Case 2:17-cv-00178-JLR Document 91 Filed 12/21/17 Page 1 of 3 1 The Honorable James L. Robart 2 3 4 5 6 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 8 9 JOHN DOE, et al., 10 11 12 13 Plaintiffs, v. DONALD TRUMP, in his official capacity as President of the United States, et al., Defendants. JEWISH FAMILY SERVICES, et al., 16 19 CASE NO. C17-1707JLR Plaintiffs, 17 18 SECOND SUPPLEMENTAL DECLARATION OF JOSEPH DOE IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION (RELATING TO CASE NO. C:17-0178JLR) 14 15 CASE NO. C17-0178JLR v. DONALD TRUMP, et al., Defendants. 20 21 22 23 I, “Joseph Doe,” do hereby declare and state: 24 25 26 SECOND SUPPLEMENTAL DECLARATION OF JOSEPH DOE IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION (2:17-cv-00178-JLR) - 1 AMERICAN CIVIL LIBERTIES UNION OF WASHINGTON FOUNDATION 901 Fi fth Avenue, Sui te 630 Seattle, W ashington 98164 TELEPHONE: (206) 624-2184 KELLER ROHRBACK L.L.P. 1201 Third Avenue, Suite 3200 Seattle, W A 98101 -3052 TELEPHONE: (206) 623-1900 FACSIMILE: (`206) 623 -3384 Case 2:17-cv-00178-JLR Document 91 Filed 12/21/17 Page 2 of 3 1 2 3 4 1. I have personal knowledge of the matters contained herein and, where I do not have direct knowledge, I believe them to be true and correct based upon the information available to me. 2. In order to get the required medical examinations to be cleared for travel to the 5 6 7 8 9 10 11 United States, my family has to travel to Nairobi to go to the IOM (International Organization for Migration) health clinic. This is a journey of nearly 500 miles one way from where they live. 3. They have to travel by bus, and the trip is risky because the roads are not great and accidents are common. And my wife has to travel by herself with three young children. 4. Once they get to Nairobi, they need to stay in a hotel for a few days, because they are given a window of several days when they will be seen but don’t know exactly which day 12 13 14 they will be seen at the clinic. The clinic is for migrants and refugees, and there is always a long wait as many families are waiting for their examinations. The clinic calls them the night before 15 to tell them to arrive at 7:00am the next morning. So they have to be ready and waiting in 16 Nairobi. 17 18 19 5. Paying for their lodging and transportation is expensive, and I send them extra money to cover it. They also have to pay the taxi fare to IOM from the hotel. 6. They have had two rounds of medical examinations so far. The medical 20 21 22 23 clearances expire after six months, and their first round of clearances expired in early August 2017. They are now in danger of having their second medical clearances expire. Their clearances will expire in late February 2018. 24 25 26 SECOND SUPPLEMENTAL DECLARATION OF JOSEPH DOE IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION (2:17-cv-00178-JLR) - 2 AMERICAN CIVIL LIBERTIES UNION OF WASHINGTON FOUNDATION 901 Fi fth Avenue, Sui te 630 Seattle, W ashington 98164 TELEPHONE: (206) 624-2184 KELLER ROHRBACK L.L.P. 1201 Third Avenue, Suite 3200 Seattle, W A 98101 -3052 TELEPHONE: (206) 623-1900 FACSIMILE: (`206) 623 -3384 Case 2:17-cv-00178-JLR Document 91 Filed 12/21/17 Page 3 of 3 1 EXECUTED this 20th day of December, 2017, at 2 3 4 Joseph Doe 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 SECOND SUPPLEMENTAL DECLARATION OF JOSEPH DOE IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION (2:17-cv-00178-JLR) - 3 AMERICAN CIVIL LIBERTIES UNION OF WASHINGTON FOUNDATION 901 Fi fth Avenue, Sui te 630 Seattle, W ashington 98164 TELEPHONE: (206) 624-2184 KELLER ROHRBACK L.L.P. 1201 Third Avenue, Suite 3200 Seattle, W A 98101 -3052 TELEPHONE: (206) 623-1900 FACSIMILE: (`206) 623 -3384