State of Washington, et al v. Donald J. Trump, et al

Filing 91

Submitted (ECF) Amicus brief for review and filed Motion to become amicus curiae. Submitted by American Immigration Council, National Immigration Project of the National Lawyers Guild, Northwest Immigrant Rights Project, Human Rights First, KIND (Kids in Need of Defense), and Tahirih Justice Center. Date of service: 02/06/2017. [10304762] [17-35105]--[COURT UPDATE: Attached exhibits (originally submitted in entry [92]), resent notice. 02/07/2017 by LA] (Mincer, Jonathan) [Entered: 02/06/2017 11:59 PM]

EXHIBIT B

1

Honorable James L. Robart

2
3
4
5
6
7
8

UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

9
10
11
12
13

Juweiya Abdiaziz ALI; A.F.A., a minor; Reema Case No.: 2:17-cv-00135-JLR
Khaled DAHMAN; G.E., a minor; Ahmed
Mohammed Ahmed ALI; E.A., a minor; on
behalf of themselves as individuals and on
DECLARATION OF CAROL E. EDWARDS
behalf of others similarly situated,
IN SUPPORT OF PLAINTIFFS
Plaintiffs-Petitioners,

14
15
16
17
18
19
20
21
22

v.
Donald TRUMP, President of the United States
of America; U.S. DEPARTMENT OF STATE;
Tom SHANNON, Acting Secretary of State;
U.S. DEPARTMENT OF HOMELAND
SECURITY; John F. KELLY, Secretary of
Homeland Security; U.S. CITIZENSHIP AND
IMMIGRATION SERVICES; Lori
SCIALABBA, Acting Director of USCIS;
OFFICE OF THE DIRECTOR OF NATIONAL
INTELLIGENCE; Michael DEMPSEY, Acting
Director of National Intelligence,

23

Defendants-Respondents.
24
25
26
27
28

DECLARATION OF CAROL E. EDWARD
Case No. 2:17-cv-00135-JLR

NORTHWEST IMMIGRANT RIGHTS PROJECT
615 Second Avenue, Suite 400
Seattle, WA 98104
206-957-8611

DECLARATION UNDER OATH
I, Carol L. Edward, hereby declare under penalty of perjury of the law of the State
of Washington, and the laws of the United States of America, that the following is true and
correct to the best of my knowledge and belief:
l. My Law Offices, tht:: Law Offices of Carol L. Edward & Associates, P.S., are the
attorneys of record for lbado Hassan and Isahaq Ahmed Rahi. Attorney Eric Lin
was involved in assisting the clients with processing the paperwork.
2. Jbado Hassan is a United States citizen and sponsored her husband Isahaq Ahmed
Rabi to join her in the United States.
3. Tbado and Isahaq went through all the normal legal channels and met all the
requirements for Isahaq to immigrate to the United States as a lawful pennanent
resident, commonly referred to as a green card holder. This includes filing
papervvork with the U.S. Department ofHomeland Security: United States
Citizenship and Immigration Services, the National Visa Center, and the U.S.
Department of State.
4. lsahaq is a Somali national and has been living in the country of Austria with a
refugee application pending. He tied Somalia due to serious and life threatening
problems he faced in Somalia.
5. Isahaq traveled to tht:: U.S. with a refugee travel document issued by tht: wuntry of
Austria and with a validly issued immigrant visa issued by the U.S. Consulate in
Vienna, Auf'tria. He had previously been interviewed and submitted the necessary
information so that background security checks could be completed prior to his visa
issuance by the Amerit:an Consulate.
6. Isahaq tle\V to the U.S. with a one-way ticket as he was planning on living in tht:
United States permanently with his wife ll1ado. He carried with him legal
documents that he provided to the customs and border patrol agents at SeaTac
International Airport. Isahaq was refused entrance to the United States at SeaTac
Airport on Saturday, January 28, 20 17.
7. The fact that Isahaq was forced to lt:avc the United States by U.S. Customs and
Border Enforcement without even an opportunity to talk to her caused Tbado great
distress as she did nol know what was happening. According to family members
who spoke to Isahaq after he returned to Vierum, he himself was not sure whether
he would be allowed to return to Vienna or would be deported back to Somalia, the
country he had fled. He was also told when he \Vas at the airport that he could not
speak to his lawyer.

DECLARATION OF CAROL E. EDWARD
Case No. 2:17-cv-00135-JLR

NORTHWEST IMMIGRANT RIGHTS PROJECT
615 Second Avenue, Suite 400
Seattle, WA 98104
206-957-8611

8. After learning that Isahaq had not been allowed to enter, I contacted CBP at the
airport by telephone and was informed that they \Yould not discuss the case w ith
me, even though I was tht: attorney for Isaha4 and further would not cwn discuss
the current procedure in dealing \Vith persons arriving from one of the seven
countries that are part of President Tnunp's executive order.

Signed on

\ { :)._q \ :;).J) I 1(date)

at

t ..vcs tlvt
~
(Place of signing, city,state

Con.c.r<..k

Signature

DECLARATION OF CAROL E. EDWARD
Case No. 2:17-cv-00135-JLR

NORTHWEST IMMIGRANT RIGHTS PROJECT
615 Second Avenue, Suite 400
Seattle, WA 98104
206-957-8611