Case 2:17-cv-00178-JLR Document 116 Filed 01/29/18 Page 1 of 6 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 DOE, et al., 10 11 12 Case No. C17-0178JLR Plaintiffs, v. DONALD TRUMP, et al., 13 DECLARATION OF CHRISTOPHER EADES IN SUPPORT OF JFS PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO STAY PROCEEDINGS Defendants. 14 15 JEWISH FAMILY SERVICES OF SEATTLE, et al., 16 17 18 v. DONALD TRUMP, et al., Defendants. 19 20 Plaintiffs, I, Christopher Eades, declare as follows: 21 22 23 24 25 26 1. I am the Executive Director of St. Andrew’s Refugee Services (―StARS‖) in Cairo, Egypt. I have held this position since October 2014. 2. StARS provides legal, educational, and psychosocial services to the refugee population in Cairo. The Refugee Legal Aid Program (―RLAP‖) at StARS provides information, counseling, referral, representation, and advocacy for refugees and asylum seekers in Egypt. In DECLARATION OF CHRISTOPHER EADES IN SUPPORT OF PLAINTIFFS’ OPPOSITION – 1 137643578.5 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 116 Filed 01/29/18 Page 2 of 6 1 my capacity as Executive Director of StARS, I oversee RLAP’s work and directly supervise the 2 RLAP Director. RLAP employs approximately 20 legal staff and volunteers representing 3 refugees in resettlement, refugee status determinations, and protection matters. 4 5 6 3. I submit this declaration in support of JFS Plaintiffs’ opposition to Defendants’ motion to stay proceedings pending disposition of cross-appeals. 4. As a result of my work at StARS, I have personal knowledge of the refugee 7 population in Egypt seeking resettlement, as well as the frequency of circuit rides conducted by 8 the Department of Homeland Security’s U.S. Citizenship and Immigration Services (“USCIS”). 9 10 11 12 13 5. During my time at StARS, the vast majority of the refugees RLAP assisted in the resettlement process were from one of the 11 SAO countries.1 6. The United Nations High Commissioner for Refugees (“UNHCR”) registers refugees in Egypt and collects data about the number of individuals registered. 7. According to the UNHCR’s most recent available statistics—from 2016—Egypt’s 14 total refugee population was 143,473.2 More than 97 percent of these registered refugees were 15 from one of the 11 SAO countries: 16 a. 116,013 refugees were from Syria; 17 b. 13,848 refugees were from Sudan; 18 c. 4,362 refugees were from Iraq; 19 d. 3,384 refugees were from Somalia; 20 1 21 22 23 24 25 26 I understand, based on media reports, that Security Advisory Opinions (“SAOs”) are required for refugees from Egypt, Iran, Iraq, Libya, Mali, North Korea, Somalia, South Sudan, Sudan, Syria, and Yemen (“the 11 SAO countries”). See, e.g., Yeganeh Torbati & Mica Rosenberg, Under Trump Plan, Refugees from 11 Countries Face Additional U.S. Barriers, REUTERS (Oct. 24, 2017), available at https://www.reuters.com/article/us-usaimmigration-refugees/under-trump-plan-refugees-from-11-countries-face-additional-u-s-barriers-idUSKBN1CT2IV. 2 See Population Statistics: Population of Concern, UNHCR, http://popstats.unhcr.org/en/persons_of_concern (enter 2016 under “year,” “Egypt” under “country/territory of asylum/residence”, “All origins” under “Origin,” and “Refugees incl. refugee-like situations” under “Data items to display.” Click “Export” tab, “CSV” under “Current View”). The resulting spreadsheet is attached hereto as Exhibit A. To calculate the total number of registered refugees in Egypt in 2016, I added all numbers under “Refugees (incl. refugee-like situations)” with the exception of Palestinians because Palestinians in Egypt are not eligible for refugee status or resettlement through UNHCR. DECLARATION OF CHRISTOPHER EADES IN SUPPORT OF PLAINTIFFS’ OPPOSITION –2 137643578.5 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 116 Filed 01/29/18 Page 3 of 6 1 e. 2,532 refugees were from South Sudan; 2 f. 66 refugees were from Yemen; 3 g. 8 refugees were from Mali; 4 h. There were no registered refugees from Libya or North Korea.3 5 6 The number of Iranians registered as refugees in Egypt in 2016 is not publicly available.4 8. In the two-year span beginning in January 2015 and ending in December 2016, 7 USCIS conducted circuit rides in Egypt approximately three out of every four fiscal year 8 quarters, or at least three times a year. 9 9. The International Organization for Migration (―IOM‖) Resettlement Support 10 Center for the Middle East and North Africa (―RSC MENA‖) operates a permanent refugee 11 processing site in Cairo, Egypt, funded by the U.S. Department of State. 12 13 10. Historically, a significant share of the refugees who arrived in the United States from the Middle East and North Africa have come from Egypt.5 14 15 16 I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. 17 Executed this 29th day of January, 2018, at 18 Cairo, Egypt. 19 20 21 Christopher Eades 22 23 3 24 25 26 See id. Although it is one of the 11 SAO countries, I have not listed Egypt here because UNHCR does not register nationals of the country in which it is located. 4 See id. 5 See IOM, Resettlement Support Center: What We Do, https://egypt.iom.int/resettlement-support-centre (―Of the 8,642 refugees who arrived in the United States in US FY 2017 with the assistance of RSC MENA, 1,417 individuals came directly from Egypt.‖). DECLARATION OF CHRISTOPHER EADES IN SUPPORT OF PLAINTIFFS’ OPPOSITION –3 137643578.5 Perkins Coie LLP 1201 Third Avenue, Suite 4900 Seattle, WA 98101-3099 Phone: 206.359.8000 Fax: 206.359.9000 Case Document 116 Filed 01/29/18 Page 4 of 6 Exhibit A Case 2:17-cv-00178-JLR Document 116 Filed 01/29/18 Page 5 of 6 Extracted from United theNations UNHCR High Population Commissioner Statisticsfor Reference RefugeesDatabase Date extracted: 2018-01-26 18:53:32 +01:00 Year 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 Country / territory Origin of asylum/residence Refugees (incl. refugee-like situations) Egypt Afghanistan 14 Egypt Azerbaijan 0 Egypt Burundi 22 Egypt Benin * Egypt Burkina Faso 0 Egypt Bangladesh 0 Egypt Central African Rep. 5 Egypt China 0 Egypt Côte d'Ivoire 139 Egypt Cameroon 5 Egypt Dem. Rep. of the Congo 38 Egypt Congo * Egypt Comoros 0 Egypt Djibouti 6 Egypt Algeria * Egypt Eritrea 1531 Egypt Estonia 0 Egypt Ethiopia 1392 Egypt Ghana 0 Egypt Guinea 6 Egypt Gambia 0 Egypt Indonesia 0 Egypt India 0 Egypt Iran (Islamic*Rep. of) Egypt Iraq 4362 Egypt Jordan 0 Egypt Kazakhstan 0 Egypt Kenya 6 Egypt Kyrgyzstan 0 Egypt Kuwait * Egypt Lebanon 0 Egypt Liberia 0 Egypt Libya 0 Egypt Sri Lanka 0 Egypt Morocco * Egypt Madagascar 0 Egypt Mali 8 Egypt Myanmar * Egypt Niger 0 Egypt Nigeria 9 Egypt Pakistan 0 Egypt Philippines * Egypt Palestinian 70027 Case 2:17-cv-00178-JLR Document 116 Filed 01/29/18 Page 6 of 6 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Egypt Russian Federation 16 Rwanda * Saudi Arabia* Sudan 13848 Solomon Islands 0 Sierra Leone* Somalia 3384 Serbia and Kosovo * (S/RES/1244 (1999)) South Sudan 2532 Syrian Arab Rep. 116013 Chad 42 Togo 0 Tajikistan 11 Turkmenistan * Tunisia * United Rep.*of Tanzania Uganda 8 Uzbekistan * Stateless * Various/Unknown 0 Yemen 66 South Africa 0 Zimbabwe 10