Case 1:17-cv-00255-TSC Document 122 Filed 11/01/17 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA PARS EQUALITY CENTER, IRANIAN AMERICAN BAR ASSOCIATION, PUBLIC AFFAIRS ALLIANCE OF IRANIAN AMERICANS, INC., et al., Civil Action No. 1:17-cv-255 Hon. Tanya S. Chutkan Plaintiffs, v. DONALD J. TRUMP et al., Defendants. PLAINTIFFS’ LOCAL RULE 65.1(C) REQUEST FOR PERMISSION TO FILE A DECLARATION IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION Pursuant to Local Rule 65.1(c), Plaintiffs request permission to file a declaration on behalf of Abolfazl Kowsari, the U.S.-based refugee sponsor of Plaintiff Reza Zoghi, in support of Plaintiffs’ Motion for Preliminary Injunction (ECF No. 107). Plaintiffs have attached the declaration as Exhibit 1. The declaration provides updated factual information regarding Plaintiff Reza Zoghi, see ECF Nos. 117, 93, which may be helpful to the Court’s resolution of the Preliminary Injunction Motion. Plaintiffs received the declaration one day after receipt of Defendants’ Memorandum of Law in Response to Plaintiffs’ Supplemental Submission. ECF No. 121. Plaintiffs shared the declaration with Defendants immediately upon receipt. Pursuant to Local Rule 7(m), Plaintiffs met and conferred with Defendants regarding this motion as soon as feasible. Defendants oppose the motion. The Rule 7(m) correspondence is attached as Exhibit 2. Case 1:17-cv-00255-TSC Document 122 Filed 11/01/17 Page 2 of 2 Dated: November 1, 2017 Respectfully submitted, /s/ Joanna K. Wasik Cyrus Mehri (D.C. Bar # 420970) Joanna K. Wasik (D.C. Bar # 1027916) MEHRI & SKALET, PLLC 1250 Connecticut Ave., NW Suite 300 Washington, DC 20036 (202) 822-5100 (202) 822-4997 (fax) cmehri@findjustice.com John A. Freedman (D.C. Bar # 453075) David P. Gersch (D.C. Bar # 367469) R. Stanton Jones (D.C. Bar # 987088) Nancy L. Perkins (D.C. Bar # 421574) Ronald A. Schechter (D.C. Bar # 245019) Robert N. Weiner (D.C. Bar # 298133) Samuel M. Witten (D.C. Bar # 378008) Sally L. Pei (D.C. Bar # 1030194) Sonia Tabriz (D.C. Bar # 1025020) Stephen K. Wirth (D.C. Bar # 1034038) ARNOLD & PORTER KAYE SCHOLER LLP 601 Massachusetts Ave., NW Washington, DC 20001 (202) 942-5000 (202) 942-5999 (fax) john.freedman@apks.com Kristen Clarke (D.C. Bar # 973885) Jon Greenbaum (D.C. Bar # 489887) LAWYERS’ COMMITTEE FOR CIVIL RIGHTS UNDER LAW 1401 New York Ave., NW Suite 400 Washington, DC 20005 (202) 662-8600 (202) 783-0857 (fax) jgreenbaum@lawyerscommittee.org Christopher M. Odell (pro hac vice) ARNOLD & PORTER KAYE SCHOLER LLP 700 Louisiana Street, Suite 1600 Houston, TX 77002 (713) 576-2400 (713) 576-2499 (fax) christopher.odell@apks.com Hassan Zavareei (D.C. Bar # 456161) TYCKO & ZAVAREEI LLP 1828 L Street, NW Suite 1000 Washington, DC 20036 (202) 973-0900 (202) 973-0950 (fax) hzavareei@tzlegal.com Susan S. Hu (pro hac vice) ARNOLD & PORTER KAYE SCHOLER LLP 250 West 55th Street New York, NY 10019 (212) 836-8000 (303) 836-8689 (fax) susan.hu@apks.com Adrienne D. Boyd (pro hac vice) ARNOLD & PORTER KAYE SCHOLER LLP Suite 4400 370 Seventeenth Street Denver, CO 80202 (303) 863-1000 (303) 832-0428 (fax) adrienne.boyd@apks.com Counsel for Plaintiffs 2 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Pars Equality Center, Iranian American Bar Association, Public Affairs Alliance of Iranian Americans, Inc. et al, Plainti?s, v. Civil Action No. 17-255 Donald J. Trump, President of the United States, et al. Defendants. DECLARATION OF ABOLFAZL KOWSARI IN SUPPORT OF PLAIN MOTION FOR PRELIMINARY INJUNCTION Pursuant to Title 28 U.S.C. Section 1746, I, Abolfazl Kowsari, hereby declare and state as follows: 1. My name is Abolfazl Kowsari. 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 a citizen of Iran and a lawful permanent resident of the United States. I arrived in the United States in 2002 on a Diversity Immigrant Visa along with my wife. We currently reside in Minnesota. 3. I am a sponsor for Reza Zoghi. 4. I became a sponsor for Reza Zoghi because we are friends we had mutual friends in Iran and we started communicating on social media. Mr. Zoghi and his family were looking for a sponsor, and I knew this fact, and I offered to be their sponsor. 5. As a sponsor, I provided my personal information to the United Nations High Commissioner on Refugees in Turkey. 6. It is my understanding that Reza Zoghi was later connected with Lutheran Immigration and Refugee Service. Lutheran Immigration and Refugee Service called me and told me that they will assist Reza Zoghi once he and his family arrive in the United States, for a period of about three to six months. For example, the agency will ensure that Mr. Zoghi and his family have health insurance, social security numbers, housing, and some initial funds. 7. Resettlement agencies provide sponsors for refugees who arrive in the United States so that the refugees know someone when they arrive, and have a point of contact going forward. 8. In my role as sponsor, I will provide emotional support to Mr. Zoghi and his family. I will be there for them as they adjust to their new life here. 9. I will also be available to answer any questions that Mr. Zoghi and his family have about life in the United States. For example, I can help answer questions about their housing, or provide them with information about public transportation. 10. I have been in contact with Lutheran Immigration and Refugee Service prior to Mr. Zoghi?s arrival in the United States. I am one of the few individuals authorized to receive information about Mr. Zoghi and his family from Lutheran Immigration and Refugee Service. 11. On or about July 14, 2017, I contacted Lutheran Immigration and Refugee Service to ask whether the agency had made ?formal assurances? to the United States Department of State on behalf of Mr. Zoghi. I was informed by an employee of the agency that the agency had made formal assurances on Mr. Zoghi?s behalf. 12. During this phone call, Lutheran Immigration and Refugee Service also informed me that Mr. Zoghi?s case was active and that, as of July 14, 2017, it had a ?green light? for further processing. I also learned that Mr. Zoghi?s medical exam was active until October 2017. 13. Recently, I have not received any updates from Mr. Zoghi or Lutheran Immigration and Refugee Service about Mr. Zoghi. 14. Mr. Zoghi has not yet arrived in the United States. As soon as he is scheduled to arrive, Lutheran Immigration and Refugee Service will let me know. I, Albofazl Kowsari, declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this 1 day of November 2017, in Maple Grove, Minneso Albof Joanna Wasik From: Schwei, Daniel S. (CIV) Sent: Wednesday, November 01, 2017 7:41 PM To: Cyrus Mehri; 'Freedman, John Cc: 'Jones, Stanton'; 'Pei, Sally'; Joanna Wasik; 'Wirth, Stephen Subject: Re: Pars Equality Center et al v. Trump et al DDC Rule 7(m) Communication Cyrus, The Government opposes your motion. This 11th-hour ?ling is contrary to Local Civil Rule 65, as well as the Court's Minute Order of October 24 (?Unless otherwise noted, the court will not accept additional ?lings relating to Plaintiffs? Motion for Preliminary Injunction prior to the November 2 hearing") The Government has not been provided an adequate amount of time to review this declaration prior to the hearing at 9:30 tomorrow morning, and therefore would be prejudiced by its submission. --Daniel Sent from my Verizon, Samsung Galaxy smartphonc Original message From: Cyrus Mehri Date: 11/1/17 6:53 PM To: ?Freedman, John "Schwei, Daniel S. Cc: "'Jones, Stanton'" "'Pei, Sally'" Joanna Wasik "'Wirth, Stephen Subject: RE: Pars Equality Center et al v. Trump et al DDC Rule 7(m) Communication Daniel: Here is the declaration that we just received. Please respond to us by 8 pm at which time we intend to file our motion with the Court. Cyrus From: Cyrus Mehri Sent: Wednesday, November 01, 2017 6:28 PM To: 'Freedman, John Schwei, Daniel S. (CIV) Cc: Jones, Stanton; Pei, Sally; Joanna Wasik; Wirth, Stephen K. Subject: RE: Pars Equality Center et al v. Trump et al DDC Rule 7(m) Communication Daniel -- We intend to file a motion for leave under Rule 65 to submit a declaration from the refugee resettlement sponsor for Reza Zoghi. We expect to receive the declaration shortly and will send it to you immediately upon receipt so you will have copy as soon as we have it. Pursuant to Local Rule please let us know your position this evening. We look forward to hearing from you. Cyrus Case 1:17-cv-00255-TSC Document 122-3 Filed 11/01/17 Page 1 of 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA PARS EQUALITY CENTER et al., Plaintiffs, Civil Action No. 1:17-cv-255 Hon. Tanya S. Chutkan v. DONALD J. TRUMP et al., Defendants. PROPOSED ORDER GRANTING PLAINTIFFS’ MOTION FOR LEAVE TO FILE DECLARATION The Court, having considered Plaintiffs’ Rule 65(c) Request for Permission to file a Declaration in Support of the Motion for Preliminary Injunction, and finding that good cause appears, orders as follows: The Motion is hereby GRANTED. The Declaration is deemed filed and in the record in this case. IT IS SO ORDERED. Dated: November __, 2017 ____________________________ U.S. DISTRICT JUDGE