Case 2:17-cv-00141-JLR Document 6 Filed 01/30/17 Page 1 of 4

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON,

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DECLARATION OF AYESHA
BLACKWELL-HAWKINS, ESQ.

Plaintiff,
v.
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,

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Defendants.

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Pursuant to 28 U.S.C. § 1746(2), Ayesha Blackwell-Hawkins hereby declares as
follows:
1. I am over the age of eighteen and competent to testify.

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2. I am Senior Manager of Mobility and Immigration at Amazon.com, Inc. and its

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subsidiaries ("Amazon"). I manage the team that is responsible for providing
immigration supp01t for employees and their dependent families and ensuring lawful

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DECLARATION OF
AYESHA BLACKWELL

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immigration to and from the various countries in which Amazon operates. I have
been employed in this capacity since 2009.

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3. Amazon employs more than 40,000 employees in the State of Washington and more

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than 180,000 employees in the United States. Our employees come to us from every

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comer of the United States and every comer of the world.
4. From the very beginning, Amazon has been committed to equal rights, tolerance, and
diversity - and we always will be. As we've grown the company, we' ve worked hard

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to attract talented people from all over the world, and we believe this is one of the

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things that makes Amazon great - a diverse workforce helps us build better products

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for customers.

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5. The Executive Order, "Protecting the Nation from Foreign TelTorist Entry into the

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United States, signed by President Trump on January 27, 2017 (the "Executive

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Order") immediately - and negatively - impacted employees, dependents of
employees, and candidates for employment with Amazon.

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6. Because the Executive Order suspends entry into the United States of "aliens from

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countries referred to in section 217(a)(12) of the INA, 8 U.S.C. 1187(a)(12)" it is

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unclear whether it applies to only citizens of identified countries or anyone born in

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those countries irrespective of their culTent citizenship or visa status. It is also unclear

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whether the suspension applies to employees with dual citizenship (in both an

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identified and non-identified counh·y). In order to comply with the order and to
ensure the safety of our employees, we assume the Executive Order covers both

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scenarios.
7. Amazon is currently aware of 49 employees born in one of the countries identified in

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the Executive Order. 47 in that group currently have citizenship in another country.

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The remaining two employees hold pe1manent residence in another country. These

DECLARATION OF
AYESHA BLACKWELL

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employees work in the United States lawfully pursuant to Jl, H-lB, E-3, TN, LPR
and L-1 A visas.
8. One example of an impacted employee is a senior Amazon lawyer who was born in

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Libya but has been a UK citizen for many years. This employee had plans to travel to

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the United States for business during the month of February. We have instructed the

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employee to cancel her plans and remain in the UK rather than risk being denied
entry to the United States.

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9. Amazon is also currently aware of 10 dependents of Amazon employees born in one

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of the countries identified in the Executive Order. These dependents live in the

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United States lawfully pursuant to H-lB, L-lB, E-3, LPR, F-1 OPT, and TN visas.

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10. We reached out to impacted Amazon employees and dependents and recommended
that they refrain from travel outside of the United States until further notice. Fmiher,
we have advised any such individuals who are living outside of the United States,
with current plans to visit the US for business or personal reasons, to cancel those

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plans until the entry restrictions are lifted.

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11. Amazon is also currently aware of 7 candidates for employment who have received

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offers for employment with Amazon. All of these candidates were born in Iran, but

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are currently citizens of Ge1many, Canada, and Australia. We are currently assessing

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alternatives that could include placement in countries other than the United States.

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12. The Executive Order has impacted more than just Amazon employees, dependents,
and candidates. Asghar Farhadi, the Iranian director of the film, The Salesman, is

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similarly prohibited under the language of the Executive Order from attending the

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Academy Awards in Los Angeles, where his film is a nominee for Best Foreign Film.

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Amazon's subsidiary, Amazon Studios, is the distributor of the film.

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DECLARATION OF
AYESHA BLACKWELL

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13. Finally, my team is continuing to receive of inquiries from employees who are not

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immediately impacted, but who are seriously concerned about their ability to travel

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and the potential expansion of the Executive Order.

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I declare under penalty of pe1jury that the foregoing is true and correct.

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Ill

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Ill

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Ill
Executed this

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DECLARATION OF
AYESHA BLACKWELL

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3~of January, 2017.