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)

FOURTH
DECLARATION OF
ASIF CHAUDHRY

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The Honorable James L. Robart
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON,
Plaintiff,

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NO.
FOURTH DECLARATION OF ASIF
CHAUDHRY

v.
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DONALD TRUMP, et al.,
Defendants.

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I, Asif Chaudhry, hereby declare and affirm:

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1.

I am the Vice President for International Programs at Washington State

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University (WSU), Washington State’s land grant institution and the second largest public

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research university in the Pacific Northwest. I have held this position since June 2015. Prior to

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my current role at WSU, I spent my career working for the United States Government as a Senior

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Foreign Service Officer, holding numerous leadership positions in the Departments of State,

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Defense, and Agriculture. These positions included Vice President of the Commodity Credit

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Corporation, Foreign Policy Advisor to the Chief of the United States Navy at the Pentagon, and

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U.S. Ambassador to the Republic of Moldova.

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DECLARATION OF ASIF CHAUDHRY

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ATTORNEY GENERAL OF WASHINGTON
332 French Administration Building
PO Box 641031
Pullman, WA 99164-1031
[phone]

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I am aware of the revised Executive Order issued March 6, 2017, entitled

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“Protecting The Nation From Foreign Terrorist Entry Into The United States.” I have personal

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knowledge of the facts set forth in this declaration, and I am competent to testify about them.

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3.

As Vice President for International Programs at WSU, I have responsibility for

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WSU’s international research activities, study abroad programs, international students, and

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student and faculty exchanges. I am the chief international relations officer at WSU and am

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responsible for the role of International Programs in carrying out WSU’s mission of global

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engagement, which is “To apply knowledge through local and global engagement that will

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improve quality of life and enhance the economy of the state, nation, and world.” I also manage

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WSU’s programs focusing on establishing strategic partnerships with governments and

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educational institutions across the globe.

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4.

WSU’s global presence includes active research programs in dozens of countries

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worldwide and study abroad programs in over 70 countries worldwide. The University also has

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matriculated undergraduate, graduate, and professional students and visiting scholars from many

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countries worldwide.

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5.

WSU has obtained its final enrollment numbers for the spring 2017 semester.

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The University has 157 students from the six countries targeted in the revised Executive Order.

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Many of these students are on single-entry visas and could be denied re-entry if they left the

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United States. As a result of the Executive Order, these students will be unable to have family

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and colleagues join or visit them this semester and into the summer. In addition, because of the

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uncertainty surrounding whether they would be allowed back into the country and what will

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happen after the 90-day period, many of them have decided to forego international travel or

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conference activities related to their research, or to visit family.

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6.

As an example, one Iranian graduate student, who is in year two of his Ph.D.

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program, has decided not to leave the country to visit his family until he finishes his degree,

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which means he will not see his family for several years. In addition, students who otherwise

DECLARATION OF ASIF CHAUDHRY

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ATTORNEY GENERAL OF WASHINGTON
332 French Administration Building
PO Box 641031
Pullman, WA 99164-1031
[phone]

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would leave the country to carry out dissertation research fear they may not be permitted to

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return to the country to defend their dissertations. These students are under constant stress, their

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research programs are being negatively impacted, and many are having difficulty focusing on

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their studies.

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7.

Other students and faculty are impacted as well. WSU has seven (7) visiting

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scholars from the six affected countries. One Iranian post-doctoral fellow has a husband who is

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Iranian but currently lives in Germany. He applied for a dependent visa in January to join her in

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the United States, but it has not yet been issued. The visa likely will not be issued prior to the

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effective date of the order, which means her husband will not be able to join her. She is afraid

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to visit her husband in Germany, as well as her mother in Iran, for fear of being denied re-entry

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into the United States.

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8.

Another WSU student has a fiancé who is Iranian and lives in Iran. The fiancé

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was scheduled to be interviewed for permanent residency in May 2017. That interview has now

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been canceled and she cannot come to the United States.

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9.

The revised Executive Order, as well as the previous one, have created an

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atmosphere in which international students and faculty feel unwelcome in the United States.

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This is directly affecting WSU. For example, after several years of increasing international

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enrollments, WSU is seeing a significant decline this year. WSU’s Department of Teaching and

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Learning has reported that this year’s international application numbers have dropped

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dramatically. Last year, the Department processed 63 international student applications for its

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Special Education program, and this year it processed ten. Applications from international

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students for other programs also are down. These declines have an economic impact on WSU

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as well as the individual College and Departments.

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10.

WSU has six (6) undergraduate student applicants for fall 2017 from countries

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targeted in the Executive Order, compared with 12 for fall of 2016. Two of these students have

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been offered admission, and one has confirmed intent to enroll. These students now need to

DECLARATION OF ASIF CHAUDHRY

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ATTORNEY GENERAL OF WASHINGTON
332 French Administration Building
PO Box 641031
Pullman, WA 99164-1031
[phone]