EXHIBIT 1 Document] THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, Plaint?j?s, V. Civil Action No. Donald J. Trump, President of the United States, at al. Defendants. DECLARATION OF THE PARS EQUALITY CENTER IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION ?Pursuant to Title 28 U.S.CL Section 1746, I, Bita Daryabari hereby declare and state as follows: 1. I am over the age of eighteen years. I have personal knowledge of the facts set forth herein, and am competent to testify thereto. 2. I am the Founder and Executive Director of The Pars Equality Center (Pars). Inthis capacity, I serve as the leader of all of Pars? departments. I also facilitate Pars? work with other like-minded organizations, engage in fundraising efforts on behalf of the organization, and work with the Board of Directors. 3. The Pars Equality Center is a 501(c)(3) non~prof1t dedicated to helping all members of the Iranian-American community and other Persian-speaking countries realize their full potential as informed, self-reliant, and responsible membersmof American society. Pars believes that learning and teaching the rights and. responsibilities of citizenship in a democracy as well as the rules and rewards of entrepeneurship are the necessary ingredients for our success as a community. Pars achieves its?mission primarily by providing extensive social and legal services out of community?centers. The organization?s Persian-speaking staff advocates for families and individuals in need with a strong focus on refugees, asylees, and those newcomers living in poverty. The Board of Directors of Pars are all of Iranian descent. Pars is basied in California. 4. While its focus is on the Iranian-American community, Pars does not close its doors to anyone seeking its services. Especially in its immigration services, Pars serves clients from various backgrounds and nationalities. In 2016, Pars provided 20,713 units of service,1 across all of its locations, with the majority of clients of Iranian descent. 5. Among other things, Pars provides mentorship and career development for Iranian- Americans. or example, Pars hosts a Silicon Valley career development techniques and best practices workshop, which covers resume writing, successful interviewing, information about the culture of the workforce in Silicon Valley, and how employees can make themselves an instant asset to potential employers. Pars also hosts a ?Generation initiative that provides the younger generation of Iranians, both American-born and immigrants, with career mentors, peer mentors and career opportunities. Pars selects a broad array of mentors from the private, public, and art sectors, provides formal mentorship that connects younger Iranians with mentors that best ?t that individual?s needs, and organizes social events to allow members of the community to bring together the community and facilitate career connections. Through its work with Generation Pars acts as a catalyst for social, cultural and economic integration of Iranians speaking communities to achieve their highest potential. 1 A ?unit of service? measures one service - for example, one workshop, one immigration-related consultation, or one ESL class. One individual can receive multiple units of service from Pars. 2 . b. Pars provides various other social services to Iranian Americans and Persian speakers of all ages. Pars provides, among other things, English as a Second Language (ESL), citizenship, and resume writing/interview skills classes; computer training and access to employment resources including job fairs; assistance navigating the social and medical systems; and other services to improve the quality of the family?s life in our community. Through the Kordestani Family Fund, Pars also invests in the education of Iranian American youth by providing a grant each year to a student of Iranian descent graduating from high school in California with speci?c plans to continue their education in a College or University in California. PARS also has a social club for Persian speaking immigrants over the age of 55 which includes interactive programs, tours and picnics to provide an uplifting and inspiring environment that these individuals can call home away from home. 7. The legal services provided by PARS are intended to provide community members the resources to become productive citizens by educating and advocatingon behalf of individuals in the community. The legal staff members at PARS are either licensed attorneys or accredited Board of Immigration Appeals representatives, and they guide individuals through the immigration process and provide extensive legal services, including: citizenship, green card renewals, domestic violence based petitions, family relative petitions, travel documents, issues arising in the refugee context, and counselor processing. 8. legal team also works on a national level to offer advice, analysis and legal research in other areas, including litigation, employment, family and sanction law issues. To this end, PARS works with other organizations, such as the Iranian American Bar Association and the Public Affairs Alliance of Iranian Americans, across the United States to educate the community about relevant legal issues and advocate on behalf of Iranian Americans in the US 9. I have a long?standing passion for increasing knowledge of my native Iranian culture, as well as improving the lives of people from Iran and beyond. I founded the Pars Equality Center in 2010 to be a community-based social service and legal services foundation and have served as its Executive Director since that time. Prior to my work at Pars, I received my Master?s degree at Golden Gate University in California, where I was later awarded the Alumni of the?Year award in 2008. Upon graduation, Ijoined GammaLink, Inc., one of the early pioneers in the ?eld of telecommunications. I later moved to MCI Communications where, more than once, I received distinguished medal awards and recognition for my worlc. I have also been recognized for my various philanthropic efforts, and have received the Ellis Island Medal of Honor (2012); the United Nations Appreciation Award for Outstanding Leadership, Commitment and Support of the UN, and Achieving the UN Millenium Development Goals (2011); and the Public Affairs Alliance of Iranian Americans Philanthropist of the Year Award (2010). Harm to PARS caused by the Januarvgj, 2017 Executive Order 10. Pars is extremely concerned about the E0 because it has already had, and will continue to have, a highly negative impact on both the community that we serve as well as the mission and purpose of our organization. For the reasons discussed below, enforcement of the E0 will harm Pars? mission in multiple ways and has already forced Pars to scramble to address its effect, thus causing Pars to divert valuable resources away from its usual activities. ll. 12. 13. The goal of the legal services that Pars typically provides m? to effectively use the immigration laws to advocate on behalf of immigrants, including immigrants from Iran, and to guide individuals through immigration processes has also been crippled by the E0. While Pars attorneys seek to provide concrete answers, at present the vagueness and ambiguity prevents them from informing those who seek their services what to expect with their or their family members? pending visa and green card applications, whether they should submit future petitions, or whether they will be able to travel outside of the United States for work or pleasure in the future. The assistance that Pars typically provides to individuals with their visa applications or green card petitions is at best severely delayed; at worst, it is at a complete standstill. The E0 will have a severely negative impact on the mission of our organization. Pars seeks to facilitate the social, cultural and economic integration of Iranians to achieve their highest potential while also staying connected to their Iranian heritage. However, the ED falsely singles out Iranians in the United States and those seeking to enter as a terrorist threat. Such a negative label on the Iranian-American community has already sown fear and anxiety in the community we serve. The stigma and discrimination that is caused by 'uthe Ban will exacerbate the challenges that immigrant groups, especially immigrants from primarily Muslim countries like Iran, already face in the United States. Pars also seeks to elevate Iranians and "Persian speakers to achieve their highest career potential in the United States. However, the E0 blocks the entry of, or forces the departure of, many Iranians who would otherwise have contributed to the vibrant and creative economy of the United States. For example, based on my leadership of and experience with Pars? mentorship and career development, Generation and educational i 14. 15. programming, I believe it is likely that the E0 will affect the decisions of employers, who may prefer not to hire or sponsor Iranian visa holders, or even legal permanent residents and dual citizens. In addition, the E0 will cause individuals with high levels of educational attainment Master?s and degree holders who are applying for or other business or student visas to be denied visas or for their visas not to be renewed. Some of these educated individuals may also choose to leave the United States, even if it means leaving behind promising careers or degree programs, in order to be reunited with family who is not able to enter the United States. The and emotional toll of the E0 has already come into stark relief in conversations between Pars staff and Iranian Americans. Entire families are experiencing profound disruption, given that the children of visa holders may be well~integrated into American life and culture, yet the E0 may soon force their parents to leave the United States. In short, while Pars ?ghts for families to establish themselves in their communities and for individuals to achieve their greatest career potential, the E0 is likely to cause family separation and a brain drain from the United States. The purposes of Pars? citizenship classes will also be undermined by the E0. Pars teaches Iranian immigrants about the US. democratic system, and the rights and privileges that it bestows. The goal is for those who learn at Pars to become well-integrated, self-suf?cient members of their communities. However, after the E0, Pars has been unable to answer basic questions about what the US. government has in store for those entering the country from Iran and those currently in the United States on visas. The E0 has made it dif?cult, if not impossible, for many individuals to plan their future lives in the United States. It has all but put hopes of citizenship and permanent status 0th of reach for those 16. 17. .18. who do not have it, including refugee applicants and asylum applicants. And for dual citizens and permanent residents both, the E0 means that they may not be able to have their family members join them in the United States as planned. The vast uncertainty, confusion, and deep fear caused by the E0 has already manifested itself great harm to the communities that Pars serves as well as the organization?s mission. That harm will only continue to deepen as the E0 continues to be enforced. Our organization has suffered economic harm directly as a result of the E0. Since the signing of the E0, our legal services staff has received twice the typical volume of calls, emails, in?person questions and other inquiries. Individuals of all legal statuses dual citizens, green card holders, visa holders, those seeking protected status (VAWA, Visa, 10751 with waiver), refugees and refugee applicants, and asylees and asyulum applicants, and others have called with fearful questions about themselves or their loved ones. Instead of our usual legal services, we have been focused almost completely on addressing unanswerable queries about the E0. Our legal services team is inundated with constant telephone calls, emails, and messages. In the week following the signature of the E0, the Senior Director of the Legal Department alone has been forced to devote dozens of hours of her time solely to dealing with EO-related issues. In fact, the Work of answering calls and answering the queries of individuals has spilled over to our social services team, which would typically make a referral to the legal services team, because legal services is so overwhelmed. The individuals who have contacted Pars as a result of the E0 include asylum applicants from Iran outside the United States who are unable to enter the United States, as well as 19. - 20. 21. 22. those Iranians who have been granted refugee status in the United Stateshbut whose families are still abroad and now unable to join them. Our resources have also been diverted from our typical programming. Instead of preparing and giving panels and presentations on topics of education, citizenship, and career, we have been forced to present almost exclusively on the E0 and its impact on the Iranian American community. Since the E0 was signed, we have spent signi?cant time organizing with other groups and entering into coalitions to share information and be able to adequately inform the community about its effects. As an example,ione attorney at Pars has been unable to work on any of the cases to which she wasassigned before the E0 was signed. Instead, she spends all of her working time researching updates on the E0 and making presentations on its impact. For one of her presentations, she had to seek out the assistance of a who would counsel distraught individuals after her presentation. Another attorney has hadeto devote signi?cant time completing research on the E0 and basic constitutional analysis so that she could respond to queries received by Pars, instead of performing her regular job functions. Other staff members, particularly within Pars? legal services branch, have spent their time educating themselves about the E0 and regularly posting online about it for the bene?t of the impacted community. In summary, the E0 has caused profound and emotional harms to the Iranian-American community. It has created fear and anxiety and separated and unmoored families. It has also put into jeopardy the economic security of these communities and is sure to cause a brain drain from the United States as many Iranian immigrants, refugees and Iranian Americans are forced to, or choose to, leave the country in search of more stable employment, reuni?cation with their families, or both. By extension, the E0 will also weaken the economic contribution of the Iranian-American community to the United States. The EU has crippled core aspects of Pars? mission and wreaked havoc on the organization?s ability to continue with its usual programming, social, educational, and legal services. I, Bitye Darya'bari: declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Winn; if w, Executed this ?day 201 7, in 3a. 3599?? WW Bite g??yabari EXHIBIT 2 Document! THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et Plainti??s, Civil Action No. V. Donald J. Trump, President of the United States, er al. Defendants. DECLARATION OF IRANIAN AMERICAN BAR ASSOCIATION IN SUPPORT OF MOTION FOR PRELIMINARY IN JUN CTION . Pursuant to Title 28 U.S.C. Section 1746, I, Babak Yousefzadeh, hereby declare and state as follows: i I. I am over the age of eighteen years. I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others, and am competent to testify thereto. 2. My name is Babak Yousefzadeh. I am the President of the Iranian American Bar Association (IABA). I have personal knowledge of the facts set forth in this declaration, or I believe them to be true based on my experience at IABA, information provided to me by others, or review of information and documents available to me in the course and scope of my position with If asked to do so, I could testify truthfully about the matters contained in this declaration. 3. The IABA is a non-profit independent and apolitical professional association operating under section 501(c)(6) of the Internal Revenue Code. It seeks to educate the Iranian American community in the United States about legal issues of interest, advance legal rights of the community, and ensure that government officials and the public at large are fully and accurately informed on legal matters of concern to the Iranian American community. The IABA also seeks to foster and promote the achievements of Iranian American lawyers and other legal professionals. 4. Founded in 2000 with a single Washington, DC chapter and four members, the IABA now has additional. chapters in Dallas, Los Angeles, New York, Northern California, Orange County, Phoenix, and San Diego. Currently, we have over 1500 members, including attorneys, judges and law students, and consist of the only national network of Iranian American lawyers in the US. The IABA provides a formal mentorship program to law students and new lawyers, jobs board, and continuing education programs including a national conference. The af?liated IABA Foundation has granted over two dozen scholarships to law students since it was established in 2013. 5. The members of the IABA Board of Directors are distinguished members of the Iranian American legal community. There is one board member for each local chapter, multiple at large members (depending on annual needs) and one student representative. 6. I am currently in my third term as President, and I am also a member of the Board of Directors, representing the Northern California Chapter. I have been a member of IABA for eight years. I am also a Partner with the national law ?rm Sheppard, Mullin, Richter Hampton, LLP, in their labor and employment practice group. 7. In addition to my role at IABA, I have a personal stake in ensuring the United States applies its immigration practices fairly to Iranian nationals and provides asylum to those legitimately ?eeing political persecution. My family had to leave Iran for Switzerland in 1984 when I was only seven years old, sought asylum in Germany andultimately sought and obtained political asylum in the United States after a two-year process. 8. My family was forced to leave Iran because of my father?s opposition to the then-newly? formed government of the Islamic Republic of Iran. My father opposed the Shah?s regime and supported democratic change. However, based on what I have learned, in the unrest following the revolution, there Was a suppression of those who sought a democratically. elected civil government and additional liberties, including by means of imprisonment and extra judicial executions. At the time, my father was politically active. His political circle was under a severe threat, and people he knew and associated with had been imprisoned and executed. Even though they opposed the regime and did not want to leave their country, my parentsdecided the risk of staying was too great. My mother, my 13- year sister and I left immediately, and my father was only able to follow with a great deal of dif?culty several months later. If we were not able to leave the country, I fear my father would have perished. 9. I came to the United States in 1986 and was a permanent resident until 2001, when I became a naturalized citizen. As a child and young adult, I did not perceive much difference between being a permanent resident and a citizen as far as I was concerned my family andl were like other Americans. 10. My story is not unique. In meeting and talking with?lranians of my generation who now live in the United States, I found that a lot of us came here by seeking political asylum, and often going through countries like Germany that Opened their borders to us. interestinand concern abOut enforcement Of the January 27 2017 Executive gagevitally interested in and concerned about the January 27, 2017, Executive Order, ?Protecting the Nation ?om Foreign Terrorist Entry Into the United States? (the the as'SOCiated-State' Department Memorandum of the same date This "imp05es a blanket bar to immigrants and other individuals traveling to the United States from-majority-Muslim countries, "including Iran; Who. have followed Valid procedures to obtain-lawful visas-or other authorization. It has prevented numerous-Iranian nationals wishing to relocate to or visit the." United States for work, travel or-study to do so. It has made it. difficult or in sometcases' impossible for even - permanent residents er current visa holders already in the United States to freely travel abroad andretUrn to the US. i In addition to-the EO itself,? associated actions of the State and the Department of- Homeland' Security Of?ce of Customs and Berder Patrol (?CPB?)ihave . harmed-and unfairly restricted Iranian Americans; The-secret DOS Memorandum ?implementing the E0 I?provisionally revokes? any. current immigrant or'nonimmigrant I i visa held by any national of Iran or the other countries covered by the According-to I press reports and information surfaced through legal challenges to the E0, the State Department secretly revoked-these documents vvithout providing any notice to affected individuals. The US. government has communicated directly with international airlines instructing them not to board passengers holding these visas without communicating with: travelers or the public. As a result, any current visa holder residing in the United Staies cannot travel outside the US. because they no longer have a lawful authorization to re-? enter the country. 13. The IABA is vitally interested in and concerned about the E0 because it subjects our members, and their families, friends and fellow members of the Iranian community in the United States and aboard to direct and indirect restrictions on their ability to work, travel, study and live in the United States. 14. The E0 will adversely affect our members as well as mission and- purpose of our. organization. It has already forced LABA to divert substantial resources to combating the pernicious effects. 15. Inthis statement I ?rst explain why enforcement of the E0 against the Iranian community and members is improper and arbitrary. I provide a summary of the hundreds of reports we have taken from individuals denied entry to the United States, subjected to additional delay or otherwise impacted by the E0. I then explain the economic harm that enforcement of the E0 has caused, and would cause, to our organization in particular. Impact of the E0 on the Iranian American Community 16. Based on the many individuals who have contacted the IABA since January 27, it is clear that the E0 is sowing fear. and confusion?in the Iranian American community. It has unfairly singled out Iranian Americans, despite their deep ties to this country. It has separated families and limited the ability of Iranian Americans living in the United States to visit or help family members in Iran. It has prevented US. citizens who are married to 17. Iranian nationals from maintaining a normal family life together. It has left people who sold theirhomes and possessions in preparation to immigrate in limbo. The E0 treats the Iranian-American community, estimated to approach 1 million people, that has many US. citizens and lawful permanent residents who have made signi?cant - contributions to the United States through their work, study and participation in .18. 19. community life for decades, as less than fully American. Iranian Americans have contributed to many aspects of Am?nican society including. public and military service. Without any basis orjustitication, the E0 paints all with the same brush. It effectively categorizes everyone of Iranian descent as a potential terrorist and therefore'inherently dangerous. But according to a study conducted by the CATO Institute that reviewed data from 1975-2015,-there Was not a single case of an American being killed in a terrorist attack in this country by a person born in Iran or any of the other six countries speci?ed? in the Executive order. I have heard the numerous statements from President Trump about wanting to exclude Muslims from entry into the United States. I see that he has done so by naming everyone from seven majority Muslim countries, regardless of the diversity of people and circumstances of those people. This is inconsistent with stated support for decades for Iranian dissidents and Iranian religious minorities and re?ects in my mind that the Executive Order was not meant to address a threat from Iranian citizens but simply to go after Muslims or?perceived Muslims as a group. News reports and the reports from many individuals who have contacted us since the E0 Was signed make clear how the arbitrary and inconsistent actions of the enforcement have harmed Iranians. News accounts from Iranians with otherwise .valid 20. 21. immigrant and nonimmigrant visas or green cards include being denied entry and forced to board ?ights out of the country, being detained for extremely long periods of time, and attempting to coerce permanent residents into signing away green cards.1 We have received similar reports through our direct contacts with Iranians. Some have sold their possessions and made all their preparations to relocate, only to languish at arrival terminals or be summarily returned to Iran. Families are left wondering what happened to relatives who never arrived, or are forced to separate. Families have been separated and Iranian Americans living in the United States may now be unable to visit or help family members in Iran. We have several accounts of US. citizens who are married to Iranian nationals now unable to maintain a normal family life together. Individuals who had legal permission to work or study in the United States, and who happened to be out of the country for work, conferences, family visits or other reasons, found they were unable to return to their homes, classes andjobs. Since January 27, our chapters have been on the front lines at airports and responding to emails, calls and social media postings from Iranian Americans and Iranian nationals affected by the E0. We have invited individuals to ?le reports with us, and have received .at least 350'reports, although not all are complete. Of those, over 150 reports involve individuals denied entry to the United States, including persons who were not permitted to board ?ights at all despite having valid visas or other authorization to enter the United States and persons who arrived at US. airports and were turned back and put on ?ights INatasha Bertrand, Lawsuit: Dozens of Immigrants to Enter the U.5. Coerced Into Giving Up Visas and Green Cards After Trump Travel Ban, Business Insider (Feb. 3, 2017), available at Brenda Gazzar and Washicko, Thousands Protest Trump?s Immigration Order at LAX, Los Angeles Daily News (Jan. 29, 2013), available at Lives Rewritten With the Stroke of a Pen, New York Times (Jan. 29, 2017), available at r=0. 7 22. 23. out of the country. Almost 50 others who were green card holders or had visas reported delays, more intrusive questioning or other hurdles upon arrival. Several dual citizens were denied entry and at least 10 lawful permanent residents holding green cards reported being refused entry into the United States altogether. In one instance, an IABA staff member made contact with an Iranian family who reported they had fled to Turkey to escape political persecution in Iran. The family members had been accepted as refugees under the US. Government?s Refugee Assistance Program and were awaiting safe passage to the United States. As a result of the the family had been stranded in Turkey without proper accommodation. Withinea few hours, the IABA staff member used LABA funds to pay for their stay at an Istanbul hotel and arranged for them to travel by bus to Istanbul. She also purchased them a plane ticket to the United States after a United States federal court temporarily restrained enforcement of the E0. I have also received reports of individuals directly impacted by the State Department?s secret order revoking visas and instructing airlines not to board any Iranian visa holders on flights to the United States. I received an email from an individual who, at the time of the call, had a group of 110 visa holders in Iran who were not being allowed to board planes. We have reports that the airlines have denied boarding because they believed that CPB will turn the passengers back on arrival at US. airports and that this will subject the airlines to financial penalties. We also have reports'that individuals provided the court orders to the airlines that should permit them to travel to the United States and that they were still told they are not permitted to travel because of the instructions of the US. government. ,Harm to IABA 24. The E0 will have a severely negative impact on the mission of our organization. As an 25. 26. organization that supports the rule of law and whose members are practicing attorneys andjudges, the IABA is particularly distressed about reports that the government is flouting valid orders issued by federal judges, that the State Department revoked visas in secret and without notice to affected individuals, and that Iranian Americans who properly followed all procedures necessary to obtain valid permission to enter the United States face arbitrary, unjust and discriminatory restrictions on their rights. Further, because we are an association of lawyers speci?cally, we have dropped everything to focus on providing legal assistance and support to the Iranian American community and Iranian nationals. The vagueness and ambiguity frustrates these efforts and prevents our attorneys from informing those who seek their services what to expect with their or their family members? travel plans and pending visa and green card applications. and the associated actions of the State Department and CBP have created incredible chaos and many potential legal challenges as well as the need to answer hundreds of inquiries about whether individuals can legally travel to or outside the United States. This has completely overwhelmed our limited resources. In early January, our organization set its goals such as improving our infrastructure (including our website), updating our bylaws, increasing our social media presence and improving our services for members. We had speci?c plans to increase our membership 27. and engage in fundraising. Just a couple of weeks later we ?nd that all of our resources have been diverted to combat the E0 and all of our planshare on hold. I have personally devoted 6?10 hours a day since the chaos at the airports started on the morning of January 28 just to our response to the E0. I am personally responding to the calls and emails of people impacted by the E0 and trying to coordinate responses. Since this is a voluntary endeavor it means I cannot devote normal attention to myjob or other commitments. I am coordinating our response across multiple cities, including with our members who are at airports. I am coordinating with organizations like the American Civil Liberties Union, the American Immigration Law Association, the National South 28. - Asian Bar Association, the Asian Law Caucus, and other bar associations. I am also communicating with our chapters who are impacted, and dealing with signi?cant media inquiries. Our entire Board and many of our members are also devoting signi?cant time on a voluntary basis to trying to reach people and represent them, trying to get individuals released, answering questions from travelers and their loved ones, and trying to follow up on reports of people being transferred. We are doing legal research on caSes and responding to individuals outside the US. Our organization has also devoted signi?cant resources to drafting materials to inform the community, including FAQs, and developing forms and databases to track people who are impacted. Local chapters have been spending time posting information on social media, particularly Facebook, and handling I responses. Due the vague language in the E0 and the chaos that followed, it has been ektremely challenging to provide appr0priate counseling and advice to individuals in need. 10 29. 30. 31. We are spending money to update our website in order to get information out, and have had to defer our plans to conduct fundraising in January. At our chapters, at least half of the members of our local Boards are dedicating multiple hours every day to responding to the E0. The seven members of our Board who represent local chapters are all currently working on this issue, putting in signi?cant time both on .the national level and in local coordination. The remaining other ?ve Board representatives are all helping in some capacity to support this work. At this time, we do not expect this pressure to lift and we do not know when we can return to the regular work of our association and our normal services we provide to our members. 11 I, Babak Yousefz'ad'eh, declare under penalty of perjury that the foregoing is true: and conect to the best, of my knowledge; 12 EXHIBIT 3 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, Plaintiffs, Civil Action No. V. Donald J. Trump, President of the United States, er a1. Defendants. DECLARATIONOF THE NATIONAL IRANIAN AMERICAN COUNCIL IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, Trita Parsi, hereby declare and state as follows: 1. I am over the age of eighteen years. I have personal knowledge of the facts set forth I herein and am competent to testify thereto. 2. I am the co-Founder and President of the National Iranian American Council (N IAC). NIAC is a nonpartisan, nonprofit organization operating under 26 U.S.C. 501(c)(3). It is based in Washington, DC. 3. NIAC also has a sister organization, NLAC Action, which operates under 26 U.S.C. 501(c)(4). The top of?cer of NIAC Action is Executive Director Jamal Abdi." 4. The goal of NIAC Action is to strengthen U.S. diplomacy with Iran to advance peace and human rights, promote greater openings between the American and the Iranian'people, 1 protect civil rights and opportunities fOr Iranian Americans at home, and support candidates who represent the IranianwAmerican communities? values. To ensure its members have a powerful voice in the political process,ch Action provides its members ?vvith top caliber political resources, guidance, pOWerful advocacy tools and, civic trainings, and grassroots leadership developrglent. I founded NIAC in 2002 to provide a non-partisan, non-pro?t organization through which Iranian-Americans could participate in American civic "life, NIAC works [to strengthen the voice of Iranian Americans by promoting greater lunderstanding'between the American and Iranian peopleilt also seeks to advance the interests of the IranianuAmerican community on civic, cultural and political issues. The Iranian-American community apprOaches one million people, largely US. citizens or permanent legal residents. As a recent immigrant the Iranian?Arnerican communityhas str0ng ties to family members in IIra-n. I I lift . NIACsupplies the resources, 'knovvledge, and too1s to enable civic participation and informed decision-making regarding issues facing the" Iranian4American community", "and provides the across. the'netvvork of Iranian-American r'o'rganizat'ions and the. peoples of the-United States land-'NLAC accomplishes its mission through expert research and analysis, and policy education, and community building. I . NIAC has worked to ?ght discriminatiOn against the Iranian?American' community, including dual citizens, legal permanent residents, and Iranian visa?holders. Fer example, i 2 NIAC fought discrimination at Monster.com in 2003, the world?s largest online job search. and career management company. Monster.com eliminated the word ?Iran? from a section of its standard format resumes and dropped individuals and organizations from Iran from its website. After negotiations with NIAC, Monster.com agreed to change their policy of excluding educational experience in Iran from their standard resumes. NIAC has also petitioned for group inclusion to the US Small Business Administration?s program for disadvantaged minority groups, arguing that the Iranian-American community deserves government support to pursue business and ?nancial endeavors in light of widespread discrimination in society as well as within the business' world. In addition, NIAC has successfully engaged US. ?nancial institutions, such as Bank of Hawaii, who have adopted discriminatory policies towards Iranian persons, particularly students from Iran studying in the United States. NLAC has also successfully petitioned Apple and other US. retailers regarding discriminatory policies, such as one Apple store?s refusal to sell Apple products to Iranian persons, including US. citizens and visa- holders. NLAC objected to the University of Massachusetts?s discriminatory policy against Iranian students and elicited a reversal of the policy, as well as reversals at other universities. NIAC worked with Venmo to resolve payment dif?culties, speci?cally with' the use of speci?c keywords in the payment message such as ?Persian? and _?Iran.? NIAC led the campaign to ?x the single-entry visa policy and to allow Iranian students to receive multiple entry visas. NIAC successfully opposed legislation in 2010 that would have barred every Iranian from entering the United States. Finally, NIAC 10.- ll. 12. obtained an apology from Fox sportscasters for racially discriminatory remarks against Iranian NBA player Hamed Haddadi. I NIAC co-leads the largest coalition of advocacy groups in Washington, DC. on U.S.;Iran related issues and regularly hosts brie?ngs on Capitol Hill for congressional staffers on areas of interest to the Iranian-American community. Our past brie?ngs have focused on Iran?s parliamentary elections, Iran?s nuclear program, Iran?s role in Iraq, and more. NIAC defends Iranian?American interests against corporate and media bias, discrimination, and government neglect; monitors, in?uences and shapes national legislation affecting Iranian Americans; and trains its constituents in successfully, engaging in civic participation at dozens of workshops and functionsacross the United States. constituency numbers in the tens of thousands, comprised mostly of those of Iranian heritage. Iran is predbminantly a Muslim country. A vast majority of constituents have family members that enter the United States on tourist, occupational, immigrant, ?ance, or student visas from Iran and other c0untries listed in the January 27, 2016 Ekecutive Order constituency is comprised of United States citizens, Legal Permanent Residents, and immigrant and nonimmigrant visa holders. I was born in Iran and moved with my family at the age of four to sweden to escape political repression in?Iran. My father was an outspoken academic and Zoroastrian who was jailed by the Shah and, subsequently, the Ayatollah. I moved to the United States to study foreign policy at Johns Hopkins? School of Advanced International Studies, where 4 13 14. I received my and studied under Professor Francis Fukuyama and Dr. Zbigniew Brzezinski. I am ?uent in Persian/Farsi, English, and Swedish. . As President of NIAC, my duties include fundraising, strategic relationship building, constant interfacing with our constituents, and identifying problems faced by our community, as well as solutions to those problems. President Trump?s January 27 Executive Order is the most vague, encompassing, and severe challenge faced by the Iranian-American community that I have witnessed in the past 15 years. Outside of my work at NIAC, I have followed Middle East politics through work in the ?eld and extensive experience on Capitol Hill and at the United Nations. have served as a foreign policy advisor to a Republican lawmaker. I have worked for the Swedish Permanent Mission to the UN, where I served in the Security Council, handling the affairs of Afghanistan, Iraq, Tajikistan, and Western Sahara, and in the General Assembly?s Third Committee, addressing human rights in Iran, Afghanistan, Myanmar, and Iraq. I have also served as an adjunct professor of International Relations at Johns Hopkins University SAIS, an adjunct scholar at the Middle East Institute, and a Policy Fellow at the Woodrow Wilson International Center for Scholars in Washington, DC. I am also an adjunct professor at Georgetown University. I have written three books on US foreign policy in the Middle East (the third one will be released later this year), and I havereceived several awards for these books, including the 2010 Grawemeyer Award for Ideas Improving World Order, and the 2008 Arthur Ross Book Award. My articles have been published in the Wall Street Journal, New York Times, Washington Post, L05 5 Angeles Times, Foreign A?airs, Financial Times, Jane ?s Intelligence Review, the Nation, The American Conservative, the Jerusalem Post, and The Forward, among others. In addition, I am a frequent guest on CNN, PBS Newshour, NPR, and the BBC. interest in and concern about enforcement of the January 27, 2017 Executive Order 15. NIAC is vitally interested in and concerned about the E0 because it will adversely affect our constituents, as well as the mission and purpose of our organization. As described in further detail below, the Cato Institute has documented that Iranian Americans have. I killed no Americans on US. soil, Despite this, the E0 has a disprOportionate effect on Iranians w? for example, of 90,000 visa holders potentially impacted from the seven countries targeted by the E0, almost half are from Iran alone. i 16. Further, enforcement of the E0 has already caused NIAC to divert its substantial resources to combating the pernicious effects on Iranians and Iranian Americans and will continue to do so. 17. In this statement, I ?rst explain why enforcement of the E0 against the Iranian-American community, which NIAC represents, is unfair and arbitrary. I then explain the harm that enforcement of the E0 would cause to our organization?s mission and resources in particular. Inclusion of Iran as one of the seven countries in the E0 18. Enforcement of the E0 would not achieve its stated goals of ?protecting the nation from foreign terrorist entry.? This is because facts show that a target of the E0 Iranians 6 19. 20. seeking entry into the United States are not the ?would-be terrorists? the E0 claims it seeks to deter. Despite this fact, Iranians are disproportionately affected by the E0 given that, as explained below, almost half of the visa holders potentially-impacted are Iranian. The community of Iranians and Iranian-Americans in the United States is a robust, thriving one, which makes great contributions to American society and the economy. On the whole, Iranians are far more educated than the average American. According to a study based on the 2000 census completed by the Iranian Studies Group at MIT, the percent of Iranians over 25 years old who obtained a bachelor?s degree or higher was 57%, in comparison to 24% for the rest of the population.1 Iranian-Americans also hold ?ve times the number of doctorates than the national average. The per capita income for Iranian-Americans is 50% higher than that of the nation, while the family income average is 38% higher. Iranian-Americans are highly represented in the tech industry, having . founded or held top positions at Twitter, Dropbox, Oracle, Expedia, and eBay.2 Iranian- Americans are also top venture capitalists and invest in technology startups. The Iranian-American community tends to have close-knit family ties with both nuclear and extended families. The study completed by the Iranian Studies Group at MIT found that only 3% of Iranian-Americans live in unmarried households, compared to' 7% I nationally.3 It is typical for individuals to live with or have very close ties to their. extended family. sector/S I 5202/ 7 21.2 According to a study conducted by the CATO Institute, from 1975 to 2015, there were zero reported incidents of a foreign-born citizen of Iran or any of the other seven countries listed in the E0 killing Americans on US. soil.4 In contrast, 162 Americans were killed by citizens of" Egypt, 159 killed by citizens of Lebanon, 2,369 killed by citizens of Saudi Arabia, and 314 killed by citizens of the United Arab Emirates, none of which are included in the E0. 22. None of the individuals involved in the September 11, 2001 terrorist attack were from Iran.5 Fifteen of the 19 terrorists were citizens of Saudi Arabia, while the others were citizens of the United Arab Emirates, Egypt, and Lebanon. 23. No Iranians have been involved in terrorist attacks committed on US. soil since September 1 l, 2001. The 2013 Boston Marathon bombing was carried out by tvizo non? Iranians: brothers from Chechnya.6 Chechnya is omitted from the E0, Further, the husband and wife who perpetrated the terrorist attack in San Bernardino, California, on December 2, 2015 were of Pakistani descent, another country not listed on the E0. The wife was a permanent resident, and her husband was a US. citizen at the time of the attack.70n June 12, 2016, Orlando, Florida was the location of the worst mass shooting by a single shooter in American history. The terrorist in that case was a U.S.-bom citizen of Afghan descent. The E0 does not ban the issuance of visas to immigrants from 1th~hiiackers~fast~factsl 7h ro?le/ Afghanistan.8 24. Despite the lack of correlation between Iranians and terrorist activity explained above, the E0 has a disproportionate effect on Iranians. Of 90,000 visa holders potentially impacted from the seven countries singled out by the E0, almost half (42,542) are from Iran alone.9Further, the burden of the E0 will fall heavily on the shoulders of Iranian college students and will have a negative impact on the U.S. economy as a result. Of the seven countries referenced in the E0, Iran sends the largest number of students to the U.S. ??12,269 in the last academic year and 11th-most of any country in the world.10 Finally,? citizens of Iran and Iraq well outnumber those from the other ?ve countries among green card and visa holders,11 meaning that Iranians who are blocked from entry to the United States or are denied entry if they are in the United States and choose to {travel abroad are largely those who are already legal U.S. residents. 25. In my opinion, enforcement of the E0 will jeopardize relations between Iran and the United States. The historic nuclear accord reached in 2015 between the two countries demonstrated the power of diplomacy to resolve seemingly intractable problems. In the wake of the agreement, NIAC has advocated for the U.S. and Iran to expand bilateral and multilateral engagement beyond the nuclear issue with the aim of resolving all outstanding issues, as well as exploring areas of mutual-interest. I fear that the E0 will ected?orlando-ni ht-club-shooter/sto ?id=39790797 17/0 1/3 term=.b06ffb54fet9 9 make such engagement dif?cult,tif not impossible, and will seriously undermine the good that the nuclear accord achieved. 26., Further, I agree with the many national security experts and policymakers who have spoken out in the wake of the E0 and said that its enforCement is likely to increase, not decrease, terrorism. The order will encourage the re'sentments .and anxieties that, in some rare cases, support the ideology of the Islamic State or Harm to NIAG- 27. There is a direct conflict between enforcement of the E0, which imposes 'a blanket ban. on viSa'-iSSuance to majority?Muslim countries, including Iran, and mission of defending Iranian4American interests against'corporate and media and government neglect, and monitoring-,influencing and shaping national legislation?affecting Iranian Americans. 28. The. E0 casts a negative pan on the Iranian-American community as a whole, singling out .Iran as 'a source of ?foreign terrOrists,??when in fact, according to a Cato Institute study which examined years 1975 toiiZOIS, no Iranian citizens have carried out a fatal l. terrorist attack-"IOn US. soil. In condemnation Of Iranians who immigrate-to and visit the United States, the'EO itself discriminates against IranianAmericans while I also inviting signi?cant discrimination and bias against Iranian Americans by the media, I - cOrporations, and the public writ large. The lack of basis in the facts, which show 12See. imes;Con1/2017/01/28/us/ olitics/a?swee in 4order?unlikel ~to-reduce-terrorist- 0/ whv?tr?umps?nolicies?wi ll-increase-terrorism-and- make-i 5-2776.html. 10 29. 30. that Iranian-Americans are not a serious terrorist risk, undermines goal of enabling informed, fact-based decision-making regarding issues facing the Iranian American community. Enforcement of the E0 will also strain relations between the United States and Iran, thereby debilitating mission, of promoting greater understanding between the Iranian and American peOple. In short, the E0 stands against everything that NIAC stande for. The E0 has harmed many individuals who have reached out to NIAC for assistance and guidance. U.S. legal permanent residents of Iranian heritage have been denied entry into the United States on the basis of the E0 and are unable to leave the United States absent con?dence that they will be permitted re-entry; immigrant and non-immigrant visa- holders of Iranian heritage, including, but not limited to, Iranian students studying and residing in the United States, have been unable to return to the United States, despite the fact that they are resident in the United States; and Iranians abroad have been unable to procure visas for travel to the United States. Even US. citizens of Iranian heritage, who are not targeted under the precise terms of the E0, have been negatively affected, as family in Iran has been unable to visit. In addition, they too face its resulting stigma. Since Defendant?s executive order was signed, NIAC has had to expend a signi?cant amount of resources to respond to media inquiries and requests about the impact of the executive order on Iranian Americans and their families. NIAC has also spent a substantial number of hours providing guidance and educating the public and its members of the immediate impacts of Defendant?s executive order on immigrants, green card ll 31 32. 3'3. holders, permanent residents, and US. citizens with non-citizen Iranian family members. Several members of staff and board of directors have been interviewed repeatedly and quoted in media reports discussing Defendant?s executive order and have spent several hours on phone calls and meetings with constituents and others. NIAC will have to continue expending time and resources to media requests and inquiries. . Prior to Defendant Trump?s January 27 E0, NIAC would dedicate a majority of its time and resources to public-education activities consistent with its mission. However, due to the large volume of media inquiries following Defendant?s executive order, as well as the substantial concerns of its membership and others in the Iranian and Iranian-American community, ability to continue public education activities is severely constrained 'due to its limited resources. Due to the E0, NIAC has been flooded with calls and online inquiries directly related to the BC. In just the ?rst week after it was issued, NLAC received approximately 230 calls. 200 of those calls were from constituents directly affected by the E0 seeking assistance; 30 calls were related to the E0 in other ways; only ?ve calls were unrelated to the E0. During the same time period, a total of approximately 11 NIAC staff members were diverted, with over 647 hours spent on tasks directly related to the Trump EC). These tasks included, but are not limited to: responding to media inquiries; preparing action alerts and social media postings; collecting stories and launching a webpage to- share the stories of constituents impacted by the creating ?know your rights? graphics; updating petitions; media appearances and interviews; ?elding emails and phone calls 12 from concerned and impacted constituents; organizing a ?virtual protest,? organizing and 34. 35. 36. 37. managing grassroots volunteers; holding strategic meetings centered around the contacting legislators and government agencies seeking clari?cation on behalf of constituents; issuing press releases, and; drafting memorandums internally and to various legislators. To respond to the numerous media inquiries and inquiries from policymakers and members of the public, NIAC has expended signi?cant resources to conduct the legal research pertaining to the history of the First Amendment and Establishment Clause, as well as various statutes including the Religious Freedom Restoration Act, the Administrative Procedure Act, and the Immigration and Nationality Act. This drain on time and resources directly related to the enforcement of the E0 is certain to continue. In addition to having to closely monitor the impact of the E0 on U.S. citizens and their family members, NIAC will have to continuously research and analyze potential legal actions, analyze data from the State Department and other agencies, draft and ?le related complaints, request information under the Freedom of Information Act (F OIA), and potentially litigate FOIA-related requests. The expenditure of time and resources by NIAC used to counteract the negative effects. of the E0, were and will continue to be, diverted from other projects and activities that NIAC would have otherwise been engaged in consistent with its mission. In summary, the E0 targets Iranians without any rational basis yetjust in its ?rst week of existence, the E0 has already severely disrupted the Iranian American community. It has 13 sown confusion and anxiety as many Worry about their now-uncertain legal status, whether they will be reconnected?wit'h family members, whether they will be able to live the lives that; they have planned in the United States, Or What the future holds for relations between the two countries. "14 I, Trita Parsi, declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this :3 day of February, 2017, in 211 /rfita Pa'r?si 15 EXHIBIT 4 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et Plainti??s, v. Civil Action No. Donald J. Trump, President of the United States, at al. Defendants. DECLARATION OF THE PUBLIC AFFAIRS ALLIANCE OF IRANIAN AMERICANS IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, Leila Golestaneh Austin, hereby declare and state as follows: 1. I am over the age of eighteen years. I have personal knowledge of the facts set forth herein Or believe them to be true based on my experience or upon infonnation provided to me by others, and am competent to testify thereto. 1. Background Information for the Public Affairs Alliance of Iranian Americans 2. I am the Executive Director of the Public Affairs Alliance of Iranian Americans (PAAIA). PAAIA, Inc. is a 501(c)(4) nonpro?t, bipartisan, non-sectarian, national membership organization with an af?liated 501(c)(3), Inc. I have been the Executive Director at PAAIA since February 1, 2015. 3. Because of my position as Executive Director, I know about the history and background of PAAIA as well as the organization?s mission and purposes. I am also involved in the day to day operations of PAAIA, and thus am very familiar with our current expenses and resources. I oversee the programs and activities sponsored by PAAIA and am either involved directly or indirectly with the publications PAAIA releases or otherwise contributes to. 4. The 501(c)(3) of PAAIA has an exclusive membership comprised entirely of Iranian Americans. All of the approximately 50 members of the PAAIA 501(c)(3) are either citizens or legal permanent residents and almost all reside in the United States. Membership in the 501(c)(3) is by invitation and invitees are individuals who have demonstrated leadership in their respective ?elds, are active in the Iranian American community, and are willing to commit their resources in the promotion of goals and programs. 5. The 501(c)(4) ,of PAAIA also has members who register online with the organization. Members can elect online to register for either the free membership, the $100 Supporters members, the! $1,000 Ambassador?s Circle, the $2,500 Congressional Club membership, or the $5,000 National Leadership Circle membership. In addition, PAAIA has 18,645 individuals on our mailing list who receive our communications, 8,452 of whom have signed up under the free membership program and have the option to donate to certain programs. 6. As explained in more detail below, PAAIA engages in many programs and activities which are developed and implemented by a staff located in .Washington, DC. Currently there are three full time PAAIA staff members, including myself, and two part?time university students working as staff members. 11. Mission'& Purpose I 7. PAAIA was founded to represent and advance the interests of the Iranian American community, which. is estimated to be a population approaching one. million people, a large portion of which are citizens or permanent-legal residents. Iranian Americans are patriotic and have served in all branches of the military and many have dedicated their lives to public service. Working in tandem withthe community at large and with other organizations, PAAIA has'effectively promoted the role-of Iranian Americans inthe social, cultural, and economic tapestry. of the United States!- Servingthe interests of Iranian Americans and {representingthe community before US. policymakers and t'he'American public at td fester greater understanding .betheen the people of Iran and the United States, expand opportunities for the active participation cf Iranian Americans in the democratic proces's?at all levels of government and in the-public d?batq-and provide opportunities for advancement-for our next generation. 8. - "Since its inception in 2008, continues to carry out its mission by engaging din. programs and actiVities throughout the United? States. to benefit Iranian Americans and Promote-a positive of Iranian" Ame'ricansurk-F-or example, PAAIA has implemented programs Such as Passing the Torch: of Success, the Nova/run Project,iNowruz" on Capitol Hill, Cyrus.Cylinder Tdur at the Asian Museum in' San Francisco, and A Thousand Years of the I Persian- Bodkat the Library of Congress in Washington, DC, all of which portray a more . acCur'ateV image: of ?thelrani'amAme-rican community to the general public, policymakers, and lawmakers. 9. also fights discriminatory and harassing treatment towards Iranian ?Americans and stands up forthe-rights of Iranian-Americans by working on issues such as addressing in?ammatory remarks about Iranians made- by a retired Stanford faculty member; the professional networking website, LinkedIn placed Iran back on their education drop-down menu from where it had been removed; and working with the American Values Network (AVN) to have them drOp an anti-oil ad campaign that targeted Iran in favor of a new concept that promotes clean energy but shields innocent Iranians and Iranian Americans from a bad image. In more recent years, PAAIA has written to Chancellor Kumble R. Subbaswamy, of the University of Massachusetts, Amherst, expressing disapproval of the University?s new policy which banned Iranians from enrolling in graduate engineering programs; sponsoring a letter signed by 37 prominent Iranian Americans urging the 2016 presidential candidates to refrain from broad generalizations about the Iranian people when discussing the prospective nuclear agreement taking shape between the and Iran. In 2015, PAAIA launched a National Communications Campaign to inform the general public as well as US. lawmakers about the . Iranian-American community?s broad support for the Iran Nuclear agreement. 10. PAAIA also continues to educate the general public, lawmakers, and 7p01icymakers about the Iranian-American community, For example, in May 2014, PAAIA released a report, ?Iranian Americans: Immigration and Assimilation,? available through website at Data/ ites/ 1 /pde/ iranian-americans?n- the ?rst in a series of three reports providing more in?depth' information about Iranian Americans, which discussed among other things the three major waves of Iranian immigration to the United States, self-identi?cation of the Iranian American community, and typical benchmarks of assimilation. As another example, in June 2015, PAAIA released its 2015 Survey of Iranian Americans, which was presented in a congressional brie?ng and released to the public at large in connection with a panel discussion hosted by PAAIA on the Iran nuclear negotiations. annual Survey of Iranian Americans is'available at These are just a few examples of the?numerous publications about and on issues concerning Iranian Americans that are released by PAAIA every year. 11. Because one of key initiatives is leadership-building, PAAIA operates a number of youth programs to encourage future Iranian American leaders. - youth programs include sponsoring public service fellowships for Iranian Americans throughout the United States and helping young Iranian Americans obtain internships with legislative of?ces in Washington 12. PAAIA has been featured in national and international print and online news media. The organization Writes news articles and monitOrs the media reports on Iranian Americans. PAALA is also viewedby Iranian Americans as a Source of information about issues impacting the community;- HI. I Promotion-Of the Iranian American Communi 13. According to 2014 report on. Iranian Americans: Immigration and I AssimilatiOn,while the ?rSt known Iranian American, Mii?za Mohammed Ali (better known as Hajj Sayyah, ?The Traveler?) arrived the-United States 1867, the ?rst wave of Iranian immigration to the United States did not. occur 'until the '19505. report explained that most Iranian Americans arrived in the United States during the second Wave of migration from 19379 to 2001 and were?eeing oppression in Iran; The reportwent on to deScribe how these second-wave Iranians, as _opposed to earlier immigrants, were more likely to identify themselves as exiles or politicalrefugees. I 14. PAAIA. has also published reports documenting how Jupon arriving in the-United IStates Iranians quickly assimilated into and thrived in American culture. PAAIA provides some 5 of this information on the Demographics Statistics page of its website, As PAAIA details online, Iranian Americans have educational attainments that greatly surpass the national average. According to Ronald H. Bayer?s Multicultural America: An of the Newest Americans, about 50 percent of all working Iranian Americans are in professional and managerial occupations, greater than any other group in the United States at the time the survey was conducted. 15. While assimilating into American society, Iranian Americans maintain close ties to their family in Iran. According to 2016 National Public Opinion Survey of Iranian Americans, available online at Reportrev-newcover.ndf, 84% of respondents have family in Iran and approximately one?third are in contact with their family or friends in Iran at least several times per week. 2016 survey further reported that thirty percent of respondents traveled to Iran once every two or three years. 16. A Both as individuals and as a community Iranian Americans have actively participated in and enriched all levels of American culture and society, and have contributed to economic growth in America. PAAIA has profiled or made public information about many prominent?Iranian Americans, including Cyrus Habib, Lieutenant Governor of Washington; Hadi Partovi, CEO of education non-pro?t Code.org; and Firouz Naderi, the former associate director of Jet Propulsion Laboratory. Iranian Americans have also founded some of the most innovative companies in the last twenty years and have been on the forefront of innovations in the technology sector. To provide just a few examples of preminent Iranian Americans who I am aware of, an Iranian American, Pierre Omidyar, founded eBay; an Iranian American, Omid Kordestani, serves as the Executive Chairman of Twitter; Farzad Nazem, serves as chief technology of?cer at Yahoo; an Iranian American, Salar Kamangar, is currently the CEOiof YouTube; Iranian American Omid Kordestani is Twitter?s Executive Chairman. 17. Iranian Americans have also made signi?cant contributions to the arts, such as Shoreh Aghdashloo, an Iranian American actress whose work has been recognized by the Emmys and the Oscars, and Nasser Ovissi, an internationally acclaimed artist. 18. I am also aware of Iranian Americans who have made important contributions in public service, serving in both national and state of?ces, such as Cyrus Amir-Mokri, who served as the Assistant Secretary for Financial Institutions at the United States Treasury; aryar Shirzad, who served on the staff of the National Security Council; Goli Ameri, the current President and CEO of the Center for Global Engagement; and Azita Raji, who was nominated by President . Obama to serve as United States Ambassador to the Sweden. 19. And, while theIIranian?American community has been smeared as terrorists by the Executive Order, the very ?rst responder in the San Bernadino terrorist attack was an Iranian- American medic. One of the victims of that atrocious act was also an Iranian-American. IV. Interest In and Concern About Enforcement of the January 27, 2017 Executive Order 20. PAAIA is vitally interested in and concerned about the January 27, 2017 Executive Order, ?Protecting the Nation from Foreign Terrorist Entry into the United States? (the i 21. The E0. disrupts mission of encouraging constructive relations and enhancing mutual understanding between the peoples of the United States and Iran. We are receiving inquiries from our membership as to whether the enforcement of the E0 will also strain relations between the United States and Iran, thereby debilitating mission of promoting greater understanding between'the Iranian and American people. Members are concerned that the Executive Order creates a negative stigma on Iranian Americans, directly con?icting with the missions and purposes of PAAIA, which stands for the positive impact of Iranian Americans. 22. members have been adversely affected by the signing of the E0. For example, a PAAIA member?an I.ranian~American, internationally renowned doctor, who immigrated to the United States after the Iranian government imprisoned him for several years in what was considered to be an unjust and politically motivated strike?was tremendously impacted by the E0 when his brother, despite having a valid visa and being a visiting scholar at i an American university, was not allowed to re?enter the United States this week after visiting their elderly father in Iran. This member reached out to me, and through connections I helped him obtain assistance from attorneys working with Iranian Americans whose family members have been stranded in Iran as a result of the E0. In addition, members with family in Iran are concerned about the likelihood that their family will no longer be able to come to the United States, in some case their parents. A 23. Enforcement of the E0 has already caused PAAIA to divert substantial resources to combating the discriminatory effects, and will continue to do so. Since the E0 was signed, PAAIA has had to divert most of its resources to responding to media inquiries and requests about the impact of the E0 on Iranian Americans and their families, providing-guidance and educating the public on the impact of the E0, and developing a strategy for how to respond to the E0. PAAIA has held emergency phone calls on this subject, including an emergency telephone conference for concerned Iranian Americans with immigration and civil rights lawyers to provide its members and other Iranian Americans information about the E0 and how it might impact their lives.7 PAAIA has also prepared several press releases and informational memorandum for its members concerned about the E0. The day today-activities of PAAIA have shifted away from its regular programs and activities towards combating the negative and wrongful effects of the E0 on members: and other Iranian Americans. 24. After the E0 was signed, PAAIA had to divert its-resources away from its normal I programming and-activities. For example, PAAM was scheduled to launch a new. fellowship program for Iranian AmeriCan youth, "but was unable to do so after the E0 forced PAAIA to divert its resorirces. Similarly, the forced PAAIA to poStpone an event? that :Was going-to be hoisted'on' behalf-of an Iranian American running for local of?ce. has also been; unable to devote sta'ffitimefto activities such as planning for the'organization?s upcoming annual. event . on" capitol Hill,- fundraising for the organization, inform?atiOnal and, networking events for members, and electioneering'activities for the organization. . 25. 'As another example of how PAAIA hashad to divert resources to address the'EQ, I 'Ishortly after the E0 was signed, January 29, 2017 Iwrote-an op?ed piece for the Huf?ngton I detailing? the E0 punished Iranian Americans-who had provenevery day that they were patriotic and fully supportive of national security icOncerns. As I explained in this article, the United Sitates'ishould not ?turn a blind to the fact that the people of Iran have Consistently, demonstrated affinity for the" core values Of our American democracy including liberty, freedom, and the (rule :of law. . . . [B]y using a broad brush to l'abellall Muslims as enemies of; I America, the order ignores the fact that there-has never-been a single act 'of terror committed by ran-yene 'Of Iranian descent in the United 1 States.? This article was published .online at seCuritv 5 83d7674e4b01763 7794e35 6?u4aiuw4rCWr96bt9. 26. The E0 will continue to force PAAIA to divert time and resources. In addition to Al having to closely monitor the impact of the E0 on its members and other Iranian Americans, including U.S. citizens and their family members, PAAIA will have to continuously research and analyze legal actions, monitor announcements and activity from the Department of Homeland Security and other agencies, respond to and act upon concerns from Iranian Americans about the E0, and rally the community to direct their concerns to their Congressional representatives. 10 I, Leila-Golestaneh Austin, declare under'penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this 3 day of February, 2017, in 55? as?? DC Leil Golestaneh Austin Executive Director, Public A?az?rs Alliance of Iranian Americans 11 EXHIBIT 5 Documentl THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, Plaintl?k, v. Civil Action No._ Donald J. Trump, President of the United States, at al. Defendants. DECLARATION OF ALI ASAEI IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, 1, Ali Asaei, hereby declare and state as follows: 1. I am over the age of eighteen years, and I have personal knowledge of the facts set forth' herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein: I. Background: 2. I am an Iranian citizen. I ?rst came to the United States on September 6, 2013 on an F-l student Visa. I obtained my master?s degree in electrical engineering at SUNY New Paltzin in December 2015. . wig. :?iw 10. I then applied! for and was granted F-l OPT status, which allows me to perform work directly related to my major area of study for twelve months. My OPT status expires in June 2018. Since August 2016, have been working as a research assistant at the Nathan Kline Research Institute, which is part of the Research Foundation for Mental Hygiene (RFMH). . I live in Fort Lee, New Jersey. As a research assistant, I complete MRI image processing of brains to understand brain structure as well as the structure of diseases like Alzheimer?s and Parkinson?s disease. Our goal is to learn enough about the brain to predict the occurrence of these and other diseases. The funding for this project comes from the National Institute of Health (NIH). . In addition to my work as a research assistant, I help write image processing software that has clinical and/or research applications. Outside of my work at RFMH, I have also volunteered with a local refugee organization in Jersey City, New Jersey. I was also recently featured in a New York Times article entitled, ?Twitter Adds New Ways to Curb Abuse and Hate Speech,? 1/ 1 r=0 I last saw my mother and sister in 2014, when they visited me in the United States on. B-1 and B-2 tourist visas. I have not seen my brother or father since 2013. 11parents and sister have long been planning to visit the United States. 1? personally petitioned for visas for my family. My parents paid $160.00 each for their visa applications. Within a fewyears of applying, they were able to get a nonimmigrant visa appointment at the US. Embassy in Dubai. The appointment was scheduled for February 15, 2017. Harm Caused by the January 27, 2017 Executive Order: As a result of the January 27, 2017 Executive Order (E0), the US. Embassy in Dubai sent my parents an email on January 31, 2017 notifying them that their visa appointment has been cancelled. My family and I have received no further communication clarifying whether their visa appointment will be rescheduled. My parents are currently unable to travel to the United States to visit me. I am also unable to travel to Iran to visit them due to fear of being prevented from returning to the United States as a visa holder. Under the terms of the E0, it is unlikely that I will be able to extend or apply for new work authorization when my current OPT status expires. If the E0 continues to be enforced I will be prevented from seeing my family. As a consequence of not being able to extend or apply for new work authorization, I will likely be forced to quit my job and leave the United States permanently. upon the expiration of my OPT status or earlier. This prospect has caused me great mental and emotional distress. 1, Ali Asaei, declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this A day of February, 2017, in Orangeburg, NY Ali Asaei Ali Asaei EXHIBIT 6 Document] THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Itanian American Council, Public Affairs Alliance of Iranian Americans, Inc. et a1, Plainti?is, v. Civil Action No. Donald J. Trump, President of the United States, 61? Defendants. I DECLARATION OF SHIVA HISSONG IN SUPPORT OF MOTION FOR PRELINIINARY INJUNCTION Pursuant to Title 28 Section 1746, I, Shiva Hissong, hereby declare and state as follows: 1. My name is Shiva Hissong. I am over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. I. Background: 2. I reside in'Spokane, Washington. In November 2016 I received authorization to work in the United States but am currently a stayuat?home' motherj My husband works as an architect in Spokane, and owns an architecture ?rm andan advertising 3. I am a citizen of Iran and a Green Card holder (legal permanent resident) of the United States. 4. I am a Muslim and adhere tothe religion of Islam. 5. I I was a student in Italy from August 2012 until March 2016. I was there on a student Visa and earned credits. toward my Bachelor?s Degree in fashion. While studying in Italy, I met my husband in Rome. I 6. After-my future husband and I got engaged, I applied for and received a K-l visa. I 7. I entered the United States on thisK-l visa on March 3, 2016. 8. My husband and I were married on. 'April 17, 2016 and hosted a wedding ceremony on August '28, 2016 in Spokane, Washington. 9. MySZ?parents reside. in Tehran, Iran. My father has. been ill I With Parkinson?s disease for thej'past ten years, and his condition has Signi?cantly deteriorated in the last three to four years. I 10. My parents were unable to obtain visas to attend my Wedding due. to a lack of visa i appointments at the United States Embassies in the United Arab Emirates, Armenia, or Turkey. Subsequently, my parents decided that they would try Ito-visit the United States for. .the "birth-of grandson. I i I 12. In October 2016, .my parents were able to get. a visa-appointment at the United (States Embassy in The interviewing of?cer informed my had to undergo'an administrative.interview that would take approximately three to six months-.- 13. - son was. born'on November 28, 2016. My parents: were not presentn'for his birth. pending their visa applications "and" administrative process. They have not yet met my son. 14. In light of my father?s illness and the extended application process for my parents A to obtain a visa to visit the United States, my parents and I made plans to meet in Dubai, United A Arab Emirates in March 2017 so that my parents could meet their grandson. II. Harm Suffered Post January 27, 2017 Executive Order: 15. Prior to my parents completing an administrative interview for their visa applications, President Donald Trump signed an Executive Order on January 27, 2017 (E0) immediately prohibiting the issuance of visas to Iranian citizens, and preventing the entry of Iranian citizens into the United States. 16. Following the signing of the E0, my parents? visas applications are on hold or may have already been denied. The United States Embassy in Yerevan, Armenia has not, to the best of my knowledge, issued any electronic mail or- guidelines to my parents with respect to their applications. I 17. As a result of the confusion and uncertainty surrounding my parents? Visa applications under the terms of the E0, I do not know if my parents will be able to visit the United States while my father is healthy enough to travel. 18. The morning after the E0 was signed, the immigration attorney that I had retained advised me that I should not leave the United States due to the E0. 19. Asa result of the E0, became very concerned about my ability to exit and reenter the United States, and decided to cancel my family?s visit to the United Arab Emirates in March 2017. My parents will ?not be able to meet their grandson as originally planned. Given my father?s illness, I am concerned about whether he and my mother iwill ever be able to meet my son and I would not have canceled our visit but for the E0 and the resulting confusion about whether or not legal permanent residents like myself will be allowed to travel to and from the United States. 20. In addition, prior to the signing of the. E0, my husband andI had purchased plane tickets to visit Amsterdam, the Netherlands. Following the signing of the E0, I became concerned about my ability to exit and reenter the United States and have subsequently decided not to visit the Netherlands as originally planned. 21. As a result of the confusion and uncertainty surrounding my legal resident privileges under the terms of the E0, I do not know if I will be able to travel outside the United States. 22. I have received no guidance, information, clarity, instruction, or correspondence from the United States government or my attorney concerning the issuance of visas and/or whether my parents? visas will be issued in course or whether it will not be issued under the terms of the January 27 Executive Order. 7 23. I have received no guidance, information, clarity, instruction, or correspondence from the United States government or my attorney concerning the status of my legal residency privileges under the terms of the January 27 Executive Order. 24. As a result of the confusion and uncertainty surrounding my parents? visa applications under the terms of the January 27 Executive Order, my family and myself have been greatly emotionally distressed about whether my son and/or I will be able to see my parents, especially given the severity of my father?s illness. I, Shiva Hissong, declare under penalty ofperjm'y that the foregoing is true and correct to A the best of my knowledge. I Executed this OfFebruary, 2017, mi: EXHIBIT 7 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, Plaint??is, V. Civil Action No. Donald J. Trump, President of the United States, er al. Defendants. DECLARATION OF OMID MOGHIMI IN SUPPORT OF PLAIN MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, Omid Moghimi, hereby declare and state as follows: 1. My name is Omid Moghimi. I am over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. I. Background 2. I am 28-years-old and currently reside in En?eld, MassachusettsII am currently employed as a ?rst year resident at Dartmouth-Hitchcock Medical Center in the ?eld of internal medicine. I earned my Medical Degree from Tufts University in Boston, Massachusetts. 3. I am?a dual citizen of the United States and Iran. I was born in the United States and also hold Iranian citizenship. 4. My mother, father, and older brother are all United States citizens. 5. I married Dorsa Razi in July 2015. My wife is currently 21?yearsuold and living in Iran. She has completed two years of her undergraduate studies in mechanical engineering at Tehran University in Karaj, Iran. My wife and 1 are both Muslim. 7. On or about August 3, 2015 I ?lled out a form ?i?130? and petitioned for an 1R1 visa for my wife. My wife dropped out of her undergraduate program in anticipation of moving to the United States. i The petition was approved by United States Citizenship and Immigration Service on or about December 1, 2015 and was sent to the National Visa Center for further processing. 1 9. Onor about January 13, 2016, I received an acknowledgment letter confirming that NVC had received my wife?s petition from USCIS and requested we take some ?irther action to prepare for the visa interview process. 10. On or about June 5, 2016, I received a correspondence from NVC acknowledging receipt of documents, however, due to a high volume of petitions being processed, we were advised that NVC required an additional 30 days to review the documents. 11.- Forty?six days later, on or about July 21, 2016, I received an e-mail from NVC acknowledging that they have received?all of the docur?nentation required, and that my wife?s petition had been placed in the queue to be scheduled for an interview with a consular of?cer who would adjudicate my wife?s visa petition. 12. On or about December 29, 2016, I received an e-mail from NYC notifying my wife and I that a visa interview had been scheduled for at the US. Embassy or consulate in Abu Dhabi, UAE on February 2, 2017 at 8:00 am. 13. In reliance on the visa interview appointment, I purchased ?ights and made hotel reservations for my wife and mother?in-law to travel from Iran to Abu Dhabi. I paid approximately $1,500.00 for the ?ight and hotel reservations. By all indications, my wife?s visa would have been adjudicated and issued but for the January 27 Executive Order. II. Harm Caused by the January 27, 2017 Executive Order: 14. On January 27, 2017, President Trump issued an Executive Order restricting the isSuance of visa?s to Iranian citizens, and preventing Iranian immigrants and nonimmigrants from entering the United States. Under the terms of the Executive Order, my wife would not be issued a visa and would be prevented from entering the United States. 15. On or about January 28, 2017, the day following the signing of the executive order, I reCeived an email from stating the following: ?Due to unforeseen circumstances, your interview appointment has been canceled. We will reschedule your immigrant visa interview date and inform you of the new appointment date as soon as we are able. You do not need to take any action at this time. We apologize for any inconvenience this may have caused.? 16. On or about January 29, 2017, I received another e-mail stating the following: ?Per US. Presidential executive order, signed on January 27, 2017, visa issuance to aliens from the countries of Iraq, Iran, Libya, Somalia, Sudan, Syria and Yemen, has been suspended effective immediately until further noti?cation. Your upcoming visa appointment was cancelled in compliance with these new directives. If you are a national or dual-national of one of these 3 countries, please do not attempt to schedule a visa appointment, pay visa fees at this time, or attend your previously scheduled visa appointment.? 17. To date, I have paid approximately $500.00 in visa application fees for my wife. 18. As of the date of this af?davit, my wife'and mother-in-law are in Abu Dhabi and will be ?ying back to Tehran, Iran on or about February 3, 2017. 19. I have received no guidance, information, clarity, instruction, or correspondence from the United States government concerning the enforcement of the January 27 Executive Order? and/or whetherthe NVC will reschedule my wife?s visa appointment. I also have no information ?about whether my wife will be issued an 1R1 Visa or if she will be allowed to enter the United States. My wife and I are both greatly distressed aboilt what will happen to our family because of the Executive Order. I am faced with a very dif?cult decision of continuing my residency and being separated from my wife, or withdrawingfrom my residency and flying to Iran to be with my wife. 20. As a direct result of the uncertainty caused by the E0, I have been extremely anxious, stressed, unable to sleep and eat, depressed, and nervous because I am unclear about Whether I will continue to be separated from my wife. 21. I have been checking various internet websites and blogs every day since January- 27, 2017 in an attempt to gather further-information about the issuance of visas. 22. I I am familiar with, have registered for, and participated in, various events and functions organized by the National Iranian American Council over the last ?ve years. 23. (I am afraid because I fear that the State Department, USCIS, the NCV, and/or the government agencies listed as Defendants will take retaliatory action against me or my wife for participating in this action. I, 0mid Moghimi, declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this day of February, 2017, in En?eid. NH . Omid Moghimi Omid Moghimi EXHIBIT 8 Documentl THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et Plainti?s?, v. Civil Action No. Donald J. Trump, President of theUnited States, er Defendants. DECLARATION OF JANE DOE #1 IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, Jane Doe hereby declare and state as follows: 1. My name is Jane Doe I am over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided tome by others. If asked to do so, I could testify truth?Jlly about the matters contained herein. I. Background: 2. I am 28-years-old and currently reside in San Diego, California. I am employed With the City of San Diego. I have my Master?s Degree in city planning from San Diego State University. I 3. I am a dual citizen of the United States and Iran. 4. I am a Muslim and adhere to the religion of Islam. 5. My family sold all of their belongings and assets in Iran and immigrated to the United States in 2001. IV was ll-years-old at the time and moved with my mother, father, and sister. 6. It took approximately twelve (12) years for my family to be approved to become Green Cardholders (legal permanent residents). My family has continued to live in the United States since 2001 and myself, my mother, my father, and my sister are all United States citizens. 7. Both of my parents are small business owners in the United States. 8. In 2013,11 met my ?ance in San Diego While he was visiting the United States on a tourist visa. He is 29?years-old with a Master?s Degree in engineering from Sharif University of TechnOlogy in Tehran, Iran. 9. After traveling to Iran several times to visit my fiance, we got engaged to be married in October of 2015. Thereafter, we immediately engaged the services of a Los Angeles, California immigration attorney in December of 2015 to assist us with the visa process for my fiance to move to the United States. 10. My fiance?s petition for visa was submitted in February 2016 and was approved by April of 2016. The case was created by May of 2016. 11. In October 2016, my fiance and I traveled to Abu Dhabi for the immigrant visa interview. Thereafter, the visa was adjudicated and approVed, and we were advised that ?additional administrative processing? could take up to six months. 11. Harm Caused by the January 27, 2017 Executive Order: 12. I have personally checked the US. State Department website every day since October 2016 for status updates on my ?ance?s visa. The last entry was updated on January 10, 2017 containing general information. 13. Subsequent to the approval in October of 2016, but prior to my ?ance?s visa being adjudicated and issued, President Trump signed an Executive Order on January 27, 2017 immediately prohibiting the issuance of visas to Iranian citizens, and preventing the entry of Iranian citizens into the United States. i 14. To date, I have paid approximately $5,000.00 in travel expenses to Abu Dhabi for my fiance?s immigrant visa interview. I have also paid approximately $3,500.00 in legal fees; 15. Prior to the January 27 Executive Order, my ?ance? and I had been planning an extravagant wedding ceremony in the United States that was scheduled for 2018. 16. To date, I) have spent hundreds of hours planning my wedding and I have executed contracts and paid $2,500.00 as a down payment to secure a wedding venue. An additional $2,500.00 payment will become due in May of 2017. As a result of the confusion and uncertainty surrounding my ?ance?s visa under the terms of the January 27 Executive Order, I don?t know if I should continue to make payments to the wedding venue and/or otherwise continue planning our wedding ceremony. 17. I have received no guidance, information, clarity, instruction, or correspondence from the United States government or my attorney concerning the issuance of visas and/or whether my ?ance?s approved visa wi1l be issued in course or whether it Will not be issued under the terms of the January 27 Executive Order. 18. I have been checking various internet websites and?blogs every day since January 27, 2017 in an attempt to gather further information about the issuance of visas. ,19. As a direct result of the uncertainty caused by the E0, -1 have-been extremely anxious, stressed, unable to sleep and eat, and nervous because I am unclear about whether I will be able to be reunited with my ?ance and get married. 20. I have joined this lawsuit as an anonymous Plaintiff because I am afraid that the State Department, USCIS, the NCV, and/or the government agencies listed as Defendants will take retaliatory action against me or my fiance for participating in this action. 1, Jane Doe declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this day of February, 2017, in San Diego: CA . Jane Doe #1 Jane Doe #1 EXHIBIT 9 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian Anterican Bar Association, National Iranian American Council, Public Affairs Alliance Of_.Iranian Americans, Inc. et al, Plaintz' s, v. Civil Action No. - Donald J. Trump, President of the United States, 61? al. Defendants. DECLARATION OF JANE DOE PLAIN MOT-ION EFOR PRELIMINARY. CTION Pursuant to Title Section" 1.746, I, Jane Doe hereby declare and state as fOllowsz l. name is Jane Doe I am over the age of eighteen years, and Ihave personal knowledge 'of the facts set forth. herein or believe them to be true based on my experience or I upon information provided to me by others; If asked to do so, I could testify truthfully about the matters contained herein. I. BackgrOund: -2. am 32-yearS-old and currently reside in Phoenix, Arizona. I am currently employed as a database administrator for FedEx ServiCes' where I have worked for approximately ?ve years. have my Master?s in Business Information Systems from the University of Memphisdual citizen of the United States and Iran. I became a citizen of the United States on or about 2008. 4. I immigrated to the United States in December of 2007, with my mother, father, both of whom are also United States citizens. 5. In 2016, I petitioned. for a student visa on behalf of my sister, who is currently in Iran. My sister is 35-years-old, and is in the last semester of her Master?s program for architecture. She is a swimmer who has coached for the Federation Internationale de Natation the international governing body for competitive swimming and aquatics. My sister is also an artist that frequently paints and does intricate mosaic work. 6. I engaged the services of an immigration attorney in Los Angeles, California to assist my sister with the visa issuance process. To date, I have paid approximately $2,000.00 in attorneys? fees. 7. My mother, a dual citizen of Iran and the United States, traveled to Iran approximately two years ago to be with my sister. My father, also a dual citizen of Iran and the United States citizen, traveled to Iran approximately seven months ago to assist my sister and mother. My father was recently diagnosed with Stage 1?2 cancer. My parents are both retired. 8. Approximately six months ago, I was informed that my sister?s petition had been approved by the United States Citizenship and Immigration Service (USCIS) and the National Visa Center (NV C), and an immigrant visa interview was scheduled for her in Abu Dhabi. 9. After her initial visa interview in Abu Dhabi, my sister?s visa was denied by the consular of?cer due to a clerical error between the NVC and the immigration of?ce in Abu Dhabi. She was forced to ?y back to Iran, and return back to Abu Dhabi several months later after the clerical error had been corrected. 10. My sister traveled back to Abu Dhabi a second time, underwent a second full medical examination, and her visa was adjudicated and issued approximately four months ago. 7 Thus, she currently holds a valid visa that should allow her to travel to the United States. Her visa is set to expire in March 2017. 11. I immediately began planning for my sister to make her ?rst entry into the United States in Phoenix, Arizona, where I currently reside, to help her get acclimated and assist her with completing her immigration documents.? My. sister intended to complete her architecture studies in the United States. 12. I purchased a ?ight for my sister to depart Iran On or about February 15, 2017 for HapprOximately $1,000.00. My mother and father also purchased. tickets to return back to the ,4 United States on .or aboUt'February 16, 2017. II. Harm Gaugeab? 27. 2017 Executive-Orderi- I 9, .13. "On Jannary 27, 2017, President Trump-iSSued an Executive Order restricting the issuance of 'visa?s- to Iranian citizens, ?and preventinglranian immigrants and 'I'lonimmigrants from entering the-United States. Under the terms of the [Executive Order, my sister will be. . prevented from entering-the United States. I I i i 14. Upon-information and belief, due ta her status asa visa-holder, my sister win-be I prevented'frOm boarding ?ights departing. Iran and/or will. b'eprevented from entering the United States. I I I 15.. To date, I have paid approximately $6,000.00 to $7,000.00 forvisa-related expenses .for my sister. As aidirect result of the uncertainty caused by the E0, I have "been extremely anxious, Stressed, unable to sleep and eat, and nervous because I unclear about vyhether I-will be able to seemy' sister. 16. I have received no guidance, information, clarity, instruction, or correspondence from the United States government or my attorney concerning the enforcement of the January 27 3 Executive Order and/or whether my sister willbe prevented from leaving Iran or entering the United States. 17. I have been checking various intemet websites and blogs every day since January 27, 2017 in an attempt to gather further information about the issuance of visas. I have also contacted the National Iranian American Council (NIAC) and checked their website to get guidance and gather more information about the Executive Order. 18. As a direct result of the uncertainty caused by the E0, I have been extremely anxious, stressed, unable to sleep and eat, and nervous because I am unclear about whether I will be able to see my sister. 19. I am familiar with, have registered for, and participated in, a ?virtual protest? organized by NIAC in an effort to petition members of Congress for legislative relief from the negative effects and consequences of the January 27 Executive Order on Iranian Americans. 20. I have joined this lawsuit as an anonymous Plaintiff because I am afraid that the State Department, USCIS, the NCV, and/or the government agencies listed as Defendants will take retaliatory action against my family for participating in this action. 1, Jane Doe declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this day of February, 2017, in Phoenix. AZ . Jane Doc #2 Jane Doe #2 EXHIBIT 10 Document] THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUNIBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, 'Plamti?s, Civil Action No. V. Donald J. Trump, President of the United States, er al. Defendants. DECLARATION OF JANE DOE #3 IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, Jane Doc hereby declare and state as follows: 1.4 My name is Jane Doe I am over the age of eighteen years, and Ihave personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon, information provided to me by others. If asked to do so, I could testify truth?illy about the matters contained herein. I. Background: 2. I am 39-years-old and currently reside in Irvine, California. I am currently employed as a realtor with HomeSmart/Evergreen Realty. I have my Bachelor?s Degree ?om Azad University in Iran in the ?eld of English translation. 3. I am a dual citizen of the United States and Iran. - I inir'nigrated to the United States in March 1999 on a Kl visa after my ?ance at the time, a United States citizen, submitted a petition On my behalf. I became a United States citizen. in December 2003 . 5. I have no other family living in the United States.- Both my brother and I are Muslim by birth. I 6. In December 2003, immediately after I became a United States citizen, I i?petitionedffor an: F4 immigrant visa on behalf of my brother. My'brother is 34-years-old. He 0 I received "his Baohelor?s" Degree from Azad Universityl'in Iran and has. complet'Ed' some cours'eWOrk itovvards his Master?s Degree in economies. I Six years later. we. received a' notification-from the United States Citizenship: and. Immigration service that the petition had been apprcived andsent to: the National . "'IVisa' Center for further processing and scheduling of. immigrant visa interview. I My brother flew to Abu Dhabi forhis scheduled visa interview on. or about December-16412016. The petition was adjudicated and -:his visa wasapprOVed andiss?ued on or I "aboutDecember 19, 2016. visa is .set to expire .on June 2017. I 3- . My brother was so excited about his. visa and the-opportunity to immigrate tothe United States that he sent me 'aep'icfur? ofhim'self kissing the American ?ag'twshirt he had to the visa'interv?iew. He immediately returned. his rental-apartment in and began living with a friend preparation of moving to. the United States. 1.0. 'I'purchased a ?ight for my brother on Turkish Airlines for approximately $670.00 to depart on March 5, 2017. Harm caused by the January? 27 2017 Executive Order: 11. On January 27, 2017, President Trump issued an Executive Order restricting the issuance of visa?s to Iranian citizens, and preventing Iranian immigrants and nonimmigrants from entering the United States. Under the terms of the Executive Order, my brother and sister- in-law would be prevented from entering the United States. 12. I immediately purchased a ?ight for my brother to depart immediately on an Etihad Airways ?ight departing Iran at approximately 1:30 am. on or about January 28, 2017, the day following the signing of the executive order. I paid approximately $850.00 to purchase the ?ight, which had a layover in Abu Dhabi. i 13. Upon arriving in Abu Dhabi, my brother and fellow visa holders and Green ?Card holders traveling?to the United States were informed that they were the ?rst group being detained under the terms of the newly issued EO. My brother and fellow passengers were escorted to a room where they were detained for over 19 hours. Their passports, visas, green cards, and ?welcome packages? were con?scated. 14. Of?cials called each passenger one-by-one and showed them the text of the E0, and stated that their visa, passport, green card, and/or welcome package is being returned to them, they will have to make travel arrangements to return back to Iran. They were also told 'to get in contact with the United States Embassy in about three months for any updates. 15. In sum, 1 have paid approximately $5,000.00 and spent hundreds of hours to secure the visa for my brother, whom I have not seen in over a year. My brother?s experiences as a result of the January 27 Executive Order have caused me and my family great ?nancial and emotional harm, which" we will continue to suffer if my brother is unable to join me in the United States. 16. I have received no guidance, information, clarity, instruction, or correspondence- from the United States government concerning the enforcement of the January 27 Executive Order and/or whether my brother will be prevented from leaving Iran or entering the United States. 17. I have called various airlines in an attempt to gather more information, to no avail. 18. I have been checking various internet websites and blogs every day since January 27, 2017 in an attempt to gather further information about the issuance of visas. I have also been in contact with the National Iranian American Council to try to gather more information or clari?cation and have been receiving frequent emails from them containing information about the E0. 19. I have been very depressed since the passing of my mother last year, and the only thing I'had to look forward to was being reunited with my only brother. As a direct result of the . uncertainty caused by the BC, I have been extremely anxious, stressed, unable to sleep and eat, and nervous because I am unclear about whether .I will remain separated from my brother. 20. My brother has told me that this experience has been as shocking and as painful for him as the death of our mother a year ago. 21'. I have joined this lawsuit as an anonymous Plaintiff because I am afraid that the StateDepartment, USCIS, the NCV, and/or the government agencies listed as Defendants will I take retaliatory action against me or my brother for participating in this action. 1, Jane Doe declare under penalty of perjury that'the foregoing is true and correct to the best of my knowledge. I Executed this A day of February, 2017, in Irvine CA . Jane Doe #3 Jane Doe #3 EXHIBIT 11 THE. UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et a1 Plainti?is, v. Civil Action No. Donald Trump, President of the United States, eta]. Defendants. DECLARATIOK on DOE SUPPORT OAF PLAIN INJUNCTION {Pursuant to Title 28 U.S.C. SectiOn 1746, 1, Jane Doe #4,'hereiby declare and stateas .- follows: I I A I am' over the age of eighteen years; and I-hav'e personal knowledge of the facts set forth herein or_?bielie_ye them tobe true based on my experience 0r" upon information pr-OVided to me by" Others;- If asked to do so: "Ii'Coul'd: testify truthfully about the matters contained herein. 2. I currently reside in San Francisco, California. I am employed ?ll] time with" an architectural ?rmIranian citizen and was granted asylum the United States in -?June 2016.- I am currently-in the process of my Green Card. I am a member of also referred to as the Circle of Mysticism. I originally entered the United?States with a student Visa. I applied for asylum in the United States approximately three and a half years ago because I 1 feared religious persecution in Iran. Members of my spiritual group have recently been killed by Iranian of?cials and I am unable to return to Iran. 4. I .have lived in the United States Since ?eeing Iran in 2013?. My parents still live in Iran and were planning to visit me this year. They have applied for tourist visas and were making travel arrangements. I was also planning to travel this year to Amsterdam to visit some friends who are currently living in Europe. My friends will be returning to Iran later this year, and when that happens I will be unable to see then because I cannot return to Iran. 11. Harm Suffered Post anuam 27 . 2017 Executive Order: 5. On January 27, 2017, President Trump issued an Executive Order restricting the issuance of visas to Iranian citizens, and preventing Iranian immigrants and nonimmigrants from entering the United States. Under the terms of the Executive Order, I am no longer able to leave the United States because if I do I fear that I will not be allowed to return to the United States. I. have been instructed by my immigration attorney not to travel. outside of the United States because of the January 27 Executive Order. 6. The Executive Order has also forced my parents to cancel their plans to visit me in the United States. My parents will no longer be able to obtain a tourist visa and I will remain separated from my family. 7. I do not have any family in the United States; all of my family is in Iran. I am close to my family and the physical separation is very emotionally and mentally dif?cult for me. 8. I have received no guidance, information, clarity, instruction, or correspondence from the United States government concerning the enforcement of the January 27 Executive Order and/or whether the Executive Order will impact my pending application for a Green Card. 9. I am afraid that the State Department or other branches of the federal government will take retaliatory action against me for being a party to this action. I am especially concerned about retaliatory actions impacting my immigration status as I am still in the process for applying for my Green Card. 1, Jane Doe declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this mg? day of February, 2017, in San Francisco. CA Jane Doe #4 Jane Doe #4 EXHIBIT 12 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. at al, Plainti?s, v. Civil Action No. Donald J. Trump, President of the United States, at al. Defendants. DECLARATION OF JANE DOE #5 IN SUPPORT OF PLAIN MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, Jane Doe hereby declare and state as follows: 1. I am over themage of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. I. Background: 2., I am an Iranian citizen. My family and I are currently located in Turkey while we await safe passage to the United States as re?igees who have been accepted to the US Government?s Refugee Admissions Program. We cannot return to Iran. Approximately three years ago my brother, sister, mother, and I ?ed Iran due to fears of political persecution. We applied to be admitted to the United States as refugees and were approved by the US. Government to enter the United States under the admissions program. I 3. 4 The Jewish Family Services organization, an af?liate of HIAS, has made arrangements to assist my family and I upon our arrival in the United States and is helping us ?nd a place to live in Seattle, Washington. 4. The International Organization for Migration (IOM), which works with the US. Government to transport approved refugees to the United States, had provided me and my family members valid visas to enable us to travel to the United States. We were scheduled to ?y form Turkey to Seattle, Washington on January 30, 2017. Our travel was not possible because of President Trump?s January 27, 2017 Executive Order. H. Harm Suffered Post January 27, 2017 Executive Order: 5. On January 27, 2017, President Trump signed an Executive Order (EO) preventing the entry of Iranian visa holders as well as others into the United States. 6. As a result of the E0, my family and I were not allowed to ?y to the United States on January 30, 2017. ~We are currently still stranded in Turkey. The IOM has booked a new flight for us to travel to the United States on Wednesday, February 8, 2017. I am hoping we can . go. However, due to the uncertainty surrounding the status of the E0 and its enforcement, my family and I fear that we will not be allowed to travel to the United States on February 8. We are greatly concerned that the travel ban for Iranian visa holders such as ourselves will be reinstated by this time, and thus we will remain stranded in Istanbul. We have been in contact with an attorney from the Iranian American Bar Association who is helping us to try and ?nd an earlier flight. 7. The E0 has caused great turmoil and distress for me and my family. My family members and I have been waiting years to be approved to enter the United States. We were distraught and very upset to learn that our travel had been canceled as a result of the E0. It shattered our hopes for starting our new life in the United States. 8. My family and I have limited economic means and were counting on the ability to soon be able to support ourselves by working in the United. States. After we were unable to travel on January 30th, we were forced to stay with an acquaintance located about 6 hours outside of Istanbul and 3 hours outside of Ankara, and slept all four adults together in one room together. The IABA made arrangements for my family and I travel to Istanbul and stay in a hotel while we await safe passage to the United States. 9. I fear that the US. government will take retaliatory action against my family and I for being a party to this action and that om: involvement will negatively impact our status in the Refugee Admissions Program. I also fear that the Iranian government will learn about my involvement in this legal action and retaliate against my father who is still in Iran. I, Jane Doc declare under penalty'of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge. Executed this day of February, 2017, in Istanbul: Turkey_. Jane Doe #5 Jane Doe #5 EXHIBIT 13 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, Plainti?iv, V. Civil Action . Donald J. Trump, President of the United States, er Defendants. DECLARATION OF JANE DOE #6 IN SUPPORT OF MOTION FOR PRELIMNARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, Jane Doe hereby declare and state as follows: 1. I am over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. I. Background: 2. I an Iranian citizen. My family and I are currently located in Turkey while we await safe, passage to the United States as refugees who have been accepted to the US Government?s Refugee Admissions Program. We cannot return to Iran. Approximately'three years ago my brother, sister, mother, and I ?ed Iran due to fears of political persecution. We applied to be admitted to the United States as refugees and were approved by the US. Government to enter the United States under the admissions program. 3. The Jewish Family Services organization, an af?liate of HIAS, has made arrangements to assist my family and I upon our arrival in the United States and is helping us ?nd a place to live in Seattle, Washington. I 4. The International Organization for Migration (IOM), which works with the US. Government to transport approved refugees to the United States, had provided me and my family members valid visas to enable us to travel to the United States. We were scheduled to ?y form Turkey to Seattle, Washington on January 30, 2017. Our travel was not possible because of President Trump?s January 27, 2017 Executive Order. II. Harm Suffered Post January 27, 2017 Executive Order: 5. On January 27, 2017, President Trump signed an Executive Order (E0) preventing the entry of Iranian visa holders as well as others into the United States. 6. As a result of the E0, my family and I were not allovved to ?y to the United States on January 30, 2017. We are currently still stranded in Turkey. The IOM has booked a new ?ight for us to travel to the United States on Wednesday, February 8,2017. I am hoping we can go. However, due to the uncertainty surrounding the status of the E0 and its enforcement, my family and I fear that we willnot be allowed to travel to the United States on February 8. We are greatly concerned that the travel ban for Iranian visa holders such as ourselves will be reinstated by this time, and thus we will remain stranded in Istanbul. We have been in contact with an attorney from the Iranian American Bar Association who is helping us to try and find an earlier ?ight. 7. The E0 has caused great turmoil and distress for me and my family. My family members and I have been waiting years to be approved to enter the United States. We were distraught and very upset to learn that our travel had been canceled as a result of the E0. It shattered our hopes for starting our new life in the United States. 8. My family and I have limited economic means and were counting on the ability to soon be able to support ourselves by working in the United States. After we were unable to travel on January 30th, we were forced to stay with an acquaintance located about 6 hours outside of Istanbul and ?3 hours outside of Ankara, and slept all four adults together in one room together. The IABA made arrangements for my family and I travel to Istanbul and stay in a hotel while we await safe passage to the United States. 9. I fear that the US. government will take retaliatory action against my family and I for being a party to this action and that our involvement will negatively impact our status in the Refugee Admissions Program. I also fear that the Iranian government will learn about my involvement in this legal action and retaliate against my father who is still in Iran. 1, Jane Doe declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge. Executed this day of February, 2017, in wIstanbul, Turkey . Jane Doe #6 Jane Doc #6 EXHIBIT 14 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, Plainti??s, V. Civil Action Donald J. Trump, President of the United States, ,er al. Defendants. DECLARATION OF JANE DOE #7 IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, Jane Doe hereby declare and state as follows: 1. I am over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. I. Background: 2. I an Iranian Citizen. My family and I are currently located in Tillrkey while we await safe passage to the United States as refugees who have been accepted to the US Government?s Refugee Admissions Program. We cannot return to Iran. Approximately three years ago my son, two daughters, and I ?ed Iran due to fears of political persecution. We applied to be admitted to the United States as refugees and were approved by the U.S. Government to enter the United. States under the admissions program. 3. The Jewish Family Services organization, an af?liate of HIAS, has made arrangements to assist my family and I upon our arrival in the United States and is helping us ?nd a place to live in Seattle, Washington. 4. The International Organization for Migration (IOM), which works with the U.S. Government to transport approved refugees to the United States, had provided me and my family members valid visas to enable us to travel to the United States. We were scheduled to ?y form Turkey to' Seattle, Washington on January 30, 2017. Our travel was not possible because of President Trump?s January 27, 2017 Executive Order. II. Harm Suffered Post January 27, 2017 Executive Order: 5. On January 27, 2017, President Trump signed an Executive Order preventing the entry of Iranian visa holders as well as others into the United States. 6. As a result of the E0, my family and I were not allowed to ?y to the United States on January 30, 2017. We are currently still stranded in Turkey. The IOM has booked a new flight for'us to travel to the United States on Wednesday, February 8, 2017. I am hopingwe can go. However, due to the uncertainty surrounding the status of the E0 and its enforcement, my family and I fear that we will not be allowed to travel to the United States on February 8. We are greatly concerned that the travel ban for Iranian visa holders such as ourselves will be reinstated by this time, and thus we will remain stranded in Istanbul. We have been in contact with an attorney from the Iranian American Bar Association (IABA) who is helping us to try and ?nd an earlier ?ight. 7. The E0 has caused great turmoil and distress for me and my family. My?family members and I have been waiting years to be approved to enter the United States. We were distraught and very upset to learn that our travel had been canceled as a result of the E0. It shattered our hopes for starting our new life in the United States. 8. A My family and I have limitedeconomic means and were counting on the ability to soon be able to support ourselves by working in the UnitedrStates. After we were unable to travel on January 30th, we were forced to stay with an acquaintance located about 6 hours outside of Istanbul and 3 hours outside of Ankara, and slept all four adults together in one room together. The made arrangements for my family and I travel to Istanbul and stay in a hotel while we await safe passage to the United States. 9. I fear that the US. government will take retaliatory action against my family and I for being a party to this action and that our involvement will negatively impact our status in the Refugee Admissions Program. also fear that the Iranian government will learn about my involvement in this legal action and retaliate against my father who is still in Iran. 1, Jane Doe declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge. Executed this 7 day of February, 2017, in Istanbul, Turkey?. Jane Doe #7 Jane Doe #7 EXHIBIT 15 Docu'mentl THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et Plaintz' s, v. Civil Action No. Donald J. Trump, President of the United States, at al. Defendants. DECLARATION OF JOHN DOE #1 IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, J'ohn Doe hereby declare and state as follows: 1. I am over the age of eighteen years. I have personal knowledge of the facts set forth herein and am competent to testify thereto. I. I Background: 2. I am anlranian citizen. I ?rst arrived in the United States on an ?F?l student visa in 2015. My wife accompanied me on an F-2 visa for spouses of students. 3. I do not have any family in the United States. My entire family, as well as my wife?s family, lives in Iran. 4. In. September 2015, I started a program in Finance and Economics at Columbia University in New York, NY. While the program is formally ?ve years long, most candidates typically take six years to complete their PhDs. I am currently in the second year of my program. 10. 11. 12. . My wife has a in electrical engineering from the University of British Columbia in Vancouver, Canada. She has completed research on the newest generation of wireless communication systems and on energy harvesting and working toward more sustainable energy systems. She is a published author in the journal of the Institute of Electrical and Electronics Engineers the most prominentjournal in the ?eld of electrical engineering. When we moved, my wife was planning to apply for a green card so that she could secure employment in her ?eld in the United States. We paid $2,000.00 to retain an immigration attorney for the ?rst phase of her green card application. I Harm Caused by. the January 27, 2017 Executive Order: On or about December 24, 2016, my wife and I ?ew to Iran to visit our families. On or about anuary? 22, 2017, I ?ew back to the United States. My wife was planning to join me later that week and had purchased a ticket for a January 28, 2017 Turkish Airlines ?ight from Esfahan, Iran to New York, NY. On January 27, 2017, President Trump signed an Executive Order (E0) preventing the entry of Iranian visa holders as well as others into the United States. My wife attempted to board her ?ight on January 28, but was prevented from boarding by Turkish Airlines, citing the E0. On or about January 30, 2017, my wife attempted to board a ?ight from Tehran, Iran to the United States, but was again turned away by the airline and not permitted to board. In my opinion, it is very unlikely that the ban on entry will be lifted pursuant to its own terms as to individuals from Iran. The E0 requires the Secretary of Homeland Security to produce a list of countries that ?do not provide adequate information? to adjudicate visas 13. 14. 15. 16. 17. and other admissions. It is likely that Iran will be on that list, and very unlikely that Iran will comply with United States demands to provide more information. As a direct consequence of the E0, I have been separated from my wife since January 22, 2017, and will continue to be separated for an inde?nite period of time. I am faced with an inevitable decision of being separated from my wife, or withdrawing from my program and flying back to Iran to be reunited with her. If the E0 continues to be enforced and my wife is prohibited from entering the country, I am planning to withdraw from my program and ?y back to Iran to be reunited with my wife in Iran. Even if my wife were permitted to enter the United States on'her F-2 visa, the E0 makes it incredibly dif?cult, if not impossible, for her to secure a Green Card to work in the United States. My wife would, therefore, be relegated to staying at home rather than. continuing 'her work and research. I, have not received any guidance, clari?cation, update, instruction, or information pertaining to the E0 from the various airlines I have contacted, the United States government, or other authorities. If I am forced to return to Iran I will likely be unable to complete my studies and it will be very dif?cult for me to ?nd employment. I protested against the Iranian government during the Green Movement after the 2009 Iranian presidential election. I was detained for four days while I was an undergraduate student. As a result of my political activity, I was permanently enjoined from studying in Iran by the Iranian government. 18. I have suffered great mental anguish and emotional distress as a result of my seoaration from my wife and the strong likelihood that I will have to abandon my studies. 19. I am joining this lawsuit as an anonymous plaintiff because various government agencies are named as Defendants, and I am scared of retaliation and consequences against me and my wife if 1 reveal my identity. I, John Doe declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. A Executed this 3 day of February, 2017, in New York John Doe #1 John Doe #1 Document] EXHIBIT 16 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, Plaintiffs, v. Civil Action No Donald J. Trump, President of the United States, ,et al. Defendants. DECLARATION OF JOHN DOE #2 IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, John Doe hereby declare and state as follows: 1. - I am over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. 1. Background: 2. I am a dual citiZen of Iran and the United States. 3. - I Work as a radiology technologist at Inova urgent care in northern Virginia. I also reside in northern Virginia. 4. My parents live in Iran. My father is a dual citizen of Iran and the United States and my mother is a Green Card holder. My father is in very poor health. He is not able to travel due to his poor health. 5. One of my sisters lives in Tehran, Iran. She applied for a green card over eleven years ago and is waitingfor it to be approved. 6. My mother in law and father in law, who are Iranian citizens, completed an immigrant visa interview in Ankara, Turkey and subsequently received immigrant visas to come to the United States in December 2016. 7. They were planning to move to the United States in March 2017. They are ?fty- nine and sixty-nine years old, respectively. II. Harm Suffered Post January 27, 2017 Executive Order: 8. I learned that on January 27, 2017 President Trump had signed an Executive Order (BO) preventing the entry of Iranian visa holders as well as others into the United States. I immediately called my mother and father in-law and advised them to purchase tickets for and board a ?ight to the United States. 10. On January 28, 2017, my father and mother in law boarded a ?ight from Tehran to the United States, with a layover in Amsterdam, the Netherlands. 11. Upon arrival in Amsterdam, my father and mother in law were prevented from boarding their connecting ?ight to the United States by KLM Airlines staff. 12. My mother and father in law attempted to and were prohibited from boarding subsequent ?ights to the United States. They slept in the airport in Amsterdam for four nights. 13. At the Amsterdam airport, my mother in law and father in law were put into contact with the staff of the Iranian American Bar Association (IABA). The staff, as well as 2 other individuals my parents met at the airport, helped them in multiple ways for example, by calling a Senator in Maryland and a Senator in Virginia on their behalf. 14. After four days, my parents were able to hoard a ?ight to the United States. They landed in Dulles on February 2, 2017. 15. Because they are visa holders, my parents will not be able to travel back to Iran if the E0 continues to be enforced. They will not be able to tend to business matters that they left unfinished when they were forced to drop everything and fly to the United States. 16. In addition, due to the E0, my sister?s Green Card application is likely on hold inde?nitely or has already been denied and she will be unable to move to the United States. I 17. If my mother becomes a widow in the future, 1 was hoping she could move to the United States to live with me. I am concerned that my mother will not be able to move to the United States due to the E0. I, John Doe declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this day of February, 2017, in Sterling, John Doe #2 John Doe #2 EXHIBIT 17 THEUNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et Plaintg??s, V. Civil Action No. Donald J. Trump, President of the United States, er a1. Defendants. DECLARATION OF JOHN DOE #3 IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, John Doc hereby declare and state as follows: 1. I am over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. 1. Background: I am an Iranian citizen. My immediate family lives in Iran. 3. My wife is an Iranian citizen. 4. We currently live in Tehran, Iran. 5. My wife and I are practicing Muslims. 6. I hold a in Pharmacology as well as a Doctorate of Pharmacy from a leading university in Iran. I graduated at the top of my class in each program. 7. I am currently a resident of Pharmacology at a university in Tehran, Iran. 8. I have published extensively in the ?eld of pharmacology. Since 2007, I have been lead author or coauthor on over 40 articles in leading scienti?c journals. 9. This past year, I was awarded a fellowship by my university to study at a top- ranked hospital in Boston, Massachusetts. The fellowship has a term of three years. The fellowship had a start date of December 1, 2016. I '10. Thefellowship allows me to conduct research on diabetes effects on the heart in the lab of a professor of medicine and biochemistry at an ivy league medical school and a senior physician in cardiovascular medicine at the hospital. 11. In connection with my fellowship, I petitioned for a ?1 visa. I petitioned. for a J-2 visa for my wife at the same time. 12. My wife and I had a visa interview on October 12, 2016 in the US. Consulate in (Dubai. I i - 13. Subsequent to the interview, I received an email instructing me to bring my passport to the US. Consulate in Dubai in order for my J-l visa to be issued. 14. At that time, my wife?s email was still under administrative processing. As a result, I successfully petitioned to have the start date of my fellowship changed to February 2017. H. Harm Suffered Post January 27, 2017 Executive Order: 15. I learned from news reports that on January 27, 2017, President Trump signed an Executive Order (E0) preventing the entry of Iranian visa holders as well as others into the United States. 16. I travelled to the U.S. Consulate in Dubai on February 1, 2017, in order to get the J-1 visa placed into my passport. 2 17. When I arrived at the Consulate in Dubai, the Consulate officials told me that they were prohibited from issuing my visa due to the E0. They instructed me that I had to go back to Tehran. IS. I travelled back to Tehran from Dubai. My wife and I are still in Tehran. 19. At present, the E0 makes it impossible for me to travel to the United States. If I am unable to travel to the United States, I will be unable to participate in my fellowship at the hospital. 20. The E0 has completely upended my career plans, as well as my family?s plans to move to the United States. 21. I am in close contact with the physician who runs the lab in which I was planning to work. We exchange emails on a daily basis with updates on my situation and the 22. I have learned from the physician that they would have great dif?culty?nding a suitable replacement on short notice. In fact, he told me that he is very eager for me to join them and will consider it a great loss to his lab ifI am not able to do so. 23. I am choosing to participate in this action anonymously because I am afraid of what the US. government may do if I join this lawsuit as a named plaintiff, especially if this lawsuit is not successful in overturning the E0. I fear that the U.S. government may retaliate against me by continuing to deny issuance of my Visa, and/or failing to grant future visas for me and my wife if they ?nd out that I have publicly opposed the E0. I, John Doc declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge. Executed this day of February, 2017, in Tehran. Iran . John Doc #3 John Doc #3 EXHIBIT 18 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, Plainti?is, Civil Action No, V. Donald J. Trump, President of the United States, at al. Defendants. DECLARATION OF JOHN DOE #4 IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursriant to Title 28 U.S.C. Section 1746, I, John Doe hereby declare and state as follows: 1. I am over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. I. Background: 2. I am an Iranian citizen. My family and I are currently located in Turkey while we await safe passage to the United States as refugees who have been accepted to the US Government?s Refugee Admissions Program. We cannot return to Iran. Approximately three years ago my two sisters, mother, and I ?ed Iran due to fears of political persecution. We applied to be admitted to the United States as refugees and were approved by the U.S. Government to enter the United States under the admissions program. 3. The Jewish Family Services organization, an af?liate of HIAS, has made arrangements to assist my family and I upon our arrival in the United States and is helping us ?nd a place to live in Seattle, Washington. 4. The International Organization for Migration (IOM), which works with the U.S. Government to transport approved refugees to the United States, had provided me and my family members valid visas to enable us to travel to the United States. We were scheduled to ?y form Turkey to Seattle, Washington on January 30, 2017. Our travel was not possible because of President Trump?s January 27, 2017 Executive Order. II. Harm Suffered Post January 27, 2017 Executive Order: 5. On January 27, 2017, President Trump signed an Executive Order (EO) preventing the entry of Iranian visa holders as well as others into the United States. 6. As a result of the E0, my family and I were not allowed to ?y to the United States on January 30, 2017. We are currently still stranded in Turkey. The IOM has booked a new ?ight for us to, travel to the United States on Wednesday, February 8, 2017. I am hoping we can go. However, due to the uncertainty surrounding the status of the E0 and its enforcement, my family andI fear that we will not be allowed to travel to the United States on February 8. We are greatly concerned that the travel ban for Iranian visa holders such as ourselves will be reinstated by this time, and thus we will remain stranded in Istanbul. We have been in contact with an attorney from the Iranian American Bar Association who is helping us to try and find an earlier ?ight. 7. The E0 has caused great turmoil and distress for me and my family. My family members and I have been waiting years to be approved to enter the United States. We were distraught and very upset to learn that our travel had been canceled as a result of the E0. It shattered our hopes for starting our new life in the United States. 8. My family and I have limited economic means and were counting on the ability to soon be able to support ourselves by working in the United States. After we were unable to travel on January 30th, we were forced to stay with an acquaintance located about 6 hours outside iof Istanbul and 3 hours outside of Ankara, and slept all four adults together in one room together. The IABA made arrangements for my family and I travel to Istanbul and stay in a hotel while we await safe passage to the United States. 9. I fear that the US. government will take retaliatory action against my family and I for being a party to this action and that our involvement will negatively impact our status in the Refugee Admissions Program. I also fear that the Iranian government will learn about my involvement in this legal action and retaliate against my father who is still in Iran. I, John Doe dec1are under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge. Executed this day of February, 2017, in Istanbul, Turkey__. John Doe #4 John Doe #4 EXHIBIT 19 Documentl . THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, Plaintl?s, v. Civil Action No. Donald J. Trump, President of the United States, at Defendants. DECLARATION OF JOHN DOE ON BEHALF OF HIMSELF AND HIS MINOR CHILD BABY DOE IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, John Doe on behalf of himself and his minor child Baby Doe hereby declare and state as follows: 1. I am over the age of eighteen years, and I have personal knowledge of te facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein.? 2. My son is Baby Doe He is a minor approximately 6 months old. I. Background: 3. 1 am an Iranian citizen. Ientered to United States in September 2009 on an F?l student visa. 1 have been studying and working in the United States since then. I received a Masters Degree in mechanical engineering in 2012 from the University of Buffalo in New York, and in 2015 I received my in mechanical engineering from the University of Buffalo. I am currently working, as a post-doctoral fellow with the SUNY Research Foundation. After entering the United States on an F-l visa in 2009, I returned to Iran two times. Once in 2012 because I had a family emergency, and again in 2013 to be married to my wife. Both times I applied for and received a valid F?l visa to return to the United States. I was interviewed and had to pass a security clearance all three times I applied for an F-1 student visa. 4. I live with my wife and our infant son, Baby Doe in New York. After we were married in 2013, my wife traveled with me to the US. with a valid visa, which is available for dependents of F?l visas. 5. I My son was born in the United States in August 2016. He has both aNUnited States and Iranian passport. 6. On January 4, 2017, my wife and son traveled to Iran to introduce my son to our - family in Iran. Most of my family is in Iran and my parents and in?laws in particular were very excited to meet my son, as he is currently their only grandchild. My wife and son were planning to stay in Iran for several months so that everyone in our families could meet my son. I purchased a plane ticket for my wife and son to ?y back to the United States on or about April 4, 2017. 7. Before my wife left for Iran, we scheduled an appointment at the US. consulate in Dubai on January 17, 2017 for my wife to apply for a new -2 visa. My wife had to travel ?om Tehran to Dubai for the interview and was unable to take our son on her journey to Dubai. My wife was interviewed at the US. consulate and provided all the necessary documentation. The US. consulate approved her visa request that same day, January 17, 2017. MyIWife left Dubai immediately after her interview because she needed to return to our son in Iran. II. Harm Suffered Post January 27, 2017 Executive Order: 8. After an visa is approved by the US. consulate, it takes several days to process the paperwork and issue the visa. On January 26, 2017, at approximately 2:00 I received an email from the US. consulate stating that my Wife?s visa was ready to be issued and asking my Wife to bring her passport to the US. consulate. Shortly afterwards, my wife made arrangements for an agency in Iran to take her passport to the US. consulate and issue her F-2 visa. Agencies like this are very common in Iran and are often used by individuals like my Wife, who are unable to stay in Dubai'while consulate takes several days to issue the visa after it is approved. These agencies typically take about 4 to 5 days to travel to Dubai, receive the visa, and return the passport. 9. On January 27, 2017, President Trump signed an Executive Order (E0) preventing the entry of Iranian visa holders and others into the United States. 10. Because of the E0, the US. consulate refused to issue the visa to my wife, even though the visa had already been approved. The agency that my Wife hired to take her passport to Dubai returned her passport without the visa. 11. My wife and I continued to try and contact the US. consulate to ?nd out how it refused to issue her visa and how my wife could obtain her visa. After a federal district judge in Washington temporarily restrained enforcement of the E0, my wife contacted the US. consulate on February 4, 2017, seeking clari?cation about the status of her visa. My wife explained that her F-2 visa was approved but has not yet been issued. The US. consulate informed by wife that she may send her passport again and that the US. consulate will issue it this time. My wife and I are very concerned that the situation willchange by the time her passport reaches the US. - consulate in Dubai. We fear that the E0 will be reinstated and that the US. consulate will once again refuse to issue my wife?s visa. 12. More importantly, as a result of the E0, my wife an infant son may no longer be allowed to return to the United States on April 2017. My son is too young to travel on his own and my wife may not be able to enter the United States even if she obtains the F-2 visa from the consulate. . We are very concerned about my son?s healthi Because he is so- young, he is still completing his vaccinations. He is currently scheduled to receiVe his third reund of vaccines in the'lbeginning of April. It is'not poSsible for him to receive the vatscinesml?be must return to the United States to do so.? A I I 13. Moreover, the E0 prevents me, an Iranian. "citizen with. legal status to live and Iwork'uin from going to Iran to collect my son and bring him home; Under the: I. .Vterrns of the ED, if I leave Iran now, II run a substantial riskof not being allowed toretum to-the United States either because I would be .unablei'to obtain another F-l visa or because I would be unable to board a ,even'if Ihad a valid Iii?l visa. alSo risk losing my job in' the United .. States if travel to Iran now to be with my" wife and sen. I i I I fear that US. government will retaliate against me and my family because of my I involvement in this lawsuit. I especially concerned about retaliation against my wife, who is a very precarious sittiati'on hie-Cause her visa'_has7been appro'Ved but-not yet issued by the US. consulate. I, John Doe declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this day of February, 2017, in Amherst NY John Doe #5 John Doe on behalf of himself and his minor child, Baby Doe 1 EXHIBIT 20 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance of Iranian Americans, Inc. et al, Plaintz?s, v. Civil Action No. Donald J. Trump, President of the United States, at al. Defendants. DECLARATION OF JOHN DOE #6 IN SUPPORT OF MOTION FOR INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, John Doe hereby declare and state as follows: 1. Iam over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. I. Background: 2. I am an Iranian citizen. I live in Malaysia with my wife, four-year-old son, and eight?year?old son. I work in the oil and gas industry as a directional driller. For many years I worked for one of the largest American oil and gas drilling companies. Before I was hired I had to complete an extensive background check. I have to travel a lot for work. I am currently located on an off-shore oil rig approximately 6 hours from the Southern coast of Iran. 3. My?family and I won the Green Card lottery. We were so excited to ?nally be able to move to the United States and we made arrangements to settle down in Tampa Bay, Florida, where we have close friends who are like family. 4. On or about January 26, 2017, my family received our visas to travel to the United States. We booked ?ights to the United States for January 29, 2017, the earliest ?ight we were able to get. Our visas are set to expire in July 2017. II. Harm Suffered Post January 27, 2017 Executive Order: 5. On January 27, 2017, President Trump signed an Executive: Order (EO) preventing the entry of Iranian visa holders and others into the United States. 6. As a result of the E0, my family and I cancelled our January 29, 2017 ?ight to the United States. We learned that because of the E0 Iranian citizens were not" being allowed to board planes, even if they had a valid visa. My wife and I were also concerned that we would be stranded with our two young children or detained in an airport. 7. I emailed the US. embassy in Malaysia after the E0 was signed and the embassy replied that my family and I could not travel to the United States. It is our understanding that so long as the E0 remains in effect we will be unable to enter the United States. 8. Iwork in the oil and gas industry and was laid off in 2015 after the price of oil decreased dramatically. While I was able to find a new job, the oil industry is still a bit unstable and I remain concerned about being able to provide for my family. I decided that it would be best for me to continue working after the E0 prevented my family and I from ?ying to the United States on January 29, 2017. I work on offshore oil rigs and I was sent to a rig about 6 hours off the coast _of Southern Iran. A few days later, I learned that the travel ban in the E0 had been temporarily stayed due to the emergency ruling of a federal court in the United States, and thus 2 Iranian citizens with valid visas were being allowed: to enter the United States. I quit my job as soon as I found out but because of the nature of my work I am not able to immediately leave the oil rig. I have to wait for a replacement, which takes time since we are located so far offshore and usually work in approximately four-week rotations. 9. My family is waiting for me to travel to the United States. When my wife was studyingin Canada, my son and I were unable to join her and the separation was very dif?cult. We are very afraid that if my Wife and sons travel to the United States without me that we will be separated again. My wife and sons will ?y ?om Malaysia to Iran once I am able to leave the oil rig. As soon as my replacement arrives, I intend to travel to Iran to meet my wife and sons and if possible we will all board the next available ?ight to the United States. 10. My family and I are very concerned that the E0 will go back into enforcement and will once again prevent us from traveling to the United States. I?have been unable to sleep or eat because I am so anxious and worried. My family and felt so lucky to win the Green Card lottery and were looking forward to settling down in Florida. We have already packed everything and sold most of our possessions in Malaysia in preparation to move the United States. We will be devastated if we miss our opportunity to go the United States and?instead will have to stay in Malaysia or I will have to find another job elsewhere. There are more opportunities in the United States for my line of work and I would like to be able to work closer to where my family lives. 11. I fear that the government will retaliate against me and my family because of my involvement in this lawsuit. I am especially concerned that the US. government will revoke our visas and not allow us to obtain our Green Cards because of my involvement. Lo.) I, John Doe declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge. Executed this day of February, 2017, in Tehran John Doe #6 John Doe #6 EXHIBIT 21 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance Of Iranian Americans, Inc. et al., Plainri?s, v. Civil Action No. Donald J. Trump, President of the United States, at al. . Defendants. DECLARATION OF JOHN DOE #7 IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, John Doe hereby declare? and state as follows: 1. I am over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. I. Background: 2. I am an Iranian citizen currently living in Turkey and seeking to be admitted to the United States as a refugee. 3.) I have been in a loving committed relationship with my partner, John Doe 8, for many years. My partner and I were both born and raised in Iran. Both of us also grew up in Muslim households. The Muslim community in Iran has not been accepting of our sexual orientation. 4. My partner and I lived together in Iran for eight years. Because of this, we experienced harassment from the Iranian people. Most or all of this harassment stemmed from religious intolerance for same-sex couples in Iran. Our neighbors were suspicious of us because we were two men living together. On several occasions our neighbors reported us to the Iranian police. We lived in constant fear that we would be taken by government of?cials, who tolerate and even encourage violence against same-sex couples in Iran. I have heard of homosexual men very afraid of the police coming to arrest us. The harassment also made us feel unwanted in Iran. We were forced to move at least three different times because either landlord or the neighbors complained. The harassment was so strong that we constantly feared for our safety and, were forced to ?ee Iran. 5. My partner and I have been living in exile in Turkey for approximately 27 months. Our life in Turkey has been very dif?cult. We live in a small town where many people do not accept our relationship and we liVe in fear of violence against us. In this atmosphere, we are constantly afraid for our safety. Both my_partner and I worked full time when we lived in Iran. We are not allowed to work in Turkey. 6. My partner is very ill. He was diagnosed with colitis and he experiences a lot of physical pain. Our sub-standard living conditions worsen his health conditions. We need to go to a country where he can recover and we can get adequate medical care. 7. My partner and I are in a terrible situation. Because of our sexual orientation,.we were unsafe in Iran and are unsafe in Turkey. We have applied for refugee status and would like to be resettled to the United States where we willbe safe from persecution and where my partner can receive treatment for his medical condition. We reached out to the Office of the UN High Commissioner for Refugees (UNHCR) after we arrived in Turkey and told them we wished to be referred to the US. Refugee Admissions Program. After a interview and vetting process, UNHCR agreed to our application for refugee status, gave us documentation of that approval, and referred us to the US. Refugee Admissions Program. We are now waiting for the decision of the United States on acceptance to the program. We know that the United States Refugee Admissions Program has admitted to the program many same?sex applicants and are waiting to be proceSsed. It has been approximately 120 days since we received the certi?cates from the UN a and referral to the US admissions program. 11. Harm Suffered Post January 27, 2017 Executive Order: 8. I am aware that, on January 27, 2017, President Trump isigned Executive Order (EO) that impacts the refugee admissions process for citizens from certain countries, including Iran. 9. My partner and I check the website icmc.net, a website referred to us by the United Nations, nearly every day to keep track of our status in the US. refugee admissions process. After the E0 was signed, the website posted a notice informng us that refugees-and refugee applicants from Iran pending admission to? the US. program could not travel to the United States due to the E0. 10. The E0 has caused us great distress. My partner and I are very concerned about whether we will ever be approved by the United States to participate in the Refugee Admissions Program. 11. Since the E0 was issued my partner?s health has severely worsened. He is not able to obtain the medical care needed where we live now. I also fear that his heath will continue to decline because we are experiencing so much anxiety and uncertainty surrounding the E0 and its impact on our refugee applications. 12. My partner and I fear that US. government will retaliate against us because of our involvement in this lawsuit. We are concerned that our involvement will impact our acceptance in the Refugee Admission Program and harm our chances to be approved by the United States. We also fear persecution from the Iranian government if it were to become awarehof our application for refugee status in the United States, or our involvement in this lawsuit. I, John Doe declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this 8th day of February, 2017, in Denizli, Turkey. John Doe #7 John Doe #7 EXHIBIT 22 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, National Iranian American Council, Public Affairs Alliance Of Iranian Americans, Inc. et al., Plainti?fs, v. Civil Action No. Donald J. Trump, President of the United States, et al. . Defendants. DECLARATION OF JOHN DOE #8 IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, John Doe hereby declare and state as follows: 1. am over the age of eighteen years, and I have personal knowledge of the facts set forth herein or believe them to be true based on my experience or upon information provided to me by others. If asked to do so, I could testify truthfully about the matters contained herein. I. I Background: 2. I am an Iranian citizen currently living in Turkey and seeking to be admitted to the United States as a refugee. 3. I have been in a loving committed relationship with my partner, John Doe 7, for many years. My partner and I were both born and raised in Iran. Both of us also grew up in Muslim households. The Muslim community in Iran has not been accepting of our sexual orientation. My partner and I lived together in Iran for eight years. Because of this, we experienced harassment from the Iranian people. Most or all of this harassment stemmed from religious intolerance for same~sex couples in Iran. Our neighbors were suspicious of us because we were two men living together. On several occasions our neighbors reported us to the Iranian police. We. lived in constant fear that we would'be taken by government of?cials, who tolerate and even encourage violence against same-sex couples in Iran. I have heard of homosexual men being arrested and beaten in?Iranian prisons. We stopped answering the door because we were very afraid of the police coming to arrest us. The harassment also made us feel unwanted in Iran. We were forced to move at least three different times because either landlord or the neighbors complained. The harassment was so strong that we constantly feared for our safety and were forced to ?ee Iran. 5. My partner and I have been living in exile in Turkey for approximately 27 months. Our life in Turkey has been very difficult. We live in a small town where many people do not accept our relationship and we live in fear of violence against us. In this atmosphere, we are constantly afraid for our?safety. It has been very dif?cult for us to find employment. 6. I am very ill. I was diagnosed with colitis and experience a lot of physical pain. Our'sub-standard living conditions worsen my health conditions. We need to go to a country I where I can recover and get adequate medical care. 7. My partnerand I are in a terrible situation. Because of our sexual orientation, we were unsafe in Iran and are unsafe in Turkey. We have applied for refugee status and would like to be resettled to the United States where we will be safe from persecution and where I can 10 receive treatment for my medical condition. We reached out to the Of?ce of the UN High Commissioner for Re?igees (UNHCR) after we arrived in Turkey and told them we wished to be referred to the US. Refugee Admissions Program. After a interview and vetting process, UNHCR agreed to our application for re?igee status, gave us documentation of that approval, and referred us to the US. Refugee Admissions Program. We are now waiting for the decision of the United States on acceptance to the program. We know that the United States Refugee Admissions Program has admitted to the program many same~sex applicants and are waiting to be processed. It has been approximately 120 days since we received the certi?cates from the UN and referral to the US admissions program. II. Harm Suffered Post January 27, 2017 Executive Order: 8. I am aware that, on January 27, 2017, President Trump signed an Executive Order (E0) that impacts the refugee admissions process for citizens from certain countries, including Iran. 9. My partner and I check the website icmc.net nearly every day to keep track of our status in the US. refugee admissions process. After the E0 was signed, the website posted a notice informing us that refugees and refugee applicants from Iran pending admission to the US. program could not travel to the United States due to the E0. 10. The E0 has caused us great distress. My partner and I are very concerned ab0ut whether we will ever be approved by the United States to participate in the Refugee Admissions Program. I 11. Since the E0 was issued my health has severely worsened. I am unable to obtain the medical care needed where we live now. The anxiety and uncertainty surrounding the E0 and its impact on our refugee applications has also caused my health to worsen because of the additional stress. 12. My partner and 1 fear that US. government will retaliate against us because ?of our involvement in this lawsuit. We are concerned that our involvement will impact our acceptance ?in theRefugee Admission Program and harm our chances to be approved by the United States. We also ?fear. persecution from the Iranian government if it were to become aware of our application for refugee status in the United States, or our involvement in this lawsuit. I, John Doe declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge." Executed this 8th day of February, 2017, in Denizli, Turkey. JohnDoe #8 John Doe #8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA PARS EQUALITY CENTER et al., Civil Action No. ?17-cv-255 Plaintiffs, A v. DONALD J. TRUMP et al., Defendants. PROPOSED ORDER GRANTING MOTION FOR PRELIMINARY INJUNCTION The Court, having considered Plaintiffs? Motion for Preliminary Injunction (?Motion?) and any opposition thereto,?and ?nding that good cause appears, orders ?as follows: i The Motion is hereby GRANTED. Defendants are hereby preliminarily restrained and enjoined from: enforcing 5 and 5(e) of Executive Order No. 13,769, ?Protecting the Nation from Foreign Terrorist Entry into the United States,? including at any United States border or point of entry; applying or 5(e) of the Executive Order to deny, revoke, restrict or cancel any immigrant or nonimmigrant visa; applying or 5 of the Executive Order to deny or suspend entry or admission to any person; applying or 5(e) of the Executive Order to prohibit any person from applying for any bene?t under the Immigration and Nationality Act of 1965; denying any person subject to the Executive Order access to legal counsel of his or her choice; (D applying Sections or 5(e) of the Executive Order to instruct any airline or other common carrier to deny passage to any person; imposing or threatening to impose any ?nancial penalty on any airline or other common carrier for allowing passage to any?persOn covered by or 5(e) of the Executive Order. A IT IS SO ORDERED. Dated: February 2017 . U.S. DISTRICT JUDGE