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
HANNANEH
HAJISHIRZI

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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10 STATE OF WASHINGTON, et. al.,
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Plaintiff,
v.

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

13 DONALD TRUMP, et.al.,
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DECLARATION OF HANNANEH
HAJISHIRZI

Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Hannaneh Hajishirzi, hereby declare as follows:
1. I am over the age of eighteen and competent to testify herein.
2. I came to the United States from Iran in 2003 to study computer science at the University

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of Illinois.
3. After completing my degree and receiving a post-doctoral degree from Carnegie Mellon

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and Disney Research, I joined the University of Washington as an Assistant Research

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Professor of Electrical Engineering. I have taught courses in Artificial Intelligence to more

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

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than hundred UW students, advised more than 10 graduate and undergraduate students,

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and brought millions of dollars funds to the university through gifts and research grants

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from government and industry.
4. I became a U.S. citizen on April, 2016.
5. My parents still live in Iran. They are both currently retired. My mother was an education

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administrator at a high school, and my father was an instructor in the traffic department.

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6. I petitioned for immigrant visas on my parents’ behalf on April 2016. I started the petition

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because my husband and I were starting a family and wanted to have them come to the

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United States to visit us. Although my parents completed their consular interview in April
2017, their visa applications are still pending.

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7. I recently gave birth to a baby girl and I’m hoping that my parents will be able to visit
their new granddaughter.

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8. However, with the President’s September 24, 2017 proclamation, I’m afraid they will

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never be able to visit us in the United States. The President’s proclamation bars Iranians

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from receiving immigrant visas indefinitely. This means my parents may never be able to

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share our lives in the United States.
9. If the proclamation goes into effect, my husband and I are thinking of applying for jobs in
Canada, where the immigration policies are not discriminatory and my parents would be
able to visit us.

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10. If that happens, the University of Washington will lose one but two of its professors. My

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husband, also an Iranian American, is an Associate Professor at the University of

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

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Washington. He has worked for the University of Washington since 2012 and teaches

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Artificial Intelligence and Machine Learning in the Computer Science department.

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I declare under penalty of perjury that the foregoing is true and correct.
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Executed on this ____ day of October, 2017

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________________________________________
Hannaneh Hajishirzi

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