MUTHANA v. POMPEO et al
COMPLAINT Seeking Expedited Relief against WILLIAM P. BARR, MICHAEL R. POMPEO, DONALD J. TRUMP ( Filing fee $ 400 receipt number 0090-5959743) filed by AHMED ALI MUTHANA. (Attachments: #1 Civil Cover Sheet, #2 Summons, #3 Affidavit Exhibit A to Complaint, #4 Exhibit Birth Certificate, #5 Exhibit United States Mission to United Nations Letter, #6 Exhibit Department of State Letter, #7 Exhibit Letter from Charles D. Swift, #8 Exhibit Letter from U.S. Attorney ND AL)(Jump, Christina)
IN THE UNITED STATES DISTRICT
COURT FOR THE DISTRICT OF COLUMBIA
AHMED ALI MUTHANA, individually, and
as next friend of Hoda Muthana and Minor
John Doe [initials A.M.]
133 Pine Rock Lane, Hoover, AL 35226
Cause No. _______
Michael Pompeo, in his official capacity as
Secretary of the Department of State, whose
official address is 2201 C St., NW
Washington, DC 20520;
Donald J. Trump, in his official capacity as
President of the United States; and
William Pelham Barr in his official capacity
as Attorney General.
DECLARATION OF AHMED ALI MUTHANA
I, Ahmed Ali Muthana, hereby declare under penalty of perjury and in accordance with 28 U.S.C.
§ 1746 the following:
1. I submit this declaration based on my own personal knowledge.
2. I am over the age of 18 and competent to testify to the facts recited below.
3. I am the father to Hoda Muthana and grandfather to Minor John Doe Muthana.
4. I worked as a diplomatic member of the Permanent Mission of Yemen to the United Nations
from October 15, 1990 to June 1, 1994.
5. On June 1, 1994, I was terminated from that position.
6. On June 2, 1994, the Yemeni Ambassador Al-Aashtal required me to surrender my
diplomatic identity card.
7. My daughter Hoda Muthana was born on October 28, 1994, in New Jersey.
8. At the time of her birth I was not serving in a diplomatic position, and had not been for many
9. In 2004, I applied for a United States passport for my daughter Hoda Muthana.
10. I received a letter from the Department of State stating that the United States believed I had
been a diplomat at the time of Hoda Muthana’s birth.
11. I responded that I had not, and provided a letter from the United States Mission to the United
Nations, dated October 18, 2004, confirming that my diplomatic position had ended no later
than September 1, 1994.
12. I provided the letter from the United States Mission to the United Nations to the United States
Department of State, which then issued a United States passport to my daughter Hoda
Muthana on January 24, 2005.
13. My daughter Hoda Muthana renewed her United States passport on or about February 21,
14. She then flew to Turkey, and later arrived in Syria. I did not know in advance that she was
taking this trip.
15. As a result of her second marriage in Syria, my daughter Hoda Muthana had a child, referred
to herein as Minor John Doe. He was born on May 19, 2017.
16. On January 15, 2016, a letter addressed to my daughter Hoda arrived at my residence, from
the United States government informing her that her passport had been revoked.
17. I responded that she was out of the country, but also reiterating what I had provided in 2004,
and confirming the facts listed above as to when my diplomatic position ended (which was
(which was before Hoda was born).
18. Hoda and her son are. to the best ofmy knowledge, currently at Camp aJ-Hawl in yria.
19. 1 would like to send money to my daughter so that she and my grandson can return to the
20. I asked the FBI if l could do this, and the FBI told me that if I send money to my daughter
and grandson for them to leave that I will be breaking the law and will be considered to be
providing material support to ISIS.
21. I do not want to support ISIS.
22. I do want to help my daughter and grandson get to the United States.
23. My daughter has communicated to me recently that she wishes to surrender to United States
authorities. and is willing to be subject to any legal consequences under the United States
Pursuant to 28 U.S.C. § 1746. l declare under penalty of perjury that the foregoing is true
correct based on my personal knowledge.
Ahmed Ali Muthana. Declarant
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