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

Filing 194

MOTION for Leave to File Third Amended Complaint, filed by Plaintiffs Commonwealth of Massachusetts, State of California, State of Maryland, State of New York, State of Washington, Intervenor Plaintiff State of Oregon. (Attachments: # 1 Complaint 3rd Amended, # 2 Index of Exhibits, # 3 Index of Declarations, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Exhibit K, # 15 Exhibit L, # 16 Exhibit M, # 17 Exhibit N, # 18 Decl of Joint Former National Security Officials, # 19 Decl of Nima Ala, # 20 2nd Decl of Rabyaah Althaibani, # 21 Decl of Alireza Ayoubi, # 22 Decl of Shervin Beygi, # 23 Decl of Bahareh Bina, # 24 Decl of Ethan Devenport, # 25 Decl of Yasaman Esmaili, # 26 Decl of Mahdi Hajiaghayi, # 27 Decl of Mojdeh Jalali Heravi, # 28 Decl of Vahid Jazayeri, # 29 Decl of Mohammad Shafiei Khadem, # 30 Decl of Ahmad Moghaddam, # 31 Decl of Younes Nouri, # 32 Decl of Proshat Parsimoghadam, # 33 Decl of Emad Soroush, # 34 Decl of Tannaz Sattari Tabrizi, # 35 Decl of Seyed Danial Vaezi, # 36 Decl of Banafsheh Samareh Abolhasani, # 37 Decl of Armin Alaghi, # 38 Decl of Pegah Jalali Asheghabadi, # 39 3rd Decl of Rovy Branon, # 40 5th Decl of Asif Chaudhry, # 41 Decl of Maryam Dadkhahan, # 42 Decl of Jason Detwiler, # 43 2nd Decl of David Eaton, # 44 Decl of Kiana Ehsani, # 45 Decl of Ali Farhadi, # 46 Decl of Hoda Farhadi, # 47 Decl of Maryam Fayazi, # 48 Decl of Mohammad Ghaedi, # 49 Decl of Anne Greenbaum, # 50 Decl of Hannaneh Hajishirzi, # 51 2nd Decl of Deirdre Heatwole, # 52 Decl of Parisa Hosseinzadeh, # 53 Decl of Adam Mokhalalati, # 54 Decl of Shima Nofallah, # 55 4th Decl of Jeffrey Riedinger, # 56 Decl of Solmaz Shakerifard, # 57 Decl of Khadijeh Sheikhan, # 58 Decl of Ali Shojaie, # 59 Decl of Hema Yoganarasimhan, # 60 2nd Decl of Kathy Oline, # 61 2nd Decl of Dave Soike, # 62 2nd Decl of Rita Zawaideh, # 63 2nd Decl of Mitra Akhtari, # 64 2nd Decl of Melanie de Leon, # 65 Decl of Payam Fotouhiyehpour, # 66 2nd Decl of Marc Overbeck, # 67 2nd Decl of Sana Parsian, # 68 Decl of Sahar Z. Zangenah, # 69 2nd Decl of Dennis Galvan, # 70 Proposed Order) Noting Date 10/16/2017, (Melody, Colleen)

DECLARATION OF
BAHAREH BINA

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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10 STATE OF WASHINGTON, et al.,
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Plaintiffs,
v.

CIVIL ACTION NO. 2:17-cv-00141-JLR
DECLARATION OF BAHAREH BINA

13 DONALD TRUMP, et al.,
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Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Bahareh Bina, hereby declare as follows:
1. I am over the age of eighteen and competent to testify herein.
2. I live in Washington State.

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3. I am originally from Iran. I came to the United States in 2011. I am a green card holder.

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4. I have a very rare kind of cancer and recently found out the tumor is spreading in my

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body. I am getting to the stage that I cannot travel anymore. If the President’s

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September 24, 2017 Proclamation goes into effect, my parents will be prevented from
getting to the US to take care of and be with me. I am super worried that I will never

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ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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get another chance to be with them again. I have so many issues to deal with right now

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related to my disease, and this ban is yet another painful problem on top of those.

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5. I was diagnosed with cancer two years ago, right before my 30th birthday. I was so
lucky that, coincidentally, my parents were visiting me at the time of the diagnosis.
They extended their stay for 8 months to help me go through the complicated treatment

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as I had to stay in the hospital for five days every three weeks. They had just planned to

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stay in the US for a month, but as we Iranians cannot get a multiple entry visa to the

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US, they decided not to go back as it would be too risky and time consuming for them

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to get another visa. My mom lost a lot of money in her business back at the time, but it
was the only option we had. After they left, we found out that I needed to continue the

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same treatment and I asked them to come back and help me. They applied for the US
visa right away. However, it took them 8 months to get the visa. They could make it to
the US right after my treatment and when I didn’t need their help as much.

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6. I need my parents to be able to come and help me. I need them to be here with me. If

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the President’s September 24, 2017 Proclamation is implemented, I will not be able to

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have my parents with me even though I need them to be.

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I declare under penalty of perjury that the foregoing is true and correct.
Executed on this ____6 day of October, 2017
________________________________________
Bahareh Bina

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ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]