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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FOURTH DECLARATION OF ASIF CHAUDHRY 1 2 3 4 5 The Honorable James L. Robart 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 10 11 STATE OF WASHINGTON, Plaintiff, 12 NO. FOURTH DECLARATION OF ASIF CHAUDHRY v. 13 14 DONALD TRUMP, et al., Defendants. 15 16 I, Asif Chaudhry, hereby declare and affirm: 17 1. I am the Vice President for International Programs at Washington State 18 University (WSU), Washington State’s land grant institution and the second largest public 19 research university in the Pacific Northwest. I have held this position since June 2015. Prior to 20 my current role at WSU, I spent my career working for the United States Government as a Senior 21 Foreign Service Officer, holding numerous leadership positions in the Departments of State, 22 Defense, and Agriculture. These positions included Vice President of the Commodity Credit 23 Corporation, Foreign Policy Advisor to the Chief of the United States Navy at the Pentagon, and 24 U.S. Ambassador to the Republic of Moldova. 25 26 DECLARATION OF ASIF CHAUDHRY 1 ATTORNEY GENERAL OF WASHINGTON 332 French Administration Building PO Box 641031 Pullman, WA 99164-1031 (509) 335-2636 1 2. I am aware of the revised Executive Order issued March 6, 2017, entitled 2 “Protecting The Nation From Foreign Terrorist Entry Into The United States.” I have personal 3 knowledge of the facts set forth in this declaration, and I am competent to testify about them. 4 3. As Vice President for International Programs at WSU, I have responsibility for 5 WSU’s international research activities, study abroad programs, international students, and 6 student and faculty exchanges. I am the chief international relations officer at WSU and am 7 responsible for the role of International Programs in carrying out WSU’s mission of global 8 engagement, which is “To apply knowledge through local and global engagement that will 9 improve quality of life and enhance the economy of the state, nation, and world.” I also manage 10 WSU’s programs focusing on establishing strategic partnerships with governments and 11 educational institutions across the globe. 12 4. WSU’s global presence includes active research programs in dozens of countries 13 worldwide and study abroad programs in over 70 countries worldwide. The University also has 14 matriculated undergraduate, graduate, and professional students and visiting scholars from many 15 countries worldwide. 16 5. WSU has obtained its final enrollment numbers for the spring 2017 semester. 17 The University has 157 students from the six countries targeted in the revised Executive Order. 18 Many of these students are on single-entry visas and could be denied re-entry if they left the 19 United States. As a result of the Executive Order, these students will be unable to have family 20 and colleagues join or visit them this semester and into the summer. In addition, because of the 21 uncertainty surrounding whether they would be allowed back into the country and what will 22 happen after the 90-day period, many of them have decided to forego international travel or 23 conference activities related to their research, or to visit family. 24 6. As an example, one Iranian graduate student, who is in year two of his Ph.D. 25 program, has decided not to leave the country to visit his family until he finishes his degree, 26 which means he will not see his family for several years. In addition, students who otherwise DECLARATION OF ASIF CHAUDHRY 2 ATTORNEY GENERAL OF WASHINGTON 332 French Administration Building PO Box 641031 Pullman, WA 99164-1031 (509) 335-2636 1 would leave the country to carry out dissertation research fear they may not be permitted to 2 return to the country to defend their dissertations. These students are under constant stress, their 3 research programs are being negatively impacted, and many are having difficulty focusing on 4 their studies. 5 7. Other students and faculty are impacted as well. WSU has seven (7) visiting 6 scholars from the six affected countries. One Iranian post-doctoral fellow has a husband who is 7 Iranian but currently lives in Germany. He applied for a dependent visa in January to join her in 8 the United States, but it has not yet been issued. The visa likely will not be issued prior to the 9 effective date of the order, which means her husband will not be able to join her. She is afraid 10 to visit her husband in Germany, as well as her mother in Iran, for fear of being denied re-entry 11 into the United States. 12 8. Another WSU student has a fiancé who is Iranian and lives in Iran. The fiancé 13 was scheduled to be interviewed for permanent residency in May 2017. That interview has now 14 been canceled and she cannot come to the United States. 15 9. The revised Executive Order, as well as the previous one, have created an 16 atmosphere in which international students and faculty feel unwelcome in the United States. 17 This is directly affecting WSU. For example, after several years of increasing international 18 enrollments, WSU is seeing a significant decline this year. WSU’s Department of Teaching and 19 Learning has reported that this year’s international application numbers have dropped 20 dramatically. Last year, the Department processed 63 international student applications for its 21 Special Education program, and this year it processed ten. Applications from international 22 students for other programs also are down. These declines have an economic impact on WSU 23 as well as the individual College and Departments. 24 10. WSU has six (6) undergraduate student applicants for fall 2017 from countries 25 targeted in the Executive Order, compared with 12 for fall of 2016. Two of these students have 26 been offered admission, and one has confirmed intent to enroll. These students now need to DECLARATION OF ASIF CHAUDHRY 3 ATTORNEY GENERAL OF WASHINGTON 332 French Administration Building PO Box 641031 Pullman, WA 99164-1031 (509) 335-2636

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