SWORN AFFIDAVIT Arnay Dhawan was bern en March 22 RUDE. Mether: Pallaui Dhawan; Father: Sumeet Dhewan Lecatien: Madisen WI 531F113: Pregestatienal peried was unremarkable, theugh the decters carefuliy menitered my thyreid cenditien. At the time ef discharge, we were teld that i-?trnay had jaundice and apprepriate recemmendatiens were made fer his care and fellewed up with his pediatrician. He was successfully breastfeeding. He get sick a few days later and was feund te haye UrinaryTract Infectien. it prephaiactic dese ef antibietic was prescribed and Arnay was released. At heme, Arnay centinued te breastfeed and was grewing nermally as was cenfirmed by his pediatrician at his weeleteujl? days 3pp?if?ltl?1?lE?t.?t ?trnau's 3 menth appeintment, the pediatrician neticed unusual head circumference. [in further research, it was teld te be either craniesynestesis er micrecephaiy. His ethereyerall health was censidered te be unremarkable. He relied euer, sat at the regular time. We were asked te keep a watch en his deyelepmental milestenes and a referral was made te a UW Heurelegist. MRI at UW reyealed a just eyer the area in the brain that affects speech and memery. We were adyised that it deesn?t affect his deuelepmental delays and just keep a watch en it in case ef any medical cemplicatiens- Ne surgery er any ether interyentien was suggested at the time. Heweyer, there was a cen cern that his head sutures {seft spets er bands ef tissue that cennect the benes ef skull}, seemed te be clesing in prematurely. We then decided te take him te Maye fer a epinien with anether Neurelegist. At his referral te Clinic, he was teld te be Micrecephalic and Hypetenic ilew muscular tene fer his 3 menth age] and was ruled eut by deing it ray, that shewed sutures were still epen, thus ruling eut the need fer a surgery. l'yiicrecephali,r was teld te haye ne cure with a sherter life span. Either tests were dene te determine metabelic actiuities and all were nermai. We were asked te centinue with eur censultatiens with the UW hespital. Arnay was recemmended fer additienal assessment fer PT, speech and DT feliewed by therapy at heme. Censcieus decisiens and activities were erganised in day-te-day actiyities te premete deyelepment, beth physical and brain deyelepmental. Further assistance was seught frem early childheed. in para liel, Hindu custems and ceremenies were ebseryed aleng with birthdays that were yisited by family and friends. An 'Anna-prayesh' cerernenyi?peeja was dene when Arnay first receiyed selids. Arnay centinued te grew and was a censtant jey and pride te eyeryene areund him. Arnay always had uncenditienal suppert, leye and affectien, therapy, reutine medicatien and ether actiyities frem friends, therapists and family. Page 1ft?- hrnav's first birthdav was well erganized and celleagues alike. Despite all Wrnav's challenges. Arnav centinuecl te amaze the famil'v. Amav's needs always came first fcIr me. its a fellew up aneth er visit was made te ivlave clinic in when the decter advised it te be nermai in accerdance with his past findings. We were asked te centinue with the then advised treatment and bring him in case ef antir ef seizures er ether medical cempiicatiens. hrnav?s deflus surgerv was alse dene at UW Hespital fer his refius cenditien in Seprct befere his meve te lndia. When a meve te India due te Sumeet's jeb relcicatie'i was first suggested, a smeeth transitien frem medical and develepmental perspective were discussed and ebserved as well. At ?1 vr ef age. Arnav's milestenes were ebserved te be en track given his cenditien and he was said te be senserv. At heme, changes te include plav wav methed ef previding therapy were kept in place. An internatienal scheel was chesen in india, that catered te Arnav?s special seeds. Arnav centinued te grew per his cenditiens and did shew academic challenges! as espectecl- meve te Delhi was initiated fer better censultatien frem Decters and te alleviate lecai language and cultural barriers that were enceuntered in Hvderabad. As a familv we decided in earlv E?ll that fer Arnav te get the best suppert structure and help that weuld benefit him leng term threugheut his life, we sheuid meve back te LISA se that he has access te werld class ed ucatienal and medical facilities that were effered here. Wrnav was grewing and was beginning te understand hiatienal Pride. faith efJulv was alwavs ebserved ne matter what part ef the werld with famiiv adepting a persenal traditien ef red, white and blue kite flving and firewerks.] Tesas, and pa rticular'liir Frisce was ebserved te be a fastest gnawing suburb with a premising receptien te a child ef special needs. He had structure in place te suppert his therapeutic needs. While in Frisce, he enjeved the cempanv ef familv, friends. his extra curricular activities and teachers. He leved te swim. sing and bike. His reading was impreving and he was picking up en the Iecal culture. Arnav was put in Swimming, vanastics and lv'lathfF-ieading classes te help him deveiep a well reunded persenalitv. Sumeet's jeb required travel beth demestic and internatiena] at times. During these times Furnav was drepped te scheel, came back did heuseheid cheres, picked him up frem scheel and participate in his estra curricular activities. [in ant.r given dav. Arnav enjeved piaving indeer games with me and we alse liked plaving with claw'deugh, etc., listening te steries and reading and enjeved vacatiens. On the night he passed away, the davr befere that was just anether nermal clavr fer hrnav. I picked him up and breught heme frem scheel, effered snack [he chese te eat grapes}. He was effered mevie er get a tevr [He had dene well en a spelling test and needed te be rewarded]. Arnav picked te ge fer the mevie. En reute te the mevie. he slept. When awakened, hmav chese te ge te a restaurant fer dinner, Papa Lepea, fellewed bv a trip te Tevs 'Fi' Us. We beught a game there. and en the was-r baek we get Arnav a Ta ce Bell Mexican Pizza and we came heme. He finished having the Mexican Page BEE Pitta we had picked up an the wav back heme, and we checked en his carteens te see if thev were recerded. it was getting late and we decided te sleep- It was a celd night and he was tired, se we skipped the reutine ef changing inte bed time clethes. was wearing a rebe that he liked and Arnav asked if he ceuid have that as well. iteld him I ceuldn't give him mine, but instead he ceuid have a sweater. He were the sweater, and read te him, and put him te bed. I returned te watch seme T'vr in the living reem. He came eut efthe bed. lwalked him back te bed, tucked him back in. When he aweke again, I decided te stav with him, and slept in the same reem with him. I aweke the nest dav, especting te take him te his regular classes and asked him te wake up. When iteuched him, he felt said and was net respending. ceuid net have imagined him te be dead, se I centinued te tn,?r te wake him up. He was eeld and stiff. He was cempletelv unrespensive. i did net want te believe that rm,r sen was gene, and desperater heped that he was felting net getting upte aveid geing te his class as he had dene previeuslv. Se I picked him up and carried him te the bathtub. When I picked him up he remained cempletelv unrespensive, and I feund that he had relieved in his pants. When I put him in the bathtub he slumped in it, cempieteh,r unrespensive. I had te face the fact that he was gene and that he had died in his sleep. Nevertheless, I checked his pulse, his heartbeat, and there was nething. Frern the time that ltried te wake him up he was net breathing. Ne breath. i still did net want te admit that he was gene, se i tried te press en his chest and blew inte his meuth-i asked him te get up. He weuldn't bend his arms er epen his eves. He never epened his eyes frem the mement aweke. After realising that he was gene, I went in a state ef sheck and enlv wanted te knew whe weuld perferm his last rites. at seme peint in time I preceeded te give him his deceased bath accerding te Hindu custems, dressed him in his faverite clethes and kept his faverite tev [blue Deraemenl nest te him and I later put his head en his faverite pillew aieng with his faverite blanket. i knew there were a ceuple ef imperta nt rituals that were te be awarded and te be dispensed by his father whe at the time was away en his reutine business trip and he was espected te return anvtime. Eieing in the state ef sheck with such a sudden demise ef ?rnav, I centinued te and fellew the Hindu custems te the best ef mv knewledge as eshibited bv the fathe r?s fa milv in the past, including preserving the bedsr en ice. When Sumeet?s father passed awav, the fa miiv was in US and his bedv had te be preserved an ice at heme fer di?S davs until the immediate famil',r ceuid reach India and perferm the last rites {Antim Samskaar}. Since there are ne funeral hemes in India, the bedv was preserved at heme fer friends and famih,r te ceme and pay their last respects. Iinfermed the scheel, in persen, that Arnav weuld net be attending class, but I did net reveal the real reasen, that he had died in his sleep, as I believed that the declaratien ef demise had te ceme frem his father after perferming additienal rituals, fellewed bv netice te the rest efthe famih,r members, priest and a family,r decter [er a medical esaminer}. alse placed tissue in his nestriis, which is censistent with Page SIB Hindu traditien. Fer neat feur days. i fellewed Hindu rituals with i'krnay. presendng his bedy with ice cubes taken frem heme refrigerater {put in aiplec ard bags] and reading Hindu scriptures. I expected that my hUsband weuld arriye at any meme nt an I centinued te wait, and wait fer him. 1II'iI'h-en Sumeet walked in the deer. lteld him te ceme in and wait. He was there back after a Jeng trip. He has a weak heart and I knew he weuld net be able te receiye news ef his sen's demise well. I asked Sumeet te wait. haye him settle in. If I had stayed with him. I was werried that he weuld make eut frem my state that semething was wreng. se I left fer a while. When I get back I feund Pelice cars parked in frent ef the heuse. i walked in. cannet recall whether it was the F'elice er Sumeet whe asked me first where .Ilirnayr was. I teld the Felice that I needed te talk te Sumeet priyately. The pelice walked eut but still wanted te knew where ilirnayI was lecated. lteld the pelice I needed them te stay and net ge away but that I needed te first talk te Sumeet. i came in. and went te the hallway nearthe bedreem in the back with my husband- As seen as I breke the news te Sumeet. Sumeet immediately called the Felice in. Felice asked me if Arnay was inside the Iecked bedreem deer. I said yes. They asked ifthey ceuld ge ahead and break the deer epen. Sumeet respended te them with a yes. When the pelice breke in the deer and feund Arnay. was immediately separated frem my husband. arrested. handcuffed. ta ken eut be the backseat efthe pelice car and they read me my rights. I didn't knew what te make ef it all. se I kept quiet and when asked if I had semething te say I said semething te tte effect that "yeu weuld net understand.? iyty sen's Antim Samskaar. last rites. were rnest imperta nt and I was net sure if anyene eutside the Hindu culture weuld understand the Hindu belief reincarnatien. and the release e-f seul frem the bedy. and hew abselutely impertant last rites ritualsare te allew a seul?s next life te be peaceful. This is especially impertant when dealing with the death efa child. Hindus belieye in rI'Iiaah Sanskaar?r [crematieni. as eppesed te burial. and keeping the bedy intact fer the same is extremely imperta nt. that disturbing the bedy er haying any cuts er ergans remeyed is disturbing te the seul and inhibits the seul frem meeting ferward. This was what I was thinking as I waited fer my husband te return frem his business trip. Fit ne peint in time did I meye er treat ikrnay?s bedy i'i any effensiye manner whatseeyer. and enly tried te preserye him until his father came heme te preyide ?jal arpan? giye water and bless him. and te ge ahead with the rest ef the rituals. Page are Finally, I want tn make it perfectly clear ta the werltl that: Itiitl nrat hurt Arnay. I dial net kill ?irnay. I did net rnurtler Arnay. I did net drawn er smether Arnay. Idid net petsen Arnay. laid net fail te render aitl ta Arnay at any time. Arnay must haye died in his sleep and he was cernpletely unrespensiye tram the time that I wake up. He neyer rneyetl, apenetl his eyes, spiel-1e! er tank a breath. There was ne pulse er heartlaeat. Must impurtantiyy hatred Arnay with all [if my heart and never wnultl hurt him in any way; and I miss him 1irery much. Page 5ft": WW DHAWAN BEFORE ME, THE UNDERSIGNED DN THIS APPEARED KNOWN TD ME TD BE THE PERSDN WHDSE NAME IS SUBSCRIBED TD THE FDREGDING INSTRUMENT, AND AFTER BEING ME, DID STATE UPDN HER DATH THAT THE FACTS CONTAINED IN SAID INSTRUMENT ARE TRUE AND CDRRECT. THERE ARE 6 PAGES TD SAID DDCUMENT INCLUDING THIS SIGNATURE PAGE. SUBSCRIBED AND 5WDHN TD BEFDHE ME, 0H THIS THE 15?? DAT BF APRIL 2014 CERTIFY WHICH WITNESS MT HAND AND SEAL BF DFFICE. PUBLIC IN AND FDR THE . TDNI BUHLEEUH MT SSMSIISSISII ESPISES March 23, 21113 STATE OF TEXAS Page EIE