International Refugee Assistance Project et al v. Trump et al

Filing 90

MOTION for Other Relief for Jane Doe #2 to Proceed Under Pseudonym by HIAS, Inc., Allan Hakky, International Refugee Assistance Project, Jane Doe 1, John Doe 1-4, Samaneh Takaloo (Attachments: # 1 Exhibit Decl. of Jane Doe #2)(Cox, Justin)

EXHIBIT A

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
SOUTHERN DIVISION

INTERNATIONAL REFUGEE
ASSISTANCE PROJECT, et al.,
Plaintiffs,
v.

Civil Action No.: 8:17-CV-00361-TDC
DECLARATION OF JANE DOE #2

DONALD TRUMP, et al.,
Defendants.
DECLARATION OF JANE DOE #2
I, Jane Doe #2, upon my personal knowledge, hereby submit this declaration
pursuant to 28 U.S.C. § 1746 and declare as follows:
1.

I am a United States Citizen of Syrian origin, and I live in Mecklenburg

County, North Carolina.
2.

I am currently enrolled in college and studying to become a healthcare

3.

My sister was born in Damascus, Syria, where she grew up and spent most

technician.

of her life. She is married and has two young boys, aged 7 and 2. In 2012, government planes
bombed her neighborhood in Damascus and destroyed her house. She and her family fled to the
home of her parents-in-law with nothing but their passports and the clothes on their backs. After
remaining with her in-laws for several weeks, my sister and her family eventually moved to a
home about two hours outside of Damascus, but shelling eventually reached that town, too.
4.

While internally displaced within Syria, my sister and her husband heard

rumors that the Syrian government’s selective service would eventually be expanded to include
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men over the age of 30. After my sister’s husband saw some of his friends taken for the selective
service, she told him to flee to Yemen, because only Yemen and Sudan accept Syrian refugees
without visas. She stayed behind in Syria with their first child, pregnant with their second,
because as a teacher, she was a government employee and was required to apply for government
approval to stop working and leave the country. She remained in Syria, enduring constant
shelling of their town, until she received permission from the government to leave work, at
which point she fled to Yemen with her child to join her husband.
5.

In Yemen, my sister’s family registered with the United Nations High

Commissioner for Refugees and received a temporary protection certificate explaining that they
should be protected from forcible return to Syria. They remained in Yemen for approximately a
year and a half, but war broke out in the country six or seven months after they arrived and the
capitol, where they were staying, was soon besieged. They had no electricity, fuel, clean water,
or food. Her husband had to risk his life to leave the city every day to find food and clean water
for them because no trucks could enter the city to deliver supplies.
6.

War engulfed the capitol and at one point, the house where my sister’s

family was staying was taken over by insurgents as a site for launching shells. She and her
children, including her newborn baby, were locked into a room for three to four days while
insurgent militiamen used their house to fire rockets. In the meantime, her husband, who had left
to find food, was prevented from entering. After the insurgents finally left, my sister and her
husband fled that same day for the Saudi Arabian border.
7.

My sister’s family is now in a refugee hotel on the Saudi Arabia-Yemen

border and living in terrible, life-threatening conditions. They endure regular shelling from the
Yemeni side of the border; where they live is shelled so often that the local school is open only

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one or two days a week, if at all. The building in which they live is infested with bugs; human
refuse from the bathroom of the unit above them leaks into their room. They are constantly sick
and their children are throwing up all the time. The Saudi Arabian government often turns off the
power to the building in an attempt to make the living conditions there so intolerable that the
refugees will leave.
8.

Discrimination against Syrian refugees in Saudi Arabia is severe. My

sister’s husband searches for work every day, but is often cheated out of his wages and kicked
out of jobs without payment because he is Syrian. Because her husband is gone during the day,
my sister must remain inside with her children; if she went out in public by herself, it is
unquestionable that she would be abducted because she is a woman and a Syrian. The only time
she and her children are able to leave the room where they are staying is at night, when her
husband returns home and can accompany them outside. For this reason, their children did not
believe that the sun rose and set in Saudi Arabia for the first year they were in the country
because they room where they were staying had no windows. Her children never have the
opportunity to play outside, but instead remain in their room for most of the day. During the rare
times that they are able to emerge from the building at night, my sister’s younger son cries and
tries to run away whenever they have to return to the hotel.
9.

My sister’s older son always asks her, “When am I going to have friends?”

He has not been able to make any friends because he is rarely able to go to school or to interact
with other children and his entire life has been a continual experience of displacement.
10.

I am very worried that my participation in this lawsuit against federal

government officials could jeopardize my sister’s visa application. My I-130 petition for her is
currently pending. Once approved for an I-130 visa, she will be able to access the U.S. Refugee

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Admissions Program (USRAP) through the Priority-2 Direct Access Program for Iraqi and
Syrian Beneficiaries of Form I-130 Petition for Alien Relatives. I do not want my participation in
this lawsuit to adversely impact either her visa or refugee applications and delay or prevent her
from joining me in the United States.
11.

I fear that whether or not my sister’s visa and refugee application are

denied, my participation in this case could result in harassment of me and my sister. Persecution
of Syrian refugees in Saudi Arabia is rampant, and the Saudi Arabian government tries to make
conditions difficult for Syrian refugees in the country. I fear that if my identity is made public, it
would be easy to identify her as well, making her susceptible to harassment or further
persecution.
12.

While participating in this lawsuit is important to me, I am also fearful that

my participation may lead to me and my family being targeted for harassment if my identity
were made public.
13.

Even as a United States citizen, I am fearful of leaving the United States

because I am afraid the Executive Order may result in difficulty or harassment upon my return to
the United States.
14.

I am aware of the reports indicating that harassment and violence targeting

Muslims has been on the rise recently. In fact several of my friends have experienced such
harassment on account of their perceived or actual religious affiliation. I am aware of the
shooting at the mosque in Quebec and the bombings of mosques here in the United States.
15.

For these reasons, I feel that my personal security and that of my family

necessitates that I be allowed to proceed under a pseudonym.

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