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 H Honorable James L. Robart 2 3 4 5 6 7 8 ITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON ATSEATfLE 9 10 A.F a minor; Reema I Case No.: 'Khaled DAHMAN; G.E., a minor; Ahmed Mohammed Ahmed ALI; E.A., a minor; on 12 behalf of themselves as individuals and on DECLARATION OF HESAM behalf of others similarly situated, 13 MOAZZAMI FARAHANI IN SUPPORT OF PLAINTIFFS 14 Plaintiffs-·Petitioners, 11 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 ofUSCIS; OFFICE OF THE . Acting 23 Defendants-Respondents. 24 25 26 27 28 DECLARATION OF HESAM MOAZZAMI FARAHANl Case No.2: 17-cv-00 135-JLR NORTHW[:ST IMMIGRANT RIGHTS PROJECT -0 615 Second Ave .• Ste. 400 Seattle, W A 98! 04 206-957 .. 8611 I, Hesam Moazzami Farah ani, declare under penalty of pe1jury as follows: 1. My name is Hesam Moazzami Farahani and I was in Iran. l am years old and I 3 work as a banker in Los A..ngeles, California. I've lived in the since 2010 and I am a 4 naturalized citizen. I became a U.S. citizen in 2016 and it was a proud day for me. I love this 5 country and becoming a citizen made me feel like I officially belonged here. 6 7 I !1 2. My mother's name Simindokht Naghi Zadeh and she is sixty~ five father's 1 8 9 10 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 11 from my parents for so long. 12 3. 13 suffers from early stage Parkinson's disease and early onset Alzheimer's. My mother has high 14 blood pressure. I am constantly worried about my parents because of their health. As the only 15 son of the family, it is my responsibility to take care of my parents. I see it as my duty to help m 16 family, particularly since I now have the resources to do so. I want my parents to live with me 17 and one of my older sisters in Los Angeles so that we can take care of them as they age. 18 4. 19 eager for my parents to come and reunite with me and my sister in Los Angeles. My sister lives 20 with me and she is recovering from breast cancer 21 22 23 24 25 26 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 27 his life. I felt so relieved knowing that my parents would be able to come and live with me. 28 NORTHWEST IMMIGRANT RK3HTS PROJEC"f DECLARATION OF HESAlVl MOAZZAM! FARAHANl Case No. 2:17-cv-00135-JLR - l 615 Second A VG ... Ste. 400 Seattle, W A 9R l 04 206-957-1\611 ~. On December 20, 2016, we bought my parents' airline tickets to travel to the U.S. on 2 March 15, 2017. We decided f(x them to travel March so that l had time to buy anew 3 l1ouse that had more space for my parents to live with me. Right now, I live in an apartment with 4 my sister. \Ve decided on the 1 5 6 .I Year, together as a family. My parents also needed time to wind down their business little by to sell one of their homes. 7 11 8 9 10 11 March so that we could celebrate Nowruz, the Persian New I 7. 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 12 thought they would be fine. However, I did not want to take any chances. I decided that my 13 parents should try and travel to the U.S. as soon as possible. On January 26, 2017, my parents 14 bought new tickets to come to Los Angeles two days later. Unfortunately, while they were on 15 their way to the U.S., everything changed. 16 8. 17 in Tehran to begin their journey to Los Angeles. They had a connection in Abu Dhabi. My 18 parents never made it on their flight to Los Angeles. They were scheduled to board Etihad 19 Airways Flight 171, leaving for Los Angeles at 8:45 in the morning on January 28 111 • However, 20 when they an·ived in Abu Dhabi, officials at the airport told them that there was a new law and 21 22 23 24 25 26 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. 9. 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 27 what they were told because they trusted the officials. The officials told my parents that signing 2R DECLARATiON OF HESAM MOAZZAMI FARAI-lANl Case No.2: 17-cv-00135-JLR NORTHWEST !MMfGRANT RIGHTS PROJECT 615 Second A vc .. Ste. 400 -2 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 2 to the United States. 3 10. 4 Later that , my parents sent me a text message telling me that officials told them they I could not come to the U.S. and that they had to go back to Iran. My parents told me they were 5 waiting in Abu Dhabi for a flight to Tehran. They told me that immigration officials had them 6 sign a paper and they sent a photo to my phone. I looked at the photo and saw an English 7 language document titled ''To Be Completed by Alien When Application for Admission 9 I Withdrawn. It was JUSt a snapshot of a single page. I asked my parents why they signed the 8 I form and they told me they dtd not know what they were signing. They said they never wanted 10 td withdraw their application and they wanted to come to Ame1ica. My parents sounded very sad 11 12 and worried. I was in shock. It was a very stressful moment for me. I had thought I was going to 13 be reunited with my parents. Instead, I wasn't sure we would be together again. 14 11. 15 detention, they were cold, uncomfortable, confused, and scared. My sister and I were panicking. 16 We did not know what to do. Eventually, my parents boarded a plane and were sent back to 17 Tehran. My father said it was the worst day ofhis life. It was also one of my worst days too. I 18 felt pressure and pain in my chest. I was so upset and confused. 19 12. 20 had to take off work because l cannot focus. All I can think about is my family. My parents are 21 22 23 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. I ·13. 24 25 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, I 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 26 bom. It hurts. AU I want is my parents to be here with me. 27 28 DECLARATJON OF HESAM MOAZZAMI F ARAHANI Case No. 2:17-cv-00135-JLR NORTHWEST iMMiGRANT RIGHTS PROJECl -3 615 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 2 true and correct to the best of my information, knowledge, belief. 3 4 5 Executed on this 2nd day ofFebruary, 2017, i 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF HESAM MOAZZAMI FARAHANI Case No. 2:17-cv-00135-JLR -4 NORTHWEST IMMIGRANT RIGHTS PROJECT 615 Second Ave., Ste. 400 Seattle, WA 98104 206-957-8611

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