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
ALI FARHADI

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON, et al.,
Plaintiffs,

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v.

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

DONALD TRUMP, et al.,

DECLARATION OF ALI FARHADI

Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Ali Farhadi, 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 an Associate Professor in the Computer Science Department at the University of
Washington (UW).

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4. I have taught more than hundreds of Washington students about Artificial Intelligence

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(AI), Machine Learning, and Computer Vision. I have advised numerous students

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through their PhDs, and have brought millions of dollars to UW in research grants, gifts

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

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and other funding. I am also co-founder and CEO of a successful startup in Seattle,

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have developed game-changing technologies in AI, is bringing multiple millions of

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dollars in revenue to Seattle, and employing several top talent for the state.

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5. I am married to Hannaneh Hajishirzi who is a professor in the electrical engineering
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department at University of Washington. Similar to myself, my wife has also taught

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several of Washington students, brought millions of dollars in funding and has advised

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several PhD students.

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6. With this travel ban, my young daughter cannot see her grandparents because they will

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not have visas to enter the United States by October 18, 2017. As immigrants, we don’t

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have any families in the US and the only connection with our family is through

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grandparents traveling to Seattle. I hope I don’t need to explain that I don’t want my
daughter not to have any memories or relations with our parents. This is what is left

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from family life for us and thanks to the new ban we don’t even have that option

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anymore.

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7. If the new travel ban is implemented, we are left with only one option: leaving the
United States.

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

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Executed on this _9___ day of October, 2017

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________________________________________
Ali Farhadi

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