WOODHULL FREEDOM FOUNDATION et al v. UNITED STATES OF AMERICA et al

Filing 5

MOTION for Preliminary Injunction by HUMAN RIGHTS WATCH, ERIC KOSZYK, JESSE MALEY, THE INTERNET ARCHIVE, WOODHULL FREEDOM FOUNDATION (Attachments: #1 Declaration of K. D'Adamo, #2 Declaration of R. Levy, #3 Declaration of D. Pokempner, #4 Declaration of E. Koszyk, #5 Declaration of J. Maley, #6 Declaration of B. Kahle, #7 Declaration of A. Lutnick, #8 Declaration of A. Levy, #9 Declaration of K. Mehlman-Orozco, #10 Text of Proposed Order)(Corn-Revere, Robert)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WOODHULL FREEDOM FOUNDATION,
HUMAN RIGHTS WATCH, ERIC KOSZYK,
JESSE MALEY, a/k/a ALEX ANDREWS, and
THE INTERNET ARCHIVE,
Plaintiffs,
v.
THE UNITED STATES OF AMERICA
and JEFFERSON B. SESSIONS, in his
official capacity as ATTORNEY GENERAL
OF THE UNITED STATES,
Defendants.

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Case No. _______________

DECLARATION OF DINAH POKEMPNER
FOR PLAINTIFF HUMAN RIGHTS WATCH
Pursuant to 28 U.S.C. § 1746, I, DINAH POKEMPNER hereby declare as follows:
1.

I am the General Counsel of Plaintiff Human Rights Watch, Inc. (“HRW”). The

facts contained in the following affidavit are known to me of my own personal knowledge and if
called upon to testify, I could and would completely do so.
2.

HRW is a 501(c)(3) tax-exempt organization based in New York, NY that

monitors human rights conditions worldwide and advocates for the cessation and remediation of
human rights violations worldwide. HRW advocates for respect of the human rights of sex
workers around the world, including in the United States, and since 2013, for the
decriminalization of sex work.
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3.

Human Rights Watch (“HRW”) is one of the key international human rights

monitoring organizations, that sees its mission as exposing violations of international human
rights law to public scrutiny around the world and generating momentum for change. Among
those violations are exploitation and violence directed at women and girls, including women and
girls who are sex workers.
4.

Sex workers, like other types of workers, may experience a wide range of human

rights violations. Some may be trafficked or held in conditions akin to modern slavery; others
may be subjected to violence, coercion, health risks or other dangerous conditions through their
work. HRW believes that the criminalization of sex work impedes sex workers in finding
protection and redress for such violations and in exercising basic rights such as access to
essential health services and police protection.
5.

Every year, HRW produces and publishes many hundreds of reports, press

releases, videos, podcasts and other online documents on its website and social media accounts.
Some of these include research and advocacy on behalf of the rights of sex workers, including
our advocacy that sex work be decriminalized. For example, in 2010, HRW reported on the
unlawful arrests and detention of sex workers in Cambodia; in 2012, HRW reported on police
searches of women for condoms as evidence of prostitution in four US cities; in 2013, HRW
documented torture, beatings and other assaults by police officials against sex workers, and
similar abuses against sex workers in Tanzania; in 2014, HRW advocated against a Canadian
anti-prostitution bill. HRW has also documented abuses against sex workers in the United States,
Lebanon and South Africa.
6.

Human Rights Watch’s policy, adopted in 2013, opposes the criminalization of

consensual adult sex work and states that the criminalization of voluntary, consensual sexual

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