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
SAHAR Z
ZANGENAH

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

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STATE OF WASHINGTON, et al.,

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Plaintiffs,
v.

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

DONALD TRUMP, et al.,

DECLARATION OF SAHAR Z
ZANGENAH

Defendants.

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Pursuant to 28 U.S.C. § 1746(2), I, Sahar Z Zangenah, 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.

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3. I am faculty at Fred Hutchinson Research Center in Seattle, WA. I am a faculty
statistician at the HIV Prevention network of the Vaccine and Infectious Disease division
of Fred Hutch. My research focuses on developing statistical methodology with

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substantive focus on design and analysis of HIV prevention trials. I work both on

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domestic (U.S) trials as well as international trials. In addition to research, I also

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

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occasionally teach a graduate course (Sample Survey Techniques) at the University of

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Washington.

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4. I am a dual US/Iranian citizen who has many family members still in Iran. I am fortunate
to be a U.S. citizen and have the luxury to be able to travel to Iran and visit our family.
However, due to my busy work schedule, I am unable to spend quality time with each
family member (most of our trips span less than two weeks).

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5. My husband is [my husband is also a dual US/Iranian citizen. He is a faculty at University

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of Washington School of Public Health. In addition to research, he also teaches to a broad

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audience at UW and mentors/advises graduate students.
6. We were planning to invite my 73 year old aunt to visit us for my 40th birthday which is

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coming up on March 22, 2018. My aunt is scheduled to have open-heart surgery in
October (she is scheduled to be admitted to the hospital on October 11th 2017) and this

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trip is planned to profoundly help her recovery. She first visited the U.S in 1978, when

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she came to help my parents with their first-born child (myself). I was born after her first

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open-heart surgery. My husband and I thought inviting her for my 40th birthday would

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be a great way to show our appreciation. Of course, it also meant a great deal for us to
have her celebrate with us along with our other family.
7. If the President’s September 24, 2017 Proclamation is implemented, none of these plans

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would be possible. More importantly, I would not be able to play any role in helping my

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aunt recover from her upcoming surgery; I remember spending many summers at her

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place in Tehran, and I was looking forward for an opportunity to give back for all she has

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done for me, by helping her get through her latest health battle.

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

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8. With two young children (two daughters ages 4.5 and 2.5), our family still has many

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milestones ahead of us. This travel ban would impair my right to invite anyone in my

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extended family to come and visit, whether it be for celebrating accomplishments and
major life events or seeking their help during times of transitions or hardships.
I declare under penalty of perjury that the foregoing is true and correct.

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Executed on this __9th__ day of October, 2017

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_________________________________

_______
Sahar Z Zangenah

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