State of Washington, et al., v. Trump., et al

Filing 118

Second MOTION to Amend Complaint, filed by Plaintiff State of Washington. (Attachments: # 1 Complaint Second Amended, # 2 Exhibit Exhibits to Second Amended Complaint, # 3 Index of Declarations, # 4 Decl. of R. Althaibani, # 5 Decl. of S. Amin, # 6 Decl. of B. Callaghan, # 7 Decl. of S. Dadgari, # 8 Decl. of A. Elfgeeh, # 9 Decl. of N. Fallah, # 10 Decl. of H. Ghasemzadeh, # 11 Decl. of E. Hassett, # 12 Decl. of A. Mubarez, # 13 Decl. of S. Parsian, # 14 Decl. of Z. Rasouli, # 15 Decl. of A. Shayegan, # 16 Decl. of J. Sime, # 17 Decl. of R. Branon, # 18 Decl. of A. Chaudhry, # 19 Decl. of D. Eaton, # 20 Decl. of D. Heatwole, # 21 Decl. of S. Hemmati, # 22 Decl. of R. Lewin, # 23 Decl. of A. Mehrizi-Sani, # 24 Decl. of V. Rabinowitz, # 25 Decl. of J. Riedinger, # 26 Decl. of V. Shah, # 27 Decl. of J. Wasserheit, # 28 Decl. of J. Wasserheit, # 29 Decl. of J. Wood, # 30 Decl. of N. Zimpher, # 31 Decl. of S. Buell, # 32 Decl. of R. Fullerton, # 33 Decl. of P. Johnson, # 34 Decl. of A. Lavine, # 35 Decl. of D. Pashman, # 36 Decl. of M. Rosenn, # 37 Decl. of M. Saunders, # 38 Decl. of J. Simeone, # 39 Decl. of D. Soike, # 40 Decl. of S. Topiwala, # 41 Decl. of J. Truppman, # 42 Decl. of R. Zawaideh, # 43 Decl. of M. Akhtari, # 44 Decl. of M. de Leon, # 45 Decl. of R. Eskandari, # 46 Decl. of T. Johnson, # 47 Decl. of E. Scherzer, # 48 Decl. of W. Berkovitz, # 49 Decl. of D. Duea, # 50 Decl. of L. Warren, # 51 Proposed Order) Noting Date 3/31/2017, (Melody, Colleen)

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DECLARATION OF HASSAN GHASEMZADEH Washington State University March 2017 Students concerns about their visa status being affected by MuslimBan 1. I am an Iranian Post-Doc associate in Research at WSU. I have got my doctorate degree from one of the best universities in Germany. In September 2016, I came to US for the first time and started my work here. Since in that time I was still a PhD student, I had to travel back to Germany (end of January, 2017) in order to have my final PhD defense. Unfortunately, after my arrival to Germany, I heard about the executive order against Iranians. After one week, when the ban was suspended by Washington State court, my supervisor at WSU asked me to re-book my ticket and fly back to US immediately! Therefore, I came back to USA on February 8, instead of February 11. My husband is still in Germany. He has applied for a dependent visa (in January) to join me here. Unfortunately, he has not received any response from US embassy yet! He is Iranian too. My German visa will expire in 17 months and that means afterward my husband must go back to Iran, since he is now on a family-visa in Germany. That will make everything more and more complicated. We were living in Germany in the last 5 years; therefore, Germany can easily prepare all needed information for US embassy for issuing a visa, but Iran cannot make that, because there is no US embassy in Iran! I don't know how long is needed for my husband to get a dependent visa. But I am sure the new executive order will definitely affect our life again. Besides, I am afraid to go to Iran to visit my mother there. Every time that I want to go out of America and visit my husband in Germany, there will be a big fear for me and I ask myself: “Am I allowed to come back to my work in USA again...?” 2. I am a student at Washington State University and my fiancé lives in Iran now. She has won the 2017 Green Card Lottery which her interview is scheduled in May 2017. Unfortunately, her interview process will be cancelled by the new travel ban order. Because she had been accepted in the Ph.D. program at the University of Oklahoma, she went to the embassy of Armenia to get her student visa in 2016, but the officer told her that she cannot be approved because she has already won lottery and her immigration’s file is under processing and she have to wait for entering via lottery. After all of our efforts to get admission and then waiting for the lottery visa process, now it will be cancelled by the new travel ban. We lost our time and money, and as Lottery 2017 process will be closed in September 2017, she also will lose her chance to study in the US beside me. She and I had planned to study and live together in the US since 3 years ago. I came to the US in 2016 via F1 visa and I already am a student at WSU and I am waiting for her but, now all of our goals will be unreachable by the new order. 3. I am a PhD student in WSU. When we were coming here we knew that single entry visa means you need to reapply for visa when you exit the country. But still we knew that based on law, after a long background check you can re-enter US and continue your PhD. 2 years ago I took my chance went back to Iran and applied for US visa again. Because I knew there is no reason for not getting cleared. Not being able to go back to my country is really frustrating. I can’t focus on my research and I’m so disappointed in my future in this country. 4. I am an Iranian PhD student at Washington State University. Given that I am on single-entry visa, even before the EO, going outside US was too risky for me. Now, it is impossible. Now I am under constant stress because I know for the future, no matter what happens to me or my family, I must decide between pursuing my studies or seeing my loved ones. I chose this country for my studies because I knew being the best is the only thing that matters here. But now, after four years of doing successful industrial research, it’s almost impossible for me to work in a company here and the whole professional network that I’ve built in years seems to be useless. 5. When I received my single-entry visa to enter the US to pursue my higher educations, I knew it means staying away from my country, and more importantly my family, for years. However, I did not know it could mean that I will be deprived of seeing my parents for at least 5 years! I had planned to have my parents here this summer, and now I feel too depressed. How can I tell my parents that they are suspected to be a threat to the national security when they just want to come visit their child after 3 years? These EOs have strongly affected not only individuals, but their communities. It has been so difficult to focus on my research, particularly when I see all my friends are stressed and disappointed. These EOs have destroyed our hope to build up a bright future! 6. I am a PhD student at Washington State University (WSU). I chose to pursue my PhD studies at WSU from among many high-ranking institutions in the world, including Australian, Canadian, and European ones. I chose an American institute because of the promise and prospect of American values, including equality, freedom, fair competition, generosity, etc. through a variety of anecdotal accounts I had been collected. I came here and found all the values which had changed my way. I was so excited and happy, and accomplished many goals this and the previous year. I was even considering staying, living, and working here. However, this unAmerican travel ban has completely changed my plans. I feel imprisoned, marginalized, belittled, and insulted. The grounds on which the Iranians (and other nationals in the order) have been banned from entering the US are entirely baseless, as neither research nor the common sense suggest the political accusations levelled against my people and our thousands years of academic, literary, and humanitarian civilization and history. It is true that the new ban has softened its language and removed some of the most critically legal aspects of it, but it is entirely unfair. It is not only unconstructive but also harmful to American interests, as tens of talented individuals will not be able to come to the US, depriving the American nation from the cultural, academic, and financial contributions they would make. I personally know many scholars who have/had to change their plans and follow their inspirations elsewhere. I think I will have to reconsider my own plans, too. I hope this insanity stops. 7. Most of first tier conferences in my area happen overseas. This Ban significantly decreases my chances of not only getting published in high quality conferences, but also since the number of targeted conferences (which has to be in the U.S. only) is very limited, I am concerned my studies would take longer than usual. 8. I am on a funding budget related to Environmental research. I heard rumors that I may lose my funding support since my nationality is Iran 9. I am about to graduate and already have a job offer from a startup company in California. Now I am on student Visa, the company stated they will apply for change of my work visa and later on they will appeal for my Green Card. Now with the new situation, I am afraid what is going to happen to me?

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