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
SANA PARSIAN

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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,

CIVIL ACTION NO. 2:17-cv-00141-JLR
SECOND DECLARATION OF SANA
PARSIAN

v.

13 DONALD TRUMP, et al.,
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Defendants.
Pursuant to 28 U.S.C. § 1746(2), I, Sana Parsian, hereby declare as follows:
1. I am over the age of eighteen and competent to testify herein.
2. I am a Washington State resident.
3. I am a dual United States citizen and Iranian citizen.

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4. I came to the United States in 2010 to continue my education in radiology. I earned my

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MD from Tehran University of Medical Sciences in 2009. Last year, I completed my last

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year of residency as Chief Resident at the University of Washington Medical Center

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Diagnostic Radiology Residency.

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5. I currently work as a Breast Imaging Sr. Fellow and Acting Instructor at Seattle Cancer
Care Alliance. I help with early diagnosis of breast cancer by interpreting mammograms ,

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

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ultrasounds, breast MRIs and with biopsy of suspicious lesions. I also teach the radiology

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residents and work on my research project for which I was awarded a research grant last

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year.
6. I am affiliated with UW Medicine and Seattle Cancer Care Alliance.
7. My husband is a United States citizen. He was born in the United States. His parents are
from Iran.
8. My husband is a software developer and entrepreneur. He owns his own company with
more than 30 employees. He works very hard and his business is growing.
9. When I became a United States citizen, I felt like an American. Now, I am not sure
anymore and I feel like a second-class citizen. My husband and I are hardworking people

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and we have had many opportunities in the United States. Many Americans have
supported me on my journey and I am very thankful to this country and its kind people.

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However, because of the President’s September 24, 2017 Proclamation, I am uncertain

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about my future in the United States.

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10. My parents live in Iran. My mom is an English teacher and my dad was a statistics
professor at Tehran University, now retired. He got his PhD in the United States. Both of
my parents are getting old. They are both on medications and have new prescriptions
being added. As a doctor with the means to help them, it is my duty and right to care for
my parents in their old age.

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11. I applied for green cards for both of my parents in April 2016. My mom’s was approved

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in December 2016. She was coming here in January 2017, when the President’s first

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Executive Order banning travel from Iran went into effect. She was returned to Iran from

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

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Amsterdam and was not able to come to the United States until March 2017 when the first

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ban was lifted by the courts.

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12. My mom will not remain in the United States without my dad. Therefore, she has been
traveling to the United States every six months as opposed to staying here with me. It has
been hard on my mom to take flights that are over 20 hours every six months so that she

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can keep her green card. It is too hard on my mom to keep doing this specially given the

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indefinite nature of the new ban. She is constantly worried about my dad who has to live

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alone in our house in Iran when she is staying with me.

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13. My dad’s green card has been in the process of security check since December 2016. He
does not have any criminal history. I have no hope for him to get his green card or a travel

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visa before October 17, 2017. I do not know if he will ever be granted a green card or not
and I am not sure if I can get a waiver for him.

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14. This has resulted in a high degree of stress in my life. I am a doctor, but I am being

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prevented from taking care of my dearest loved ones, my parents. Every time I hear of a

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new medication being added to their list, it breaks my heart. It is my basic human right to

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be able to care for my family when they need me.
15. My plan has been to complete my fellowship in breast imaging and then to take a job as a
Radiologist in Tacoma/Olympia area. I received offers from all 4 practices that I applied

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to. However, the President’s September 24, 2017 Proclamation has made me reconsider

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my plan. I am not sure if I should remain in the United States if to do so requires me to

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abandon my parents when they need me most. If anything happens to them I can not

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forgive myself.

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

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16. Because of the President’s September 24, 2017 Proclamation, I am now planning to go to

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Iran in order to see my dad. I have not seen him now for 3 years. In addition to the time

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this will take me away from my work and research, this trip comes at a personal cost to
myself based on the likelihood of being targeted by Iran’s government given my dual
citizenship status. My parents have been warning me not to go because of several

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instances of dual citizens being targeted by Iran’s government. I now have no choice but

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to risk my own safety and carrier in order for me to see to my dad’s health and wellbeing.

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I declare under penalty of perjury that the foregoing is true and correct.
Executed on 3rd of October, 2017

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________________________________________
SANA PARSIAN

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