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

Filing 67

AFFIDAVIT A. Chaudhry filed by Plaintiff State of Washington (Melody, Colleen)

Case 2:17-cv-00141-JLR Document 67 Filed 02/09/17 Page 1 of 4

1
2
3
4
5
The Honorable James L. Robart

6
7
8

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

9
10
11

STATE OF WASHINGTON,
Plaintiff,

12
v.

13
14
15
16
17
18

NO. 2:17-cv-00141-JLR
THIRD DECLARATION OF ASIF
CHAUDHRY

DONALD TRUMP, in his official
capacity as President of the United States;
U.S. DEPARTMENT OF HOMELAND
SECURITY; JOHN F. KELLY, in his
official capacity as Secretary of the
Department of Homeland Security; TOM
SHANNON, in his official capacity as
Acting Secretary of State; and the
UNITED STATES OF AMERICA,
Defendants.

19
20

I, Asif Chaudhry, hereby declare and affirm:

21

1.

I am the Vice President for International Programs at Washington State

22

University (WSU). I have made further inquiries regarding current applicants to WSU from

23

countries targeted by the Executive Order entitled “Protecting the Nation from Foreign Terrorist

24

Entry Into the United States.” Based on those inquiries, I provide the following additional

25

information. I have personal knowledge of the facts set forth in this declaration, and I am

26

competent to testify about them.

THIRD DECLARATION OF ASIF
CHAUDHRY

1

ATTORNEY GENERAL OF WASHINGTON
332 French Administration Building
PO Box 641031
Pullman, WA 99164-1031
[phone]

Case 2:17-cv-00141-JLR Document 67 Filed 02/09/17 Page 2 of 4

1

2.

Several WSU students from targeted countries have had to forego international

2

travel and conference activities related to their research. One student in WSU’s College of

3

Agricultural, Human, and Natural Resource Sciences, who is from Iran, was registered for an

4

academic conference in Canada scheduled to take place February 5 - 8, 2017. His WSU

5

department paid for the conference. The receipt, made out to his department chair, is attached

6

as Exhibit A. The department also planned to cover his travel expenses. Due to the executive

7

order, the student was unable to attend the conference.

8

3.

WSU currently has one (1) graduate student applicant for the 2017 summer term

9

and fifty-three (53) graduate student applicants for the 2017 fall semester from the countries

10

targeted by the Executive Order. If these students were offered admission and accepted, they

11

would pay a minimum of $42,216 per academic year in tuition and fees to WSU. If they were

12

unable to obtain visas, were denied entry, or decided that study in the United States was no longer

13

feasible, WSU could lose as much as $2,279,664 per academic year in revenue.

14

4.

In addition, WSU currently has one (1) admitted undergraduate and six (6)

15

undergraduate applications pending for the 2017 fall semester from prospective students from

16

the countries targeted by the Executive Order. These students would pay a minimum of $41,628

17

per academic year in tuition and fees to WSU. If these students were unable to obtain visas,

18

were denied entry, or decided that study in the United States was no longer feasible due to the

19

Executive Order, WSU could lose as much as $291,396 in revenue per academic year.

20

5.

21

the United States.

22
23
24

Ten (10) of the applicants, graduate and undergraduate, currently are already in

I declare under penalty of perjury under the laws of the State of Washington that the
foregoing is true and complete to the best of my knowledge.
Dated this 9th day of February, 2017.

25
__________________________________
Asif Chaudhry, Ph.D.

26

THIRD DECLARATION OF ASIF
CHAUDHRY

2

ATTORNEY GENERAL OF WASHINGTON
332 French Administration Building
PO Box 641031
Pullman, WA 99164-1031
[phone]

Case 2:17-cv-00141-JLR Document 67 Filed 02/09/17 Page 3 of 4

Chaudhry
Declaration
Exhibit A

Case 2:17-cv-00141-JLR Document 67 Filed 02/09/17 Page 4 of 4

A