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
HEMA
YOGANARASIMHAN

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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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Plaintiffs,
v.

CIVIL ACTION NO. 2:17-cv-00141-JLR
DECLARATION OF HEMA
YOGANARASIMHAN

13 DONALD TRUMP, et al.,
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Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Hema Yoganarasimhan, 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 United States. I am permanent resident.

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3. I am an Associate Professor at the University of Washington Foster School of Business.
4. My work is of relevance to consumers, firms, and public policy. For example, in one of

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recent papers, I examine issues at the intersection of privacy and mobile advertising. In

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another of my papers, I examine how groups of decision-makers become polarized and

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

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how polarization can affect consumer welfare. In another of my award-winning papers,

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I examine how digital firms can develop better reputation mechanisms.

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5. The newly proposed travel ban will have significant negative consequences for the UW

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Foster Marketing Department and our Phd students. It will negative impact the research
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and teaching mission of our school, we need to recruit and retain the best talent at all
levels, especially PhD students.

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6. The impact of the ban on our PhD students is significant and negative. Their parents,

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siblings and other important family members will not be able to visit them in the US,

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and given the lengthy extreme vetting process for being able to come back, they will
not able to leave the US during their studies. This means that they will not be able to

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see their family members for 5-6 years.
7. Because of the negative consequences of the President’s executive orders and

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September 24, 2017 Proclamation, it has become increasingly difficult for us to recruit

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talented PhD students from Iran. We have around 10 PhD students at the Foster

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Business School right now and I am personally advising two of them. This year, several

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students who would have normally come to US universities, possibly to the University

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of Washington, decided to go to universities in Canada or England because of the new
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barriers, and given that the new travel ban is indefinite, we expect this situation to only

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get worse going forward.

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My two current students (as well as any we could recruit in the future) are very valuable to

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the school. First, they jointly work on research with our faculty and help produce cutting-

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edge research that is useful to US businesses and is of relevance to US consumers.

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

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Second, we expect to place these students in the top business schools across the US as

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faculty. This will increase the impact and standing of Foster Business School. Third, they

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serve as teaching assistants in many of our important courses and help the teaching

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mission of the school.
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By taking away our opportunity to recruit such talent, the administration is hampering our

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ability to do high quality research, high quality teaching, and enhance the reputation of our

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school.

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

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Executed on this _9th day of October, 2017

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________________________________________
Hema Yoganarasimhan

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