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SECOND DECLARATION OF TAHER HERZALLAH

CAIR LEGAL DEFENSE FUND

Lena F. Masri (D.C. Bar # 1000019) (pro hac vice)

Email: lmasri@cair.com

Gadeir I. Abbas* (VA Bar # 81161) (pro hac vice)

Email: gabbas@cair.com

Carolyn M. Homer (D.C. Bar # 1049145) (pro hac vice)

Email: chomer@cair.com

453 New Jersey Ave., SE

Washington, DC 20003

Phone: (202) 742-6420

Fax: (202) 379-3317

KELLY / WARNER, PLLC

8283 N. Hayden Road, Suite 229

Scottsdale, Arizona 85258 

Raeesabbas Mohamed, Esq. (AZ Bar # 027418)

Email: raees@kellywarnerlaw.com

Phone: (480) 331-9397

Fax: (866) 961-4984

Attorneys for Plaintiffs 

* Licensed in VA, not in D.C.

Practice limited to federal matters

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

PHOENIX DIVISION

American Muslims for Palestine, and 

Dr. Hatem Bazian

Plaintiffs,

vs.

Arizona Board of Regents on behalf of 

Arizona State University, and 

Mark Brnovich, in his official capacity 

as Attorney General of Arizona

Defendants.

Case No. CV-18-670-PHX-JJT

Second Declaration of Taher 

Herzallah on behalf of American 

Muslims for Palestine, in support of 

Plaintiffs’ Opposition to Defendants’ 

Motion to Dismiss

Case 2:18-cv-00670-JJT Document 28-2 Filed 05/14/18 Page 1 of 5
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– 1 – SECOND DECLARATION OF TAHER HERZALLAH

DECLARATION OF TAHER HERZALLAH 

1. I am Taher Herzallah, the Associate Director of Outreach &

Community Organizing for American Muslims for Palestine (“AMP”). I previously 

submitted a declaration in support of Plaintiffs’ Motion for a Preliminary Injunction 

See Dkt. 9-2. I have personal knowledge of the facts set out in this Second 

Declaration. If called upon as a witness I would competently testify as to the 

matters stated herein.

2. On April 3, 2018, the Muslim Students Association of Arizona State

University (“MSA”) held an event on the Boycott, Divestment and Sanctions 

Movement at Arizona State University. I spoke at the event on behalf of American 

Muslims for Palestine. Dr. Hatem Bazian, the founder and chair of American 

Muslims for Palestine, also spoke. The event was a success. Holding campus 

events like this is core to the educational and advocacy mission of American 

Muslims for Palestine.

3. Due to the success of the event, the MSA has invited myself and Dr.

Bazian to come back to campus next academic year. A true and correct copy of the 

May 8, 2018 invitation we received is attached as Exhibit A. We have not yet set a 

date for next year’s event, but we are working with the new MSA student board to 

find a mutually agreeable one.

4. As I detailed in my First Declaration, my job as the Associate Director

of Outreach & Community Organizing means acting as a liaison between AMP and 

communication and student associations across the United States. Due to the 

success of the April 3, 2018 event at ASU, we are exploring opportunities for AMP 

Case 2:18-cv-00670-JJT Document 28-2 Filed 05/14/18 Page 2 of 5
1 to participate in other advocacy events within Arizona. This has included

2 preliminary discussions about whether Dr. Bazian and myself could combine next 3 year's trip with a visit to the University of Arizona.

5. I remain concerned that Arizona Revised Statutes§ 35-393.01 will 5 operate to block American Muslims for Palestine's advocacy efforts in the state of 6 Arizona. For example, I am aware that the Arizona Board of Regents currently has 7 a "No Boycott oflsrael" clause for speaker contracts at the University of Arizona. I

8 have reviewed these contracts on the University of Arizona's "Contracting FAQs"

9 website, https:/ ;Jpacs.arizona.eduVcon/tracting fags.

10 6. I verify under penalty of perjury under the laws of the United States

11 that the foregoing is true and correct.

12 Executed on May _fl, 2018 at n//,; c/u,rtl'( Virginia.

13 

14 By:M15 

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-2-

Case 2:18-cv-00670-JJT Document 28-2 Filed 05/14/18 Page 3 of 5
Exhibit A

Case 2:18-cv-00670-JJT Document 28-2 Filed 05/14/18 Page 4 of 5
Case 2:18-cv-00670-JJT Document 28-2 Filed 05/14/18 Page 5 of 5