COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF AND JURY DEMAND
Source: Council on American‐Islamic Relations
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
LINDA SARSOUR;
RASHIDA TLAIB;
ZAHRA BILLOO;
NIHAD AWAD;
COREY SAYLOR;
DAWUD WALID;
BASIM ELKARRA;
HUSSAM AYLOUSH;
HASSAN SHIBLY;
ALIA SALEM;
ADAM SOLTANI;
IMRAN SIDDIQI;
JULIA SHEARSON;
NAMIRA ISLAM;
KAREN DABDOUB;
JOHN DOE NO. 1;
JOHN DOE NO. 2;
JOHN DOE NO. 3;
JOHN DOE NO. 4;
JOHN DOE NO. 5;
JOHN DOE NO. 6;
JOHN DOE NO. 7;
JOHN DOE NO. 8;
JOHN DOE NO. 9;
JOHN DOE NO. 10;
JANE DOE NO. 1;
JANE DOE NO. 2;
Plaintiffs,
v.
DONALD J. TRUMP, President of the United States of America; in his official capacity
JOHN F. KELLY, Secretary of the Department of Homeland Security; in his official capacity
U.S. DEPARTMENT OF STATE; and,
DIRECTOR OF NATIONAL INTELLIGENCE;
Defendants.
COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF
Plaintiffs, for themselves and on behalf of all others similarly situated, by and through their attorneys, Council on American‐Islamic Relations (CAIR), The Law Office of Gadeir Abbas, and Akeel and Valentine, PLC, state as follows:
Introduction
1. The vulgar animosity that accounts for the existence of Executive Order entitled Protecting the Nation from Terrorist Attacks by Foreign Nationals (hereinafter the Muslim Exclusion Order), issued the same day of this action, is plain to see, and the absence
of the words Islam or Muslim does nothing to obscure it.
2. In fact, the Executive Order has already gained national and international media attention and nationwide protests, and has been dubbed uniformly as the Muslim Ban because its apparent and true purpose and underlying motivewhich is to ban Muslims from certain Muslim‐majority countries (Iraq, Iran, Libya, Somalia, Sudan, Syria and Yemen) (hereinafter the Muslim majority countries)has been broadcast to the general public by the Trump Administration.
3. Less known is the second and equally central purpose of the Muslim Exclusion Order to initiate the mass expulsion of immigrant and nonimmigrant Muslims lawfully residing in the United States by denying them the ability to renew their lawful status or
receive immigration benefits afforded to them under the Immigration and Nationality Act of 1965 (INA) based solely on their religious beliefs.
4. Many Muslims lawfully in the United States that are targeted by the Muslim Exclusion Order, including some of the John Doe and John Doe Plaintiffs, will be forced as a result of the Muslim Exclusion Order to return to their home countries, where they will
likely face persecution, torture and even execution, simply because they are Muslim.
Read more: https://assets.documentcloud.org/documents/3438628/CAIR-Suit-EDVA-20170130.pdf
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