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 H

Honorable James L. Robart
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ITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WASHINGTON
ATSEATfLE

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A.F
a minor; Reema I Case No.:
'Khaled DAHMAN; G.E., a minor; Ahmed
Mohammed Ahmed ALI; E.A., a minor; on
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behalf of themselves as individuals and on
DECLARATION OF HESAM
behalf of others similarly situated,
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MOAZZAMI FARAHANI IN SUPPORT
OF PLAINTIFFS
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Plaintiffs-·Petitioners,
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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 ofUSCIS;
OFFICE OF THE
. Acting

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Defendants-Respondents.
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DECLARATION OF
HESAM MOAZZAMI FARAHANl
Case No.2: 17-cv-00 135-JLR

NORTHW[:ST IMMIGRANT RIGHTS PROJECT

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615 Second Ave .• Ste. 400
Seattle, W A 98! 04
206-957 .. 8611

I, Hesam Moazzami Farah ani, declare under penalty of pe1jury as follows:
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My name is Hesam Moazzami Farahani and I was

in Iran. l am

years old and I

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work as a banker in Los A..ngeles, California. I've lived in the

since 2010 and I am a

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naturalized citizen. I became a U.S. citizen in 2016 and it was a proud day for me. I love this
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country and becoming a citizen made me feel like I officially belonged here.
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My mother's name Simindokht Naghi Zadeh and she is sixty~ five

father's

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name is Mohammadhossin Moazzami Farahani and he is seventy-one years old. My parents are
because I

both citizens of Iran. Since I left Iran in 2010, I have only seen my parents
did not want to see them,

because our situation is complicated. It has been tough to be apati

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from my parents for so long.

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3.

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suffers from early stage Parkinson's disease and early onset Alzheimer's. My mother has high

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blood pressure. I am constantly worried about my parents because of their health. As the only

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son of the family, it is my responsibility to take care of my parents. I see it as my duty to help m

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family, particularly since I now have the resources to do so. I want my parents to live with me

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and one of my older sisters in Los Angeles so that we can take care of them as they age.

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4.

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eager for my parents to come and reunite with me and my sister in Los Angeles. My sister lives

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with me and she is recovering from breast cancer

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5.

I have three sisters and I am the only son. My parents are elderly and sick. My father

I filed I-130 Petitions for my parents shortly after I became a U.S. citizen. I was really

I wanted us all to be together.

Once my parents' I-130 petitions were approved, we began the process of applying for

their immigrant visas. In late November 2016, my parents travelled from Tehran, Iran to Ankara,
Turkey for their interview with U.S. immigration officials. Their applications were approved and
immigration issued their visas on December 1,

16. I remember my parents called me after

learned that their visa was approved. They were so excited. My father is normally a very calm,
neutral man, butT could hear the excitement in his voice. It sounded like 20 years were added to

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his life. I felt so relieved knowing that my parents would be able to come and live with me.
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NORTHWEST IMMIGRANT RK3HTS PROJEC"f

DECLARATION OF
HESAlVl MOAZZAM! FARAHANl
Case No. 2:17-cv-00135-JLR

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615 Second A VG ... Ste. 400
Seattle, W A 9R l 04

206-957-1\611

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On December 20, 2016, we bought my parents' airline tickets to travel to the U.S. on

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March 15, 2017. We decided f(x them to travel

March so that l had time to

buy anew

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l1ouse that had more space for my parents to live with me. Right now, I live in an apartment with
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my sister. \Ve decided on the 1
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.I Year, together as a family. My parents also needed time to wind down their business little by
to sell one of their homes.

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March so that we could celebrate Nowruz, the Persian New

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In January 2017, I started hearing that Trump might take action to stop people

traveling to the U.S.

Muslim countries. Friends were posting things on Facebook and I was

hearing things on the news that made me concerned. I couldn't have imagined that my parents
would have been impacted by any sort of ban. They had permission to come to the U.S. and I

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thought they would be fine. However, I did not want to take any chances. I decided that my

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parents should try and travel to the U.S. as soon as possible. On January 26, 2017, my parents

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bought new tickets to come to Los Angeles two days later. Unfortunately, while they were on

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their way to the U.S., everything changed.

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8.

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in Tehran to begin their journey to Los Angeles. They had a connection in Abu Dhabi. My

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parents never made it on their flight to Los Angeles. They were scheduled to board Etihad

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Airways Flight 171, leaving for Los Angeles at 8:45 in the morning on January 28 111 • However,

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when they an·ived in Abu Dhabi, officials at the airport told them that there was a new law and

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On January 28, 2017, at approximately 4:10 in the moming my parents boarded a plane

they could not come to the United States anymore.

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My parents were detained and questioned by U.S. immigration officials in Abu Dhabi.

The officers spoke to my parents

a dialect they could not understand very well. The officials

said that the American President had signed a law that meant they could not go to the United
States. Officials told my parents to sign a piece of paper. The document was in English, which
my parents do not speak. My parents did not understand what was happening to them and did

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what they were told because they trusted the officials. The officials told my parents that signing
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DECLARATiON OF
HESAM MOAZZAMI FARAI-lANl
Case No.2: 17-cv-00135-JLR

NORTHWEST !MMfGRANT RIGHTS PROJECT
615 Second A vc .. Ste. 400

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Seattle. W A 981 04
20(,.'-J57-8<J II

the paper was simply proof they v,rere turned away and that it would help them in the future to go
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to the United States.
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Later that

, my parents sent me a text message telling me that officials told them they

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could not come to the U.S. and that they had to go back to Iran. My parents told me they were

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waiting in Abu Dhabi for a flight to Tehran. They told me that immigration officials had them
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sign a paper and they sent a photo to my phone. I looked at the photo and saw an English
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language document titled ''To Be Completed by Alien When Application for Admission

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Withdrawn. It was JUSt a snapshot of a single page. I asked my parents why they signed the

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form and they told me they dtd not know what they were signing. They said they never wanted

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td

withdraw their application and they wanted to come to Ame1ica. My parents sounded very sad

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and worried. I was in shock. It was a very stressful moment for me. I had thought I was going to

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be reunited with my parents. Instead, I wasn't sure we would be together again.

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detention, they were cold, uncomfortable, confused, and scared. My sister and I were panicking.

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We did not know what to do. Eventually, my parents boarded a plane and were sent back to

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Tehran. My father said it was the worst day ofhis life. It was also one of my worst days too. I

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felt pressure and pain in my chest. I was so upset and confused.

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had to take off work because l cannot focus. All I can think about is my family. My parents are

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My parents are still

Tehran. My whole life is on hold now. I can't sleep at night. I havel

i worried. When I talk to them on the phone, all they want to know is what is going to happen next

' and when they can come to the United States. My mother told me she is having trouble sleeping.
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My parents were at the airport in Abu Dhabi for approximately 18 hours. During their

January 28,2017 was supposed to be the start of a new, happy chapter for my family. We

spent a lot of money,
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and effort into getting my family's papers

order so they could

come here. I feel discriminated against and like a second class citizen because of where I was

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bom. It hurts. AU I want is

my parents to be here with me.

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DECLARATJON OF
HESAM MOAZZAMI F ARAHANI
Case No. 2:17-cv-00135-JLR

NORTHWEST iMMiGRANT RIGHTS PROJECl

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615 Second A vc .. Ste. 400
Seattle. WA 98104
206-957-8611

I declare under penalty of perjury under the laws of the United States that the foregoing i
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true and correct to the best of my information, knowledge, belief.

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Executed on this 2nd day ofFebruary, 2017, i

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DECLARATION OF
HESAM MOAZZAMI FARAHANI
Case No. 2:17-cv-00135-JLR

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NORTHWEST IMMIGRANT RIGHTS PROJECT
615 Second Ave., Ste. 400
Seattle, WA 98104
206-957-8611