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
SHIMA NOFALLAH

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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 SHIMA
NOFALLAH

DONALD TRUMP, et al.,
Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Shima Nofallah, hereby declare as follows:
1. I am over the age of eighteen and competent to testify herein.
2. I live in Washington State and am a PhD student at the University of Washington.

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3. I am originally from Iran.

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4. I came to the United States last year, 2016, with my husband on an F2 visa. I had a

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strong resume and applied for the PhD program in Electrical Engineering at

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the University of Washington and got admitted. I applied for a status change from F2 to

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

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F1 inside the US and now I have a valid F1 status which means I don’t have a visa

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anymore, but a valid status to study in the US.

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5. My research is focused on diagnosis of Melanoma stages using Computer Vision and
Machine Learning techniques. The incident of Melanoma is rising so fast and ~1 in 50
U.S adults will be diagnosed with this disease each year. There is a high diagnosis error
in interpreting skin biopsies of melanocytic lesion; pathologists disagree in up to 60%
of cases of invasive melanoma, which can lead to substantial patient harm. That’s why
using machine learning techniques to train a computer and using the pattern to teach
pathologists is very important matter nowadays.
6. My husband is a second year PhD student in Marketing at University of Washington.
His research is focused on quantitative analysis of customer behavior data to propose
strategies in order to have a better marketing methods and increase company’s profit.
7. My parents do not currently have visas to come to the United States. With this new
travel ban, my parents cannot ever visit me. I lost my only sibling to Leukemia a few
years ago. My parents suffered a lot during that time. The possibility of not being able
to visit me for years is like they are losing another child. We are heartbroken.
8. My PhD program length is about 5 years. Neither I nor my parents can bear this

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situation for that long. If they cannot come here to visit me, both my husband and I will

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have to quit our program and go back to Iran. It is like wasting all of our years of hard

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work.

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

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

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Executed on this

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day of October 2017

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Shima Nofallah

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