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)

SECOND
DECLARATION OF
MELANIE DE LEON

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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,

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v.

CIVIL ACTION NO. 2:17-cv-00141-JLR

13 DONALD TRUMP, et al.,
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SECOND DECLARATION OF
MELANIE DE LEON

Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I Melanie de Leon, hereby declare as follows:

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1.

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Commission (“Medical Commission”) and have personal knowledge of the facts set forth in this

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declaration.

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2.

I am the Executive Director of the Washington State Medical Quality Assurance

The Medical Commission regulates all allopathic physicians and physician assistants

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practicing on Washington patients through licensing discipline, rulemaking and education.

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

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3. The Medical Commission’s mission, as set forth in statutes RCW 18.71 and 18.71A, is to

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protect public health and promote the integrity of the profession. The health and well-being

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of the people of Washington are of paramount importance and the conduct of those licensed

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to practice medicine and surgery in this state plays a vital role in preserving this health and
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well-being.

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4. Information regarding the applicant’s country of birth is not available prior to 2008, and

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is only captured on the original licensing application, not subsequent renewals; therefore

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reported statistics involving this information may underrepresent the true numbers of

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applicants or licensees from any given location, either inside or outside of the United States.

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5. Out of the 13,727 licenses issued or reactivated since 2008, the following indicates the

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number of active licensees who indicate the following countries as their birth country:
Iran

80
Pending (in process) 3
Iraq
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Pending (in process) 1
People’s Republic of North Korea
3
Libyan Arab Jamahiriya
6
Pending (in process) 1
Somalia
2

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Syrian Arab Republic

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Pending (in process) 3
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Pending (in process) 1
Pending (in process) 1

Venezuela
Yemen

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6. The Medical Commission also issues limited licenses for residents, fellows and
teaching and research.

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

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a. Residency licenses are issued to physicians who have completed all of the
requirements for licensure except for completion of two years of postgraduate
training and have been appointed as a resident physician in a program of

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postgraduate clinical training in Washington. The Medical Commission has
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issued active limited licenses to eight applicants from Iran.
b. Upon nomination by the dean of the school of medicine of the University of

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Washington or the chief executive officer of any hospital or appropriate health

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care facility licensed in the state, the Medical Commission may issue a limited

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license to an applicant selected by its designated sponsoring institution to be
enrolled in one of its designated departmental or divisional fellowship

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programs. Fellowship programs provide focused training in a narrow specialty
area. There is currently one active fellowship license issued to an applicant

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from Iran and one active fellowship license to an applicant from Libya.

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c. Upon nomination by the dean of the school of medicine of the University of

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Washington or the chief executive officer of any hospital or appropriate health
care facility licensed in the state, the Medical Commission may issue a limited
license to a physician applicant invited to serve as a teaching-research member

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of the institution’s instructional staff. There is currently one active teaching and
research license issued to a physician from Venezuela. .

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7. The Medical Commission has found it appropriate to license applicants who may have

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completed all or a portion of their medical training in an international setting. Based upon

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census data gathered in October 2017, the Medical Commission has 3391 active licensees

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

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who were internationally trained. Of this number, 80 active licensees received all or part of

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their medical education in Iran, 14 active licensees from Iraq, three active licensees from

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North Korea, six active licensees from Libya, two active licensees from Somalia, 24 active

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licensees from Syria, seven active licensees from Venezuela and one active licensee from
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Yemen.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 6th day of October, 2017

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________________________________________
Melanie de Leon, JD, MPA
Executive Director
Medical Quality Assurance Commission

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