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]

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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

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