies at the University of Hawai’i at Mãnoa. 2. I am the Director of the University’s International Cultural Studies Program, a graduate certificate program open to any graduate student enrolled at the University. The International Cultural Studies Program, which has operated at the University for the past 20 years, takes a distinctive approach to culture, recognizing that culture is continually being made and remade through political, social, and economic forces. The University’s cultural studies program is unique among cultural studies programs because it has an explicitly international focus and actively seeks to bring subjects of an international character to its U.S. audience. 3. Each semester, the International Cultural Studies Program organizes a Speaker Series, through which various scholars and speakers are invited to the University to discuss timely issues relevant to cultural studies. Students EXHIBIT H participating in the International Cultural Studies Program are required to attend the Speaker Series to develop a broad understanding of current issues from a cultural studies perspective. The Speaker Series presentations are also open to other University students, to University faculty, and to the general public. 4. In September 2017, the International Cultural Studies Program organized a Speaker Series presentation with two journalists, both Syrian nationals from the group Raqqa is Being Slaughtered Silently (“RBSS”). One of the Syrian nationals that was set to participate in the Speaker Series was denied a visa by a U.S. Consulate, preventing that person from entering the United States and speaking at the University. 5. Although we were disappointed to lose the important perspective of one of the Syrian nationals, we continued on with the Speaker Series presentation with the other Syrian national, who obtained a B- 1/B-2 visa to enter the United States. He discussed, in depth, recent events in Syria and the work of his organization, RBSS. 6. As a direct result of the Speaker Series, various professors at the University of Hawai’i would like to offer a scholarship to the Syrian national who participated in the recent presentation at the University. 7. I am aware that 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” on September 24, 2017, which, among other things, indefinitely suspends the entry of Syrian nationals into the United States and the issuance of visas to Syrian nationals. 8. The latest travel ban will impede the University’s efforts to recruit and enroll the Syrian national to whom the University would like to offer a scholarship. The Syrian national has a refugee travel document issued by Germany that is set to expire soon. As a result, it is my understanding that this individual’s U.S. B-l/B-2 visa (whose issuance was contingent on the German travel document) will become useless by mid-November, and that this individual, who is currently outside the United States, will need to obtain a new U.S. visa to enter the United States. Because of the President’s new travel ban, this Syrian national will not be able to accept the University’s scholarship offer and will be precluded from attending the University. 9. The new travel ban also impedes the University’s ability to host nationals of the affected countries as visiting scholars or speakers. For instance, the International Cultural Studies Program has invited a Syrian national who is an expert on the Syrian revolution to participate in a Speaker Series presentation this coming year. The Syrian national has indicated interest in participating in this event either in November 2017 or in January 2018. However, this Syrian national lives outside the United States and will need a visitor visa to come to Hawai’i, which the President’s new travel ban blocks. Because of the travel ban, the University unfortunately will not be able to hold its planned Speaker Series event with the Syrian national’s participation this November or thereafter. That harms the University’s ability to fulfill its educational mission. 10. The International Cultural Studies Program, through its ongoing relationship with the Honolulu Museum of Art, also intends to hold a Speaker Series event in conjunction with a film screening at the museum’s Doris Duke Theatre. The Speaker Series event, to be held in Hawai’i, will involve a national of Chad, one of the countries affected by the latest travel ban. The Chadian national is the director of the film that the Doris Duke Theatre intends to show in connection with the visit. The Chadian national is an expert on human rights abuses in Chad. I am organizing a Speaker Series event involving the Chadian national’s participation in the spring of 2018, and the Chadian national, who lives outside the United States, would need a visitor visa to participate. 11. I am aware that the latest travel ban suspends the issuance of business (B-i), tourist (B-2), and business/tourist (B-1/B-2) visas to nationals of Chad. The latest travel ban, therefore, would prevent the Chadian national from obtaining the visa necessary to participate in the University’s planned Speaker Series event. 12. The new travel ban also negatively affects academic study and scholastic development at the University. The travel ban itself, in its various iterations, has become a topic of study at the University. The people affected by the travel ban are important resources in this burgeoning field of study, but access to those people is directly limited, perhaps indefmitely, by the travel ban. This impedes the development of scholarship in various departments, including sociology and political science, and interferes with the University’s ability to foster academic relationships with affected individuals. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. DATED: Honolulu, Hawai’i, October 4, 2017. C’— NANDITA SHARMA

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