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)

DECLARATION OF
ALI MEHRIZI-SANI

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON, and
STATE OF MINNESOTA,
Plaintiffs,
CIVIL ACTION NO. 2:17-cv-00141-JLR

v.
DONALD TRUMP, in his official
capacity as President of the United
States; U.S. DEPARTMENT OF
HOMELAND SECURITY; JOHN F.
KELLY, in his official capacity as
Secretary of the Department of
Homeland Security; REX W.
TILLERSON, in his official capacity
as Secretary of State; and the UNITED
STATES OF AMERICA,

DECLARATION OF ALI MEHRIZISANI

Defendants.
Pursuant to 28 U.S.C. § 1746(2), I, ALI MEHRIZI-SANI, hereby declare as follows:
1. I am over the age of eighteen and competent to testify herein.
2. I am a professor at Washington State University in the School of Electrical Engineering and
Computer Science.
3. I have the following information about one of our students who has been irrevocably harmed
by the President’s executive orders:
DECLARATION OF ALI MEHRIZI-SANI

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ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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One of my Iranian Ph.D. students received an 8,500 Euro scholarship from the Austrian

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Marshall Plan Foundation (which started as a U.S. Department of State program after

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World War II as part of the European Recovery Program) to spend about six months at

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Graz University of Technology (TU Graz) in my collaborator's laboratory and work on
new experiments for one of my research projects funded by the U.S. National Science
Foundation. Unfortunately, the student is now planning on not traveling outside the

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United States as he cannot know if he will be allowed to come back to finish his doctoral

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program. The student is an Iranian citizen and cannot leave the United States without

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running the risk that he will not be able to obtain a new visa in order to return to

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Washington. The planned collaboration is now on hold.

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I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 12th

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day of March, 2017

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________________________________________
ALI MEHRIZI-SANI

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DECLARATION OF ALI MEHRIZI-SANI

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ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]