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
PARISA
HOSSEINZADEH

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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 PARISA
HOSSEINZADEH

13 DONALD TRUMP, et al.,
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Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Parisa Hosseinzadeh, hereby declare as follows:

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1. I am over the age of eighteen and competent to testify herein.

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2. I live in Washington State. I am a US Legal Permanent Resident.

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3. I am an Iranian postdoctoral researcher in the Department of Biochemistry at the
University of Washington. As a member of institute for protein design, I work on
developing new computational and biochemical tools that can help generate better more
efficient drugs.
4. My current research is supported by the National Institutes of Health as well as the
Washington Research Foundation (WRF). The WRF’s forming vision is to capture and
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ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
[phone]

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enhance the value of intellectual property arising from Washington State’s research

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institutions in order to support additional research and scholarship. My research

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contributes to this advancement in important technology for Washington State and the
health of everyone through more efficient drugs.
5. I came to the US in 2010 to pursue my PhD in Biochemistry at the University of

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Illinois at Urbana-Champaign. I then moved to Seattle in the beginning of 2016 to learn

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about protein design and engineering.

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6. The events of this last year have sparked some doubts in me. I was planning to go back
home for our new year celebration right when travel ban 1.0 happened. Although I am a
permanent legal resident of the US, I didn't feel safe going back, so I decided to stay

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despite all the planning I had done for being home and celebrating the new year with
my family after 7 years. It was devastating. I was sitting home looking at all the

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souvenirs I bought for my family members, and sobbing in silence. I was basically

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non-functional those days. Everyday I would catch myself crying in a corner in the lab.

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I finally went back home in May 2017 and it helped me immensely to have been able to

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have contact with my parents and my sister. When I got back, I no longer felt depressed
and I managed to finish up my work and submit my research paper to Science
magazine for publication.
7. My mom retired in September 2017 and we were planning for her and my dad to visit

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me in Seattle in Spring 2018. But then she called me and asked me about the new travel

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ban. I didn't know about it then and when I read it I was extremely sad and angry. My

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mother and other family members do not have visas to visit me and will not have them

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

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by October 18, 2017. This new travel ban means that my parents, my only sister, and

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everyone else from my family can never visit me, NEVER. I cannot understand how

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this makes sense. Even prisoners with highest charges have visitors. I cannot call a
place home where my beloved ones are prohibited from entering it.
8. Right now, I am thinking seriously about leaving the US. It is a hard decision to make. I

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have many friends here and I am well attuned to the culture, environment, and work.

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The US is somewhat my home. I came here when I was 20 years old and I practically

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got socially mature here. I would not want to leave here if it were not for the travel ban.

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9. I think no one should need an explanation as to why they want their family to be able to
visit them. Here are just a few reasons: 1. I want to have them in my life and want them

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to be able to attend important events in my life, such as birth of my children. 2. I need
to know there is a way for my family to come visit me in case of emergency. Life is not

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always rosy. 3. I want to be able to bring my family here to be with them when they

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need me without leaving my job for a long time. 4. I cannot call a place home where

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my parents are prohibited from entering it. 5. Parents never feel you are safe in a place

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until they see that place and live in there for a while themselves. 6. It simply feels good
to take your parents for a walk in your neighborhood and show them around.
10. Because of the travel ban, I will not be able to function efficiently. I will have to fear

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everyday that maybe the next ban will force me out. I will have to live like a second-

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tier resident deprived of essential rights as a human. I will have to face my kids and try

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to explain why they are being treated differently just because of their parents' place of

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

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birth. I believe that a relaxed and healthy mental state is essential for productivity. The

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new travel ban 3.0 will definitely take that away from me and my work.

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

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Executed on this ____ day of October, 2017

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____________________
Parisa Hosseinzadeh

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