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 SHOJAIE

1
2
3
4
5
6
7
8
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

9

10 STATE OF WASHINGTON, et al.,
11
12

Plaintiffs,
v.

CIVIL ACTION NO. 2:17-cv-00141-JLR
DECLARATION OF ALI SHOJAIE

13 DONALD TRUMP, et al.,
14

Defendants.

15
16
17

Pursuant to 28 U.S.C. § 1746(2), I, Ali Shojaie, hereby declare as follows:

18

1. I am over the age of eighteen and competent to testify herein.

19

2. I live in Washington State.

20

3. I have a PhD and am a faculty member at the University of Washington School of

21
Public Health. In addition to training graduate and undergraduate students in
22
23

Biostatistics and Biomedical Data Science, my research develops Machine Learning

24

tools for analyzing Biomedical Big Data (BBD). These tools help biomedical

25

researchers decipher underlying mechanisms of complex diseases, from cancer and

26

cardiovascular diseases to neurological disorders. Therefore, my research and
1

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

1

educational activities at UW help the United States maintain its position as the leader in

2

biomedical research, by providing tools for analyzing Biomedical Big Data, and

3

training the next generation of Biomedical Scientists.

4
4. I am a dual US/Iranian citizen.
5
6

5. Three years ago, my younger sister was diagnosed with Multiple Sclerosis (MS). This

7

was, of course, devastating news, and affected her life and other members of my

8

family. Being away from her, all I could do is to lend emotional support and to help

9

uplift her spirit as she battles MS. After three years of therapy, my sister has been

10
11

starting to feel better and I had planned for her to visit us in Seattle so that she can
spend time with her nieces, travel in the US and forget about her disease for a short

12
13
14

while. In fact, I had even prepared an invitation letter for my sister and she was
planning to get an appointment from the US embassy to apply for tourist visa.

15

However, she will not have her visa by October 18, 2017. The new Visa Ban would put

16

an indefinite hold on all of these plans. As a result, it would limit my ability to play a

17

significant role in my sister’s recovery! My siblings and I lost our father at a young age,

18

when I was in high school. Being the eldest, I have tried very hard to fill my father’s

19
absence for my younger brother and sister over the years. Of course, being away from
20
21

them, my support has primarily been emotional in recent years. It is thus even more

22

disheartening to not be able to help my younger sister because of the proposed Visa

23

Ban. The Visa Ban would also limit the extent to which my two young daughters could

24

interact with their extended family. It would deprive them from much needed love that

25
26
2

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

1

could only be provided by family members, and would limit their exposure to their

2

Iranian heritage.

3

6. As a faculty at UW School of Public Health, I have a demanding career. I also have two

4
young daughters, ages 4.5 and 2.5. As a result, I have very limited time to travel and
5
6

visit my family in Iran, particularly to take my daughters there so they can see their

7

extended family and learn about their culture. The Visa Ban would limit my ability to

8

interact with family members and help them when needed. Moreover, like any other

9

parent, I want my young daughters to be surrounded by family members as they

10
11

celebrate their accomplishments and milestones. The Visa Ban would thus also deprive
the next generation of Iranian-Americans from being able to benefit from the love and

12
13
14

support of their extended family members. I would have to consider all these
limitations and reassess my options as I continue my career at UW.

15
16

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

17
18

Executed on this _9th_ day of October, 2017

19
20
21

________________________________________
Ali Shojaie

22
23
24
25
26
3

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