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

Filing 118

Second MOTION to Amend Complaint, filed by Plaintiff State of Washington. (Attachments: # 1 Complaint Second Amended, # 2 Exhibit Exhibits to Second Amended Complaint, # 3 Index of Declarations, # 4 Decl. of R. Althaibani, # 5 Decl. of S. Amin, # 6 Decl. of B. Callaghan, # 7 Decl. of S. Dadgari, # 8 Decl. of A. Elfgeeh, # 9 Decl. of N. Fallah, # 10 Decl. of H. Ghasemzadeh, # 11 Decl. of E. Hassett, # 12 Decl. of A. Mubarez, # 13 Decl. of S. Parsian, # 14 Decl. of Z. Rasouli, # 15 Decl. of A. Shayegan, # 16 Decl. of J. Sime, # 17 Decl. of R. Branon, # 18 Decl. of A. Chaudhry, # 19 Decl. of D. Eaton, # 20 Decl. of D. Heatwole, # 21 Decl. of S. Hemmati, # 22 Decl. of R. Lewin, # 23 Decl. of A. Mehrizi-Sani, # 24 Decl. of V. Rabinowitz, # 25 Decl. of J. Riedinger, # 26 Decl. of V. Shah, # 27 Decl. of J. Wasserheit, # 28 Decl. of J. Wasserheit, # 29 Decl. of J. Wood, # 30 Decl. of N. Zimpher, # 31 Decl. of S. Buell, # 32 Decl. of R. Fullerton, # 33 Decl. of P. Johnson, # 34 Decl. of A. Lavine, # 35 Decl. of D. Pashman, # 36 Decl. of M. Rosenn, # 37 Decl. of M. Saunders, # 38 Decl. of J. Simeone, # 39 Decl. of D. Soike, # 40 Decl. of S. Topiwala, # 41 Decl. of J. Truppman, # 42 Decl. of R. Zawaideh, # 43 Decl. of M. Akhtari, # 44 Decl. of M. de Leon, # 45 Decl. of R. Eskandari, # 46 Decl. of T. Johnson, # 47 Decl. of E. Scherzer, # 48 Decl. of W. Berkovitz, # 49 Decl. of D. Duea, # 50 Decl. of L. Warren, # 51 Proposed Order) Noting Date 3/31/2017, (Melody, Colleen)

DECLARATION OF
RITA ZAWAIDEH

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The Honorable James Robart
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
STATE OF WASHINGTON and
STATE OF MINNESOTA,

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Plaintiffs,
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CIVIL ACTION NO. 2:17-ev-00141-JLR

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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; REX
TILLERSON, in his official capacity
as Secretary of State; and the UNITED
STATES OF AMERICA,

DECLARATION OF RITA ZAWAIDEH

Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, RITA ZAWAIDEH, hereby declare as follows:
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1. I am over the age o1' 18 and competent to be a witness, I am a resident of the State of
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Washington. I am the founder and owner of Caravan-Serai, Inc, Caravan-Serai is a tour
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company located in Seattle that organizes tours to the Middle East and North Africa
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exclusively, I have been in business for 30 years. Since 2003, Caravan-Serai has been rated
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by Conde Nast Traveler magazine as a Top Travel Specialist,
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DECLARATION OF RITA ZAWAIDFH

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2. I am also the founder of Salaam Cultural Museum (SCM). SCM is a 501(c)(3) nonprofit

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organization that focuses on the specific task of bringing relief and aid to people affected

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by conflict and natural disaster within the Middle East and North Africa (MENA) region,

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and to bring people and cultures together to build bridges of understanding. SCM organizes

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medical and humanitarian missions to Greece and Jordan to assist Syrian refugees fleeing

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from the civil war in their country. I founded SCM in 1990.

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3. Since President Trump issued his first Executive Order on January 27, 2017, Caravan-

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Serai's business has completely evaporated. I had 4 tours of Iran that I had to cancel. Each

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of these tours had about 12 clients. I have also had to cancel around 20 Foreign Independent

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Travel tours for 1 or 2 individuals each. My customers have told me that they are simply

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afraid to travel because they are concerned about whether they will be able to reenter the

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United States when they return from their trip. Even U.S. citizens have told me that they are

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afraid to go.

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4. I have also had to cancel all planned SCM medical humanitarian missions. These are

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missions that I organize to send physicians and other health care professionals to Greece

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and Jordan to provide medical care to Syrian refugees. The physicians and other

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professionals who would go, many of whom are natives of the Middle East and North Africa

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but are U.S. citizens, have also told me that they are afraid to go on the mission for fear of

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not being able to reenter the U.S. or being subjected to severe harassment and scrutiny by

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U.S. Customs and Border Protection upon their return.

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5. I normally would organize a medical humanitarian mission every 45 days, and they would

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consist of 15 to 20 physicians and other health care professionals. Currently, I cannot

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organize any because of the participants' fears as noted above.

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6. The President's Executive Order of January 27, 2017, as well as the second one scheduled

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to become effective of March 16, has caused my business to lose almost all of its revenue.

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So far, I have not laid off any of my employees, because I value and appreciate their efforts

DECLARATION OF RITA ZAWAIDEH

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and loyalty. However, I cannot continue to employ them indefinitely if I have absolutely no

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income from wi)icli to pay them.

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

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Executed on this

day of

March,

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nIrA -7 tllA trA-cu

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241
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DECLARATION OF RITA Z,AWAIDEH

201 , at Seattle, Washington.