State of Washington, et al., v. Trump., et al

Filing 202

NOTICE of Lodging Additional Declarations re 198 Amended Complaint, ; filed by Plaintiffs Commonwealth of Massachusetts, State of California, State of Maryland, State of New York, State of Oregon, State of Washington. (Attachments: # 1 Updated Imdex of Declarations in Support of Third Amended Complaint, # 2 Decl of Negin Ingbrigtsen, # 3 2nd Decl of Sadaf Amin, # 4 Decl of Janet Billups, # 5 Decl of Janet Camp, # 6 Decl of Susan Capalbo, # 7 2nd Decl of Margaret Everett, # 8 Decl of Anke Schennink, # 9 2nd Decl of Lovely A. Warren, # 10 Decl of Wim Wiewel, # 11 Decl of Lydia Wood, # 12 Decl of Joseph E. Fahey, # 13 2nd Decl of Aaron O. Lavine, # 14 2nd Decl of Eric Scherzer, # 15 3rd Decl of Eric Scherzer)(Melody, Colleen)

SECOND
DECLARATION OF
SADAF AMIN

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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,

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Plaintiffs,
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v.

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

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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,
Defendants.
Pursuant to 28 U.S.C. § 1746(2), I, Sadaf Amin, hereby declare as follows:
1. I am a resident of New York, and I have Iranian citizenship.
2. I am a PhD Student at Weill Cornell Medicine-Medical College of Cornell University. I

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moved to New York City in August 2011 from my hometown of Tehran, Iran with the
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goal of engaging in cutting edge biomedical research.
3. Currently, I am conducting research on stem cells to develop new models and drug

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candidates for diabetes which will pave the way to use precision medicine for the

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treatment of this devastating disease.

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

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4. However, I had to make sacrifices on the way. I have not seen my family in Iran since
2011 because, as a holder of a single entry F-1 student visa, if I leave the United States I
need to obtain authorization to reenter the country. Based on the experiences of fellow

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international students, I know that this process can take weeks if not months. I could not
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risk such delays since, among other things, the extended absence could jeopardize my
research.

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5. The travel bans on Iranian nationals implemented pursuant to the March 6, 2017 Executive

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Order and the recent Presidential Proclamation have created an even greater emotional

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burden. Whereas I had been willing to make the personal sacrifice of not seeing my family
for some time to achieve my goal of advancing research on diabetes, I never understood or

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expected this sacrifice to be permanent. While I am not sure that I can remain in this
country under such circumstances, I also cannot move to Canada or Europe without
upending my family because my fiancé is a U.S. citizen.

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6. The March 6, 2017 Executive Order prevented me from visiting my family as I was not

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eligible for a new visa to return to my life, my fiancé, and my research in the United

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States.

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7. Nor was my immediate family, who live in Iran, able to come visit me because of the entry
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restrictions on Iranian nationals under that Executive Order. My mother had been planning

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to visit me over the summer in New York, but cancelled her plans after the Executive

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Order was issued.

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8. My mother remains in Iran and has applied for a visa to come to the United States. She
was interviewed for the visa in June 2017, but has not yet received it.

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

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9. On September 27, 2017, the Executive Order’s “temporary ban” on entry of Iranian
nationals into the United States become an indefinite ban pursuant to Presidential
Proclamation.

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10. After September 27th, I inquired about the status of my mother’s visa application. I was
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told that the application was still being processed.
11. Because the baseline rule under the September 27th Proclamation is that no Iranian

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nationals will be granted immigrant or nonimmigrant visas, with the exception of some

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student visas, I am doubtful that my mother will be granted a visa. I do not know whether

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or when she could receive a waiver and be permitted to visit me. The possibility that she
will be unable to visit me for the indefinite future is distressing and contributes to my

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uncertainty about whether to remain in the United States.
I declare under penalty of perjury that the foregoing is true and correct.

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Executed on this 11th day of October, 2017

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/s
Sadaf Amin

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