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
KHADIJEH
SHEIKHAN

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The Honorable James L. Robart

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON; STATE
OF CALIFORNIA; STATE OF
MARYLAND; COMMONWEALTH
OF MASSACHUSETTS; STATE OF
NEW YORK; and STATE OF
OREGON,

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

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Plaintiffs,
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v.
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DONALD TRUMP, in his official
capacity as President of the United
States; U.S. DEPARTMENT OF
HOMELAND SECURITY; ELAINE
C. DUKE, in her official capacity as
Acting Secretary of the Department of
Homeland Security; REX
TILLERSON, in his official capacity
as Secretary of State; and the UNITED
STATES OF AMERICA,

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Defendants.
Pursuant to 28 U.S.C. § 1746(2), I, Khadijeh Sheikhan, hereby declare as follows:
1. I am a resident of New York, and I have Iranian citizenship.

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2. I am a third-year computer science PhD student at New York University and am
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scheduled to graduate in 2021.

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3. I specialize in Computational Geometry. My research helps large companies in the

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technology industry, such as Google. I completed an internship at Google this past

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summer.

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ATTORNEY GENERAL OF NEW YORK
120 Broadway
New York, NY 10271-0332

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4. I had a multiple entry visa that expired in August 2017. Although I have a student visa,
I am afraid that if the Proclamation issued on September 24, 2017, remains in effect, I
will be unable to return to the United States to complete my education if I depart.

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5. The issuance of the travel ban Executive Orders has had a negative impact on my
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studies as well as on my personal life. For instance, the Executive Orders have limited

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my ability to travel for academic reasons. I need to be able to travel internationally in

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order to complete my research in the narrow field of computational geometry.

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6. Prior to the travel ban announced in the Proclamation, I planned on traveling to
Brussels in January 2018 to attend a research group spearheaded by my advisor, who
recently moved there. I have placed these plans on hold due to concern that I will not be

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allowed to return to the United States once I leave. As a result, I will miss obtaining
critical feedback on my research from my advisor, as well as opportunities to
collaborate with other researchers in my field.

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7. The travel ban Executive Orders have also limited my ability to travel for personal

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reasons. My mother, father, and five siblings live in Iran. Because of the travel ban

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announced in September 2017, I am not sure when I will see my family again. My

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husband, who is also a citizen of Iran, is a computer science PhD student at Stony
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Brook University. His father passed away so he frequently has to visit his mother in

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Iran, who now lives alone. The travel ban impacting Iranian nationals prevents my

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husband from going to Iran to visit his mother. If my husband cannot visit his mother,

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we both may have to quit our PhD programs and return to Iran.

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ATTORNEY GENERAL OF NEW YORK
120 Broadway
New York, NY 10271-0332

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8. Moreover, the travel ban Executive Orders have limited my opportunities for post-

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graduation employment. Even though remaining in the United States post-graduation

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would increase my opportunities for employment, the Executive Orders have caused me

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to reconsider whether staying in the United States would be the best choice for me.
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Because of these Orders, I remain uncertain about when I will be able to see my family

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again and whether I will be able to travel as required to further my education. This has

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placed a substantial emotional burden on me and my family.

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I declare under penalty of perjury that, to the best of my knowledge, the foregoing is true
and correct.

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Executed on this 11th day of October, 2017

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_______/s/_______
Khadijeh Sheikhan

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ATTORNEY GENERAL OF NEW YORK
120 Broadway
New York, NY 10271-0332