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)

DECLARATION OF
KIANA EHSANI

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON, et al.,

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Plaintiffs,
v.

CIVIL ACTION NO. 2:17-cv-00141-JLR
DECLARATION OF KIANA EHSANI

DONALD TRUMP, et al.,
Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Kiana Ehsani, hereby declare as follows:
1. I am over the age of eighteen and competent to testify herein.
2. I live in Washington State.

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3. I am originally from Iran.

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4. I came to the United States in September 2015 to earn my PhD in computer science at

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University of Washington. I am here on a single entry visa.
5. For the first six months, I suffered from depression because I couldn’t go to visit my
family and they couldn’t come to visit me. They had been attempting to get a visa

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

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appointment but because there were only a few number of appointments available in

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the embassies assigned for Iran, they were not able to get any. Getting homesick

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affected my personal and academic life such that I had to take some days off of school
and use the medical help to get back to normal life. My mom finally got an
appointment in February 2016 and got her visa in May 2016. She came to the US in

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summer 2016 and I was able to see her after more than 10 months. After she came to

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US, my depression got better and I was able to have my normal life again without

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taking any therapy sessions and everything was fine until the first executive order, then

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I had to take therapy again.
6. That same summer of 2016, my dad went to get the visa but he was rejected. In January

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2017, I travelled to the peace arch state park to see my dad in the canadian border. We
met there in the park. I totally felt like being a prisoner who is having a visitor. We

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were not able to exchange gifts, we were not able to spend more than few hours

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together, we had to stay in the park and there was no indoor area so we both got a very

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severe flu because of the cold and rainy weather.

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7. After I came back from the park, the news about the first travel ban came out. I was
extremely disappointed. I even got some reactions from the people in the street when I
was talking in Persian to my friends, “go to your country”, “our president will kick you

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out” and the things that really hurt me and broke my heart. This has never happened to

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me before the executive orders and I believe that publicly announcing this ban gave

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these people the permission to express their hate to immigrants and foreigners.

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2

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

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8. My goal in coming to the United States and the University of Washington was to
pursue making an opportunity to achieve academic progress, attend conferences and
contribute to the computer science community. Unfortunately, due to travel issues and
having a single entry visa, I missed attending several conferences such as, European
Conference on Computer Vision 2016, Neural Information Processing Systems 2016,

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International Conference on Computer Vision 2017. These conferences are the main

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conferences in my field and there also some important workshops in these conferences

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about the new technologies and methods in the field which are not published anywhere

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else and can be very informative and helpful for research in computer vision. I will not
have a visa that allows me to leave and re-enter the United States before October 18,

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2017.
9. My mother has been suffering from cancer and she has received chemotherapy for 6

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months. Because she was afraid that I would go to her and not be able to return to the

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school because of my single-entry visa, she didn’t tell me about her sickness. When I

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found out, I felt absolutely guilty for not being there in her sickness to help her.

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10. In March 2017, my mom went to the embassy again to get the visa to come and visit
me. Until the time of writing this letter, we still haven’t heard anything from the US
consulate.

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11. I haven’t seen my mom for more than a year now and other family members for more

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than two years. If the President’s September 24, 2017 Proclamation goes into effect, I

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have decided that despite being a successful student with a GPA of 3.8, successful

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research experiences under supervision of Ali Farhadi in the University of Washington

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

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Computer Science & Engineering Department which is ranked 6th in computer science

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nationwide, received a master’s degree, done a very successful internship at Google and

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having many job offers from different companies such as, dropbox, NVIDIA, Disney
research and many others, I am quitting the program and leaving school in December
2017 to go back to Iran and visit my family. Due to the fact that my family, especially

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my mom and my brother, will be prohibited from coming and visiting me here, I am not

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certain that I would apply for another visa or consider coming back to finish my PhD.

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I declare under penalty of perjury that the foregoing is true and correct.

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Executed on this 4_ day of October, 2017

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________________________________________
Kiana Ehsani

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