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

Filing 98

DECLARATION of Janet Billups in Support of State of Oregon's Motion to Intervene filed by Plaintiff State of Oregon re 94 MOTION to Intervene Attorney Scott J Kaplan added to party State of Oregon(pty:pla) (Kaplan, Scott)

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1 2 3 4 IN THE UNITED STATES DISTRICT COURT 5 FOR THE WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 STATE OF WASHINGTON, et al., 8 Plaintiffs, Case No. C17-0141JLR 9 DECLARATION OF JANET BILLUPS v. 10 DONALD J. TRUMP, et al., 11 Defendants. 12 13 14 I, Janet Billups hereby declare and affirm as follows: 15 1. I have personal knowledge of the facts set forth in this declaration and I am 16 competent to testify about them. 17 2. I am General Counsel and Senior Vice President of Oregon Health and Sciences 18 University, in Portland, Oregon. 19 3. Oregon Health & Sciences University is Oregon's public academic medical 20 center. It is comprised of the degree-granting schools of dentistry, medicine, nursing, public 21 health and pharmacy; multiple scientific research institutes; the OHSU Hospital and 22 Doernbecher Children's Hospital; and several pediatric and adult ambulatory care clinics in the 23 Portland area. As part of its statutory state-wide mission, as set by the legislature and governed 24 by a board appointed by the Governor of the State of Oregon, OHSU also provides patient care 25 services and educational and training programs for its students throughout Oregon. 26 1 - DECLARATION OF JANET BILLUPS SP3/rh2/8035718-v1 OREGON DEPARTMENT OF JUSTICE 100 SW Market Street Portland, OR 97201 (971) 673-1880 / Fax: (971) 673-5000 1 4. OHSU's student body includes over 115 international students and trainees from 2 six continents and 34 countries. Its hospitals employ a diverse and international medical staff, 3 and its schools and research institutes employ a diverse and international faculty. 4 5. OHSU has at least 15 individuals from the countries subject to the Executive 5 Order: six students, two post-doctoral fellows, one Research Assistant Professor, and six Medical 6 Residents, including three green card holders. The school is expecting two more post-doctoral 7 fellows from Iran (one Iranian citizen, one Canadian citizen born in Iran) if the travel ban is 8 stayed. 9 6. As with any university, the loss of students and professors from the seven 10 countries included in the Executive Order would have a direct impact on the students, the 11 professors, and their colleagues and the advancement of science, which uniquely draws upon the 12 synergy of collaborations from scientists around the world 13 7. The delivery of medical care to Oregonians will also be severely compromised 14 should OHSU lose any of its medical residents (Residents). Residents are medical school 15 graduates receiving advanced training in the specialties of surgery, cardiology, and pathology. 16 Residents have an exceptionally important service function in the hospitals and outpatient clinics 17 where they train. For example, Residents in procedurally oriented disciplines such as surgery 18 serve as the first assistant in procedures, and losing them is analogous to flying a commercial 19 aircraft without a co-pilot. Emergency, middle-of-the-night medical care is delivered on the 20 front line by Residents who sleep in the hospital. Examining tissue and diagnostic test results for 21 disease diagnosis is a critical function performed by Residents. 22 8. Although all Residents work under the tutelage of their faculty instructors, they 23 perform a considerable amount of front-line and hands-on work as part of that proctored training. 24 Senior-level Residents in particular provide upper level, sophisticated patient care service. 25 OHSU will lack the necessary work force to adequately provide those services if these 26 Residents' visas are revoked or the Residents are banned from traveling back to the U.S. upon 2 - DECLARATION OF JANET BILLUPS SP3/rh2/8035718-v1 OREGON DEPARTMENT OF JUSTICE 100 SW Market Street Portland, OR 97201 (971) 673-1880 / Fax: (971) 673-5000 1 necessary travel abroad. Replacing experienced, senior Residents is exceptionally difficult and 2 rare, particularly since this is not just employment, but an accredited higher education training 3 program. 4 9. The number of Resident slots is capped programmatically by the Accreditation 5 Counsel for Graduate Medical Education, so there is no ability for an academic medical center to 6 simply "staff up" their Resident corps in advance to ensure coverage in case a Resident is 7 abruptly removed from the program. Residency programs are thus tightly coupled and team8 based with each member of the residency team having a critical role. The loss of even one 9 Resident to a program carries a very high risk of adversely impacting OHSU's capability to 10 deliver the patient care that the State of Oregon expects, and that Oregonians rely upon. 11 I declare under penalty of perjury that the foregoing is true and correct. 12 13 14 DATE net Billups ( 15 16 17 18 19 20 21 22 23 24 25 26 3 - DECLARATION OF JANET BILLUPS OREGON DEPARTMENT OF JUSTICE 100 SW Market Street Portland, OR 97201 (971) 673-1880 / Fax: (971) 673-5000 SP3/rh2/8035718-v1

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