State of Washington, et al., v. Trump., et al

Filing 118

Second MOTION to Amend Complaint, filed by Plaintiff State of Washington. (Attachments: # 1 Complaint Second Amended, # 2 Exhibit Exhibits to Second Amended Complaint, # 3 Index of Declarations, # 4 Decl. of R. Althaibani, # 5 Decl. of S. Amin, # 6 Decl. of B. Callaghan, # 7 Decl. of S. Dadgari, # 8 Decl. of A. Elfgeeh, # 9 Decl. of N. Fallah, # 10 Decl. of H. Ghasemzadeh, # 11 Decl. of E. Hassett, # 12 Decl. of A. Mubarez, # 13 Decl. of S. Parsian, # 14 Decl. of Z. Rasouli, # 15 Decl. of A. Shayegan, # 16 Decl. of J. Sime, # 17 Decl. of R. Branon, # 18 Decl. of A. Chaudhry, # 19 Decl. of D. Eaton, # 20 Decl. of D. Heatwole, # 21 Decl. of S. Hemmati, # 22 Decl. of R. Lewin, # 23 Decl. of A. Mehrizi-Sani, # 24 Decl. of V. Rabinowitz, # 25 Decl. of J. Riedinger, # 26 Decl. of V. Shah, # 27 Decl. of J. Wasserheit, # 28 Decl. of J. Wasserheit, # 29 Decl. of J. Wood, # 30 Decl. of N. Zimpher, # 31 Decl. of S. Buell, # 32 Decl. of R. Fullerton, # 33 Decl. of P. Johnson, # 34 Decl. of A. Lavine, # 35 Decl. of D. Pashman, # 36 Decl. of M. Rosenn, # 37 Decl. of M. Saunders, # 38 Decl. of J. Simeone, # 39 Decl. of D. Soike, # 40 Decl. of S. Topiwala, # 41 Decl. of J. Truppman, # 42 Decl. of R. Zawaideh, # 43 Decl. of M. Akhtari, # 44 Decl. of M. de Leon, # 45 Decl. of R. Eskandari, # 46 Decl. of T. Johnson, # 47 Decl. of E. Scherzer, # 48 Decl. of W. Berkovitz, # 49 Decl. of D. Duea, # 50 Decl. of L. Warren, # 51 Proposed Order) Noting Date 3/31/2017, (Melody, Colleen)

DECLARATION OF
RABBI WILL
BERKOVITZ

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turned back to their home countries, will almost certainly face life-threatening
persecution. These vulnerable individuals feel that they cannot risk being identified,
much less participate, in this lawsuit out of fear of retaliation or other consequences.
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JFS annually resettles over 300 refugees and, to date, has resettled 237 in

federal fiscal year (FY) 2017. Until Executive Order 13769 was issued, JFS was
expecting to resettle an additional 65 refugees in FYI 7. JFS has 147 clients overseas
who have already been extensively vetted and are awaiting resettlement in the United
States. Among these clients, 22 are from the six countries identified in the March 6,
2017 Executive Order whose residents have been precluded from immigration,
consisting of 11 prospective immigrants from Iran and 11 from Somalia.
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Among all JFS clients awaiting resettlement, only 8 have travel arrangements.

The U.S. Department of State has limited travel scheduling following Executive Order
13769, notwithstanding this Court's injunction. As a result, our clients have only been
scheduled for travel through March 14, 2017.

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I declare under penalty of perjury that the foregoing is true and correct.
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Executed on this LZth day of March, 2017

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Rabbi Will Berkovitz
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ATTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue, Suite 2000
Seattle, WA 98104 -318 8
(206) 464-77.14