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)

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