International Refugee Assistance Project et al v. Trump et al
Amended MOTION for Temporary Restraining Order and/or Preliminary Injunction by HIAS, Inc., Allan Hakky, International Refugee Assistance Project, Jane Doe 1, John Doe 1-4, Samaneh Takaloo (Attachments: # 1 Exhibit IRAP Declaration, # 2 Exhibit HIAS Declaration, # 3 Exhibit MESA Declaration, # 4 Exhibit John Doe #1 Declaration, # 5 Exhibit John Doe #3 Declaration, # 6 Exhibit Meteab Declaration, # 7 Exhibit Jane Doe #2 Declaration, # 8 Exhibit Mohomed Declaration, # 9 Exhibit Harrison Declaration, # 10 Exhibit Hausman Declaration Pt.1, # 11 Exhibit Hausman Declaration Pt.2, # 12 Exhibit Hausman Declaration Pt.3)(Jadwat, Omar)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
ASSISTANCE PROJECT, et al.,
Civil Action No.: 8:17-CV-00361-TDC
DONALD TRUMP, et al,
DECLARATION OF PAUL HARRISON
I, Paul Harrison, upon my personal knowledge, hereby submit this declaration
pursuant 28 U.S.C. § 1746 and declare as follows:
I am a United States citizen, and I live in Euless, Texas.
My fiancé is an Iranian national who lives in Tehran, Iran. We have been
together since November 2015. He was raised Muslim.
In March 2016, I petitioned for a K-1 visa for my partner—by then, my fiancé—
so he could join me in the United States. He had an interview at the U.S. Embassy in Ankara,
Turkey on November 7, 2016.
On January 17, 2017, we found out via an email from the U.S. Embassy in
Ankara that my partner’s visa processing was complete.
On January 27, 2017, President Trump signed Executive Order 13769, entitled
“Protecting the Nation from Foreign Terrorist Entry Into the United States,” which barred all
Iranian nationals from coming to the United States.
On January 30, 2017, we received a subsequent email from the U.S. Embassy in
Ankara, stating that my fiancé should not submit his passport because his visa process had been
placed on hold until further notice. The email said he should check online and contact the
Embassy when the ban was lifted to continue his visa processing.
On February 7, 2017, my partner received another email from the Embassy,
informing him that he could now submit his passport for the visa because the Department of
Justice had informed the embassy of the Washington State court ruling, barring the U.S.
government from enforcing certain provisions of Executive Order 13769, including those related
to visas and travel.
My partner and I made plans to meet in Turkey and to submit his passport for the
visa processing. We arrived in Turkey on March 3, 2017. On March 6, 2017, we learned there
was a new Executive Order that also barred Iranian nationals from coming to the United States
unless their visa had already been issued.
We looked at the website of the U.S. Embassy in Ankara to see if there was an
instruction not to submit passports because of the new order, but there was no new information.
On March 8, 2017, we submitted my partner’s passport to the U.S. Embassy in Ankara through
an express mail carrier.
The Executive Order is creating a significant hardship for me and my partner. I
cannot visit him in Iran, given Iran’s reciprocal ban on U.S. citizen visitors, and the continued
cost of flying to Turkey to be together is a considerable financial hardship.
Moreover, homosexuality is a crime in Iran, punishable in some cases by death.
My partner has had two incidents with the morality police in Iran who harassed him on one
occasion and assaulted him on another. For him, living each day hiding who he is and in
constant fear of exposure for his homosexuality is incredibly emotionally and mentally stressful.
He wants the opportunity to live as himself, and I am eager for him to join me here in the United
States where we can live openly together as a couple.
I am concerned that, even if there is a possibility of a waiver, my partner will have
to start this lengthy process over again, and there is no guarantee that he will receive a waiver,
even after previously being approved for a visa to the United States. I am also concerned that, as
relations deteriorate between the United States and Iran, it will only become more difficult for
my partner if the U.S. Embassy requires more information from Iran to process his visa.
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