Case 2:17-cv-00178-JLR Document 83 Filed 12/13/17 Page 1 of 5 1 THE HONORABLE JAMES L. ROBART 2 3 4 5 6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 9 JOHN DOES, et al., 10 11 12 CASE NO. C17-0178JLR Plaintiffs, v. DONALD TRUMP, et al., 13 Defendants. SUPPLEMENTAL DECLARATION OF JOHN DOE 1 IN SUPPORT OF PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION (RELATING TO CASE NO. C17-1707JLR) 14 15 JEWISH FAMILY SERVICE, et al., Plaintiffs, 16 17 18 CASE NO. C17-1707JLR v. DONALD TRUMP, et al., Defendants. 19 20 Supplemental Declaration of John Doe 1 21 22 23 24 I, John Doe 1, upon my personal knowledge, hereby declare as follows: 1. I am a national of Iraqi origin, and I currently live in Cairo, Egypt. 2. I am waiting to travel to the United States as a refugee through the Direct Access Program for U.S.-Affiliated Iraqis (“DAP”). 25 26 SUPPLEMENTAL DOE 1 DECLARATION NO. C17-1707-JLR– 1 137847291.2 Perkins Coie LLP 1201 Third Avenue, Suite 4900 Seattle, WA 98101-3099 Phone: 206.359.8000 Fax: 206.359.9000 Case 2:17-cv-00178-JLR Document 83 Filed 12/13/17 Page 2 of 5 1 2 3. I previously provided a declaration to the International Refugee Assistance Project about my experience seeking resettlement and how I have been harmed by the most 3 4 5 recent ban on refugee admissions to the United States. 4. As I previously stated, in early October 2017, the International Organization for Migration (IOM) called to tell me that my travel to the United States was imminent 6 and that I should get ready to leave Egypt. In the time I was trying to update my 7 passport, the new refugee ban took effect, preventing me from traveling to the United 8 9 10 States. 5. On November 12, 2017, after weeks of delay, the Egyptian passport office finally refused to transfer the entry stamp from my expired Iraqi passport to my current Iraqi 11 passport, because I initially entered Egypt on a tourist visa. The Egyptian officials 12 became very aggressive and also told me I have no right to be a refugee in Egypt, 13 even though I showed them my UNHCR registration that is valid through March 14 15 16 2019. 6. The next day, on November 13, 2017, I visited the IOM office to tell them about by experience at the Egyptian passport office and ask about alternative options for travel 17 18 19 documents to exit the country. 7. The IOM employee told me that it did not matter because travel to the United States is suspended under the new Executive Order and I could not travel. She said that, if 20 21 22 travel resumes, IOM would contact me once they have a travel date for me. 8. The IOM employee also told me that, if necessary, someone from IOM would accompany me to the Egyptian passport office to assist me with getting necessary 23 paperwork after travel resumes. In addition, IRAP has referred me to a local 24 organization in Cairo that assists refugees in obtaining necessary travel documents in 25 advance of resettlement. 26 SUPPLEMENTAL DOE 1 DECLARATION NO. C17-1707-JLR – 2 137847291.2 Perkins Coie LLP 1201 Third Avenue, Suite 4900 Seattle, WA 98101-3099 Phone: 206.359.8000 Fax: 206.359.9000 Case 2:17-cv-00178-JLR Document 83 Filed 12/13/17 Page 3 of 5 1 2 3 4 9. I now remain stranded in Egypt because the new Executive Order has prevented my travel and resettlement to the United States. 10. Egypt is on the verge of becoming a war zone and my safety is at risk every day I am stuck here because of the Refugee Ban. Even worse, after my experience with the 5 Egyptian passport officers, I am afraid every day that a police officer will ask to see 6 my passport and deport me back to Iraq, which would put me and my family in even 7 greater danger. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 SUPPLEMENTAL DOE 1 DECLARATION NO. C17-1707-JLR – 3 137847291.2 Perkins Coie LLP 1201 Third Avenue, Suite 4900 Seattle, WA 98101-3099 Phone: 206.359.8000 Fax: 206.359.9000 Case Document 83 Filed 12/13/17 Page 4 of 5 I declare under penalty of perj uly under the laws of the United States of America that the foregoing is true and correct. Executed in Cairo, Egypt on December 13, 2017. SUPPLEIVIENTAL DOE 1 DECLARATION Perkins Coie LLP 2 NO C17-1707-JLR 4 1201 Third Avenue, Suite 4900 Seattle, WA 98101-3099 Phone: 206.359.8000 1378472912 Fax: 206.359.9000 Case 2:17-cv-00178-JLR Document 83 Filed 12/13/17 Page 5 of 5 1 Declaration of Translation 2 I, Alaa Majeed, affirm, under penalty of perjury under the laws of the United States of America, 3 pursuant to 28 U.S.C. § 1746, that the foregoing is true and correct: 4 1. 5 and vice versa. 6 2. 7 accurately and completely to the best of my abilities, for John Doe 1 by phone, and he informed 8 me that he understood its contents before signing the Declaration. I am fluent in both English and Arabic and competent to translate from English into Arabic I translated the within Supplemental Declaration of John Doe 1, from English to Arabic, 9 10 11 Executed on date: 12 December 12, 2017 Berlin, Germany ____________________________ ALAA MAJEED 13 14 15 16 17 18 19 20 21 22 23 24 25 26 SUPPLEMENTAL DOE 1 DECLARATION NO. C17-1707-JLR – 5 137847291.2 Perkins Coie LLP 1201 Third Avenue, Suite 4900 Seattle, WA 98101-3099 Phone: 206.359.8000 Fax: 206.359.9000