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
JUDITH WOOD

1
2
3
4

5
6

7
8

UNITED STATES DISTMCT COURT
WESTERN DISTRICT OF WASHINGTON

9
10

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

11
Plaintiff,

12
13

14
15
16
17

DECLARATION OF JUDITH WOOD

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

18

Homeland Security; TOM SHANNON,
in his official capacity as Acting
Secretary of State; and the UNITED

19

STATES OF AMERICA,

20

Defendants.

21
22
23

24
25

26

I, Judith Wood, hereby declare and affirm:
1. I have personal knowledge of the facts set forth in this declaration and I am
competent to testify about them.
2. I am Senior Manager of Program Operations of Continuum College at the

University of Washington. My responsibilities include administration of the Visiting

DECLARATION OF
JUDITH WOOD

ATTORNEY GENERAL OF WASHINGTON

1
2
3

4
5

6
7
8
9
10
11
12
13
14
15
16
17

18
19
20
21
22
23
24
25

International Student Internship and Training (VISIT) program, which permits undergraduate
and graduate students pursuing degrees at universities outside of the United States to participate
in full-time supervised research and work-based learning experiences at the University of
Washington (UW), a top research university. Each intern is hosted by a UW academic
department or program and is supervised by a member of the faculty from the department or
program. Each internship may be between 3 weeks and 12 months long. Interns must also hold
a J-l student intern visa for the duration of their internships.
3. As part of the process in preparing to hosting a VISIT intern, the supervising
faculty member is required to design a Training/Intemship Placement Plan that the intern will
follow while they are at the UW. There are other human resources expended by the University
in processing and setting up a VISIT internship, including the processing of the Form DS-2019

or "Certificate of Eligibility for Exchange Visitor (J-l) Status" required by the U.S. Department
of State.
4. I am aware of the U.S. Presidential Executive Order entitled "Protecting the
Nation from Foreign Terrorist Entry Into the United States" issued on January 27, 2017, which I
understand prohibits any person who is a citizen of any one of seven countries (Iran, Iraq, Libya,
Somalia, Sudan, Syria, and Yemen) from entering the U.S. for ninety days.
5. I am aware of two participants accepted into the VISIT program who were
affected by the Executive Order referenced above. Each intern was scheduled to start their
respective internships at the UW during the ninety-day ban imposed by the Executive Order. (It
is my understanding that these are the same two interns referenced in the Second Declaration of

Jeffrey Riedinger, Vice Provost for Global Affairs at the UW, which is on file in this case.)
6. I am aware that on Febmary 3, 2017, a judge in the U.S. District Court Western
District of Washington issued a temporary restraining order that restrained the enforcement of
the Executive Order referenced above.

26

DECLARATION OF 2 ATTORNEY GENERAL OF WASHINGTON
JUDITH WOOD

7. Based on an email message sent to my office by the department hosting one of the

2

3
4
5
6
7
8
9
10
11
12

13
14
15
16
17
18
19
20
21
22

internships, it is my understanding that one of the VISIT interns referenced above, who is a
citizen of one of the seven countries where he is pursuing his PhD., was only able to enter the
U.S. because of the February 3, 2017 temporary restraining order. Had this order not been
issued, the intern would not have been able to come to the UW to start his internship in the

medical field. The UW also would have lost the one time VISIT program fee paid by the intern
in the amount of $1,250.00 plus the quarterly registration fee of $45.00 for each academic
quarter the intern was at the UW for the VISIT program. (His internship is expected to last four
academic quarters.) The academic department hosting the intern would have also lost the benefit
of the intern's participation in research and collaboration.
8. Based on an email message sent to my office by the department hosting the other
internship, it is my understanding that the second affected VISIT intern, who is a citizen of one
of the seven countries included in the Executive Order, where he is pursuing his PhD., decided to
cancel his internship at the UW in one of the science related departments after the Executive
Order was issued. This happened after the UW expended human resources in preparing for the
intern's arrival. The UW also will lose the quarterly registration fee of $45.00 for each of
academic quarters the intern was to be engaged in his internship (which was expected to last
three academic quarters). (The hosting academic department had agreed to cover the applicable
program fee.)
I declare under penalty of perjury under the laws of the State of Washington that the
foregoing is tme and complete to the best of my knowledge.
Dated this 9th day of February, 2017.

23

24
25 11 MjrfiTH woo6r"'
26

DECLARATION OF 3 ATTORNEY GENERAL OF WASHINGTON
JUDITH WOOD