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)

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DECLARATION OF RITA ZAWAIDEH 1 2 The Honorable James Robart 3 4 ,5 6 7 8 9 10 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON STATE OF WASHINGTON and STATE OF MINNESOTA, 11 Plaintiffs, 12 CIVIL ACTION NO. 2:17-ev-00141-JLR 13 14 15 16 17 18 19 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. 20 Pursuant to 28 U.S.C. ยง 1746(2), I, RITA ZAWAIDEH, hereby declare as follows: 21 1. I am over the age o1' 18 and competent to be a witness, I am a resident of the State of 22 Washington. I am the founder and owner of Caravan-Serai, Inc, Caravan-Serai is a tour 23 company located in Seattle that organizes tours to the Middle East and North Africa 24 exclusively, I have been in business for 30 years. Since 2003, Caravan-Serai has been rated 25 by Conde Nast Traveler magazine as a Top Travel Specialist, 26 DECLARATION OF RITA ZAWAIDFH 1 2. I am also the founder of Salaam Cultural Museum (SCM). SCM is a 501(c)(3) nonprofit 2 organization that focuses on the specific task of bringing relief and aid to people affected 3 by conflict and natural disaster within the Middle East and North Africa (MENA) region, 4 and to bring people and cultures together to build bridges of understanding. SCM organizes 5 medical and humanitarian missions to Greece and Jordan to assist Syrian refugees fleeing 6 from the civil war in their country. I founded SCM in 1990. 7 3. Since President Trump issued his first Executive Order on January 27, 2017, Caravan- 8 Serai's business has completely evaporated. I had 4 tours of Iran that I had to cancel. Each 9 of these tours had about 12 clients. I have also had to cancel around 20 Foreign Independent 10 Travel tours for 1 or 2 individuals each. My customers have told me that they are simply 11 afraid to travel because they are concerned about whether they will be able to reenter the 12 United States when they return from their trip. Even U.S. citizens have told me that they are 13 afraid to go. 14 4. I have also had to cancel all planned SCM medical humanitarian missions. These are 15 missions that I organize to send physicians and other health care professionals to Greece 16 and Jordan to provide medical care to Syrian refugees. The physicians and other 17 professionals who would go, many of whom are natives of the Middle East and North Africa 18 but are U.S. citizens, have also told me that they are afraid to go on the mission for fear of 19 not being able to reenter the U.S. or being subjected to severe harassment and scrutiny by 20 U.S. Customs and Border Protection upon their return. 21 5. I normally would organize a medical humanitarian mission every 45 days, and they would 22 consist of 15 to 20 physicians and other health care professionals. Currently, I cannot 23 organize any because of the participants' fears as noted above. 24 6. The President's Executive Order of January 27, 2017, as well as the second one scheduled 25 to become effective of March 16, has caused my business to lose almost all of its revenue. 26 So far, I have not laid off any of my employees, because I value and appreciate their efforts DECLARATION OF RITA ZAWAIDEH 1 and loyalty. However, I cannot continue to employ them indefinitely if I have absolutely no 2 income from wi)icli to pay them. 3 4 I declare under penalty of pei jury that the foregoing is true and correct. 5 6 Executed on this day of March, 7 8 nIrA -7 tllA trA-cu 9 10 12 13 14 15 16 17 18 19 20 21 22 j 23 241 25 1 26 DECLARATION OF RITA Z,AWAIDEH 201 , at Seattle, Washington.

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