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

Filing 194

MOTION for Leave to File Third Amended Complaint, filed by Plaintiffs Commonwealth of Massachusetts, State of California, State of Maryland, State of New York, State of Washington, Intervenor Plaintiff State of Oregon. (Attachments: # 1 Complaint 3rd Amended, # 2 Index of Exhibits, # 3 Index of Declarations, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Exhibit K, # 15 Exhibit L, # 16 Exhibit M, # 17 Exhibit N, # 18 Decl of Joint Former National Security Officials, # 19 Decl of Nima Ala, # 20 2nd Decl of Rabyaah Althaibani, # 21 Decl of Alireza Ayoubi, # 22 Decl of Shervin Beygi, # 23 Decl of Bahareh Bina, # 24 Decl of Ethan Devenport, # 25 Decl of Yasaman Esmaili, # 26 Decl of Mahdi Hajiaghayi, # 27 Decl of Mojdeh Jalali Heravi, # 28 Decl of Vahid Jazayeri, # 29 Decl of Mohammad Shafiei Khadem, # 30 Decl of Ahmad Moghaddam, # 31 Decl of Younes Nouri, # 32 Decl of Proshat Parsimoghadam, # 33 Decl of Emad Soroush, # 34 Decl of Tannaz Sattari Tabrizi, # 35 Decl of Seyed Danial Vaezi, # 36 Decl of Banafsheh Samareh Abolhasani, # 37 Decl of Armin Alaghi, # 38 Decl of Pegah Jalali Asheghabadi, # 39 3rd Decl of Rovy Branon, # 40 5th Decl of Asif Chaudhry, # 41 Decl of Maryam Dadkhahan, # 42 Decl of Jason Detwiler, # 43 2nd Decl of David Eaton, # 44 Decl of Kiana Ehsani, # 45 Decl of Ali Farhadi, # 46 Decl of Hoda Farhadi, # 47 Decl of Maryam Fayazi, # 48 Decl of Mohammad Ghaedi, # 49 Decl of Anne Greenbaum, # 50 Decl of Hannaneh Hajishirzi, # 51 2nd Decl of Deirdre Heatwole, # 52 Decl of Parisa Hosseinzadeh, # 53 Decl of Adam Mokhalalati, # 54 Decl of Shima Nofallah, # 55 4th Decl of Jeffrey Riedinger, # 56 Decl of Solmaz Shakerifard, # 57 Decl of Khadijeh Sheikhan, # 58 Decl of Ali Shojaie, # 59 Decl of Hema Yoganarasimhan, # 60 2nd Decl of Kathy Oline, # 61 2nd Decl of Dave Soike, # 62 2nd Decl of Rita Zawaideh, # 63 2nd Decl of Mitra Akhtari, # 64 2nd Decl of Melanie de Leon, # 65 Decl of Payam Fotouhiyehpour, # 66 2nd Decl of Marc Overbeck, # 67 2nd Decl of Sana Parsian, # 68 Decl of Sahar Z. Zangenah, # 69 2nd Decl of Dennis Galvan, # 70 Proposed Order) Noting Date 10/16/2017, (Melody, Colleen)

SECOND
DECLARATION OF
DAVID EATON

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UNITED STATES DISTMCT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON, et al.,

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Plaintiffs,
V.

CW1L ACTION NO. 2:17-cv-00141-JLR

DONALD TRUMP, et al.,
Second Declaration of David L. Baton
Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, David L. Baton, hereby declare as follows:
1. I have personal knowledge of the facts set forth in this declaration and I am
competent to testify about them.
2. I am the Dean of the Graduate School of the University of Washington ("UW").
I have held this position for more than four years. My responsibilities in this position

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include overseeing admissions of all graduate students for all three campuses of the University of
Washington (Seattle, Bothell, and Tacoma), and the review and evaluation of over 350 different
graduate degrees in 126 graduate programs.
1 ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188

[phone]

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3. I understand that a newly issued Presidential Proclamation imposes certain
restiictions on the issuance of visas to persons from eight countries, Syria, Libya, Iran, Somalia,
Chad, Yemen, Venezuela and North Korea.

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4. I have reviewed with my staff the updated Graduate School records relating
to the enrollment of graduate students for the current (Autumn 2017) quarter. Based on that

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review, I have determined that the UW has currently enrolled, to date, a total of 105

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graduate students from four of the eight listed countries (none are from Chad, North Korea,

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Yemen or Syria) who are not permanent residents of the United States. I have also reviewed
the application data for graduate admissions that have been received by the Graduate School

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for future quarters. To date we have received applications for future quarters - Winter 201 8

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through Autumn 2018 - from a total of 30 potential students, from every country on the list except
for Chad and North Korea. A chart summarizing these statistics is attached as Exhibit A.
5. I am aware that at least two graduate students from one of the listed countries

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who were admitted for Autumn Quarter 2017, have recently contacted the Graduate School

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seeking to defer their enrollment because they have been unable to obtain visas.
6. The University has a strong policy of promoting diversity, openness and

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inclusion at all academic levels, and it actively encourages qualified students from around the

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world to come here and participate in our vibrant and globally connected academic community.

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I believe that every student from a different country brings a unique and valuable perspective

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to that community and thereby enriches the overall academic experience of all of our students.

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I am concerned that categorical restrictions placed on students and others coming from certain
countries will not only lead to a drop off in applications from those countries, but may also

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

[phone]

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negatively impact currently enrolled students from those countries, who may feel isolated from

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family and friends and may feel that they are not able to leave the U.S. without running a

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significant risk that they will not be able to return.

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Executed on this 10th day of October, 2017

Z^a^c^ ^ (^at^^

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

[phone]

Exhibit A

Total Registered Autumn 2017

Country of Citizenship

Registered

Chad

89

Iran

2

Libya
North Korea

4

Somalia

Syria

10

Venezuela
Yemen

TOTAL

105
Applications for future quarters (submited and un-submitted)

Country of Citizenship

WTR18

SPR18

SUM 18

TOTAL

AUT18

Chad
Iran

6

Libya

15

23

1

2

1
0

North Korea

1

2

Syria

1

1

Venezuela

2

2

Yemen

1

1

21

30

1

Somalia

TOTAL

2

1

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