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DECLARATION OF TETYANA DORSANEO

 JODY L. WINTER, ESQ.

SBN: CA 249592 (active)

JENNIFER J. PANICKER, ESQ.

SBN: CA 258656 (active)

LLOYDWINTER, P.C.

1724 Broadway Street, Suite #6

Fresno, CA 93721

559-233-3636

559-385-2000 (fax)

jwinter@lloydwinterlaw.com

Attorneys for plaintiff Tetyana Dorsaneo

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT CALIFORNIA

TETYANA DORSANEO,

Plaintiff, 

v. 

EDWARD MATTHEW 

DORSANEO, an individual,

Defendant.

CASE NO. 4:17-cv-00765-VC

DECLARATION OF TETYANA

DORSANEO IN SUPPORT OF 

PLAINTIFF’S OPPOSITION TO 

DEFENDANT’S MOTION FOR LEAVE 

TO AMEND HIS ANSWER

Date: July 20, 2017

Time: 10:00 a.m.

Dept: Courtroom 4 / 17th Floor

Judge: Hon. Vince Chhabria

I, TETYANA DORSANEO, declare:

1. I am the plaintiff in this action.

2. I became a conditional lawful permanent resident (LPR) of the United

States on February 5, 2014.

3. Prior to the expiration of my status as a conditional LPR, I filed a Form I751, Petition to Remove Conditions on Residency with U.S. Citizenship

and Immigration Services (USCIS). USCIS issued a receipt notice to me

dated February 1, 2016. A true and correct copy of the receipt notice is

subjoined hereto as Exhibit 1.

4. I prepared my first Form I-751 petition pro se without the assistance of

counsel.

5. As the basis for why my first Form I-751 petition was filed without the
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DECLARATION OF TETYANA DORSANEO

assistance of my husband I selected “extreme hardship” from the options 

listed on the petition. 

6. I later received a Request for Additional Evidence (RFE) from USCIS via a 

notice dated January 12, 2017. A true and correct copy of the receipt notice 

is subjoined hereto as Exhibit 2.

7. After receiving the RFE I contacted a nonprofit legal service organization. 

A lawyer at that organization assisted me in drafting a second Form I-751 

Petition. Based on the attorney’s legal advice, the second Form I-751 

Petition listed abuse by my U.S. citizen spouse as a basis for why I was 

filing without his assistance. 

8. I filed the second Form I-751 Petition with USCIS and received a receipt 

notice dated April 7, 2017. A true and correct copy of my receipt notice 

from USCIS is subjoined hereto as Exhibit 3. The receipt notice states that 

my status as an LPR has been extended for a period of one year from the 

date of the receipt notice (i.e., April 7, 2018). 

9. On June 19, 2017 I attended the second of two biometrics appointments 

that have been assigned to me in connection with the Form I-751 petition. 

A true and correct copy of my biometrics appointment notice, dated June 2, 

2017 is subjoined hereto as Exhibit 4. 

10.My second Form I-751 petition remains pending with USCIS. 

[The remainder of this page is intentionally left blank]
I I declare, under penalty of 

p

erjury under the laws of California, that the foregoing 

2 is true and correct. 3 Dated: (){ /.t).. , 2017 ' 4 

5 6 7 8 9 

10 

11 12 13 14 15 

16 17 18 19 

20 21 

22 23 
1-797, Notice of Action

I-751 RECEIPT NOTICE

Receipt Number : EAC-16-126-00010

Ref7

rence Number: A205555182 Petitioner: DORSANEO 

T. DORSANEO

205 GALLAGHER CT 2ND FL APT

SCRANTON , PA 18505 

Receipt Date: 02/01/2016 

Receipt Time: 08:33 

, TETYANA P. 

**** THE ABOVE RECEIPT NUMBER MUST ACCO�PANY ALL INQUIRIES **** 

Amount Received: ' . ."'.,$590. 00 

Your conditional resident status is extended for a period of one year. During 

the on7-year extension you are authorized employment and travel. (This 

extension and authorization for employmen� and travel does not apply to you if 

your conditional resident status has been fermi?

ated.) 

In order to further process your petitio�, 'you will be receiving an Application 

Support Center(ASC) appointment notice wit"h a specific time, date, and location 

to capture your fingerprints, photo, and signature. You MUST wait for your 

appointment notice before going to the A.SC for biometric processing. 

NOTE: Conditional resident applicants, inclu;l.ing conditional resident 

dependents residing overseas pursuant to military or government orders WILL NOT 

RECEIVE an A.SC appointment notice. To complete biometric processing, these 

applicants must submit the required items listed on the I-751 form 

instructions. 

If you have not already done so, provide supporting documents to assist users

in processing your petition and to establish eligibility to remove the 

conditional basis of your permanent residence. PLEASE INCLUDE A COPY OF THIS 

RECEIPT NOTICE WITH ANY SUPPORTING DOCUMENTS YOU SUBMIT. 

Upon receipt of your A.SC appointment notice, you can find the status of your 

case on-line at www.uscis.gov. To view the status of your case, enter the 

uppl�=ation �u..�.bcr fo�r.d �t the top of the �SC �p�ci�tmer-t �otice. �OTE: T�e 

I-751 form type will be listed as "CRI89" under the application type in our

case status on-line tool.

NOTE: If you checked box "E" or "F" under Part 2 - Basis for Petition, you 

may NOT file a change of address request through the users web site or by 

calling the National Customer Service Center. If you or your parent were 

subjected to battery or extreme cruelty, contact the appropriate users Service 

Center where you originally filed your Form I-751 for specific address change 

instructions. 

VERMONT SERV CENTER 

75 LOWER WELDEN ST 

ST ALBANS , VT 05479-0001 

(800) 375-5283

PAGE l OF l 

Form I- 797 (Rev. 01/31/05) N 
U.S. �putmcnt ofHomeluid Security 

U.S. Citizenship and Immigration Services 

Applicant/Petitioner A# I Application/Petition

A20SSSS 182 Petition To Remove Conditions On Residence (form I-7 S 1) 

Notice Date !

Response due by 

January 12, 2017 April 9, 2017 

Notice of Action 

Page I of 4 

TETYANA PAVLYUCHYK DORSANEO 

TETYANA DORSANEO 

20S GAUAGHER CT 2ND FL APT 

SCRANTON PA 18S0S I 1111111 1111 1111111111 1111111111 IIIII IIIII IIIII IIIII IIII IIII 

*A20555S182* 

Applicant/Petitioner 

DORSANEO,TETYANAPAVLYUCHYK 

Bcnefiaary 

Receipt Number 

EAC16084S2341 (CRI89) 

IMPORT ANT: THIS NOTICE CONTAINS YOUJ!. UNIQUE NUMBER. THE ORIGINAL NOTICE MUST BE SUBMITTED WITH THE 

REQUESTED liVIDENCE. 

You arc receiving this notice because U.S. Citizenship ar1d Immigration Services (USOS) requires •ddition.J evidence to process your form. Please 

provide the evidence listed on the attached pagc(s). Include duplicate copies if you arc requesting consular notification. 

Your rcspoDK must be received in this office by April 9, 2017 

Please note that you have been allotted the maximum period .Jlowed for responding to • Request For Evidence (RFE). The time period for 

responding c.umot be extended. 8 CFR 103.2(h)(8)(iv). Because many immigration benefits arc time sensitive. you are cncour•gcd to respond 

to this request as early as possible. but no later than the deadline provided above. If you do not respond to this notice within the allotted time. 

your a.sc may be denied. The rcgula.tions do not provide for an extension of time to submit the requested evidence. 

You must submit .JI requested evidence at the same time. If you submit only some of the requested evidence. USCIS will consider your response • 

request for • decision on the record. 8 CFR 103.2(h)(11). 

If you submit a document in any language other than English. the document must be accompanied by a full and � English tnnslation. The 

a-artslator must certify that the a-artslation is accurate and he or she is competent to tnnslatc from that language to English. If you submit • foreign 

language a-anslation in response to this request for evidence, you must .Jso include• copy of the foreign language document. 

Proces;l..g of your fcrr.1 or benefit request will rc,umc upon receipt of i·cur respomc. If ycu h,•:c not head from USClS ,•.1thin 60 cbys of 

responding, you may contact the USCIS Nation.J Customer Service Center (NCSC) at 1-800-37S-S283. If you arc hearing impaired. please call 

the NCSC mo at 1-800-767-1833. 

Mail this notice •nd your response to: 

Fonn 1-797 (8/03/90) Y 

U.S. CITIZENSHIP AND IMMIGRATION SERVICES 

VERMONT SERVICE CENTER 

7S LOWER WELDEN STREET 

ST. ALBANS, VT 0S479-000 I 

FOil OFFICE USE ONLY 



l�t..·

.

pu�

lmcut of llomclnrtll Sccuritv t -�- t ,Hi:u.·u�hip null lonnil,,!n1tio11 s��·icc� 1-797, Notice of Action

I-751 RECEIPT NOTICE

Receipt Number · EAC-17-213-00143 Ref7r7nce Number; A205555182 Petitioner: DORSANEO 

Receipt Date: 04/07/2017 

Receipt Time: 16:15 

K. KENNEDY 

BARBARA J HART JUSTICE CENTER

608 JEFFERSON AVE

SCRANTON , PA 18510 

, TETYANA P. 

**** THE ABOVE RECEIPT NUMBER MUST ACCpMPANY ALL INQUIRIES   

Amount Received: .** *FEE �IVED*** 

Yoi...r -o-·" t · , · · d A .z '"' 

� ...... ior:.a. :::-es:..dent stat·.is is ext;;n eu ... o ... .:. p:::.:io • d f o or,e: ye:ar. During the on7-year extension you are authorized employment and travel. (This 

extension

_

aJ?-d authorization for employment and

.

travel does not apply to you if

your conditional resident status has been terminated.) 

In order to further process your petition, you will be receiving an Application 

Support Center(ASC) appointment notice with a specific time, date, and location 

to c�pture your fingerprints, photo, and signature. You MUST wait for your 

appointment notice before going to the AS� for biometric processing. 

NOTE: Conditional resident applicants, including conditional resident 

dependents residing overseas pursuant to military or government orders WILL NOT 

RECEIVE an ASC appointment notice. To complete biometric processing, these 

applicants must submit the required items listed on the I-751 form 

instructions. 

If you have not already done so, provide supporting documents to assist users

in processing your petition and to establish eligibility to remove the 

conditional basis of your permanent residence. PLEASE INCLUDE A COPY OF THIS 

RECEIPT NOTICE WITH ANY SUPPORTING DOCUMENTS YOU SUBMIT. 

Upon receipt of your ASC appointment notice, you can find the status of your 

case on-line at www.uscis.gov. To view the status of your case, enter the 

application number found at the top of the ASC appointment notice. NOTE: The 

I-751 form type will be listed as "CRI89" under the application type in our 

case status on-line tool. 

NOTE: If you checked box "E" or "F" under Part 2 - Basis for Petition, you 

may NOT file a change of address request through the users web site or by 

calling the National Customer Service Center. If you or your parent were 

subjected to battery or extreme cruelty, contact the appropriate users Service 

Center where you originally filed your Form I-751 for specific address change 

instructions. 

VERMONT SERV CENTER 

75 LOWER WELDEN ST 

ST ALBANS , VT 05479-0001 

(800) 375-5283

PAGE 1 OF 1 

Form I-797 {Rev. 01/31/05) N 
g r Homeland Securily 

- J and Immigration Services

Form 1-797C, Notice of Action 

.)l"ICE DOES NOT GRANT ANY IMMIGRATION STATUS OR BENEFIT. 

�SC Appointment Notice - APPLICANT COPY At'rLH'A I ION/11

t:'I 11 ION/tU:Vl t-..S I l'WMUl-.M MJll<l-:IMl"I·. 

EACl72nOOl4J . 1:ACl7172517�7 06102/2017 

t·,.;t· IYl'f SOC IAI.Sl-:CIIKI I\' Nllri.UU·,R lSl"ISA# ('(HJI. ·

m1 . CIHM9 A205 �55 182 1 

,n·cw:r--1 ,,,uuw l'H'k Sl-�N\'U-t n., n-.M l'i\C:E 

I vsc 1 or I 

TETY ANA PA YL YUCHYK DORSANEO I 11111 c/o BARBARA J HART JUSTICE CENTER

608 JEFFERSON A VE 

SCRANTON PA 18510 

To process )Our aprlication. pc1i1ion. or request. Lhc U.S. Ci1izcnship & lmniigr.ition Service, (USCIS) 111u,1 capture your bionk!lrics. 

PLEASE APPEAR AT THE BELOW APPLICATION SUPPORT CENTER (ASO Al' THE UATE ANI> l'lME SPECIF\EI>. 

IF YOU FAn.. TO APPEAR AS SOIEDULED, YOIJR APPLICATION, l'ETITION, OR REQUEST WILL Bt; CONSlllEREI> ABANDONED. 

APPLICATION SUPPORT CENTER PLEASE REAi) THIS ENTIRE NOTICE CAREFULLY. 

USCIS PHILADELPHIA DA n; AND TIME OF APPOINTMENT 

I 0�00 Drummond Road Suite I 00 ()6,'19/2017 

Philadelphia PA 19154 IO:OOAM 

WHEN YOU GO TO THE APPUCATION SUPPORT CENTER TO HAVE YOUR BIOMETRICS TA""EN, YOU MUST BRING: 

I. THJS APPOINTMENT NOTICE: and 

2. PHOTO IDENTIFICATION. Na1urali1.ation ;ipplicant!,, mulit bring their Alien Hc�idcnt Card. All other applu:antc;; must bring a pa.-.�pon, dri,cr', 

license. national ID. military ID, or State-issued photo ID. Ir you appear without proper idcntifu:atiun. you will not tX! fingerprinted. 

CELL PHONES, CAMERAS, OR OTHER RECORl)(NG DEVICES ARE NOT PERMITTED. 

NOTE: When you appear :11 the USCIS Application Support Center. you will reaffirm. under penalty of perjury

. thal you rc\'icwcd and undcr:i,tood �our 

application. petition. or l'l..-qucst and all supporting documents. Lhat 1hc answers were provided by you. and that the l'ontcn1s of )Our application. petition. 

or rcquc.-sl arc. complc1c. true. and correct If you were a�sistcd in completing your application. petition. or TL'<IUCSI. you will be rcaffim1ing tha1 Lhc person 

assistini you aho re,,1cwcd the Acknowledgt>ment or Appointment at USCIS Applicaliun Support Center with you. 

NOTE: USCIS will Ulric your fingerprints. 10 check the criminal history records or 1hc FBI. You nmy obtain r, copy or your own FBI idcnufication record 

using the procedures outlini.:d within Title 28 C.F.R., Section 16.32. The procedures 10 change. com:ct. or up<lalc your FBI 1dcn11fication rl·conl arc oullim.·d 

within Tule 28. C.F R .. Scc11on 16.34. 

NOTE: If 1hc USCIS ASC is dosed due to inclement weather or for other unforeseen circum.;;1anccs. USCIS will uutomulicyllu-.-sffit-dule your 

appointmcnl for the nc,t avail;:1blc appointment dale and mail you a nolil'C w11h the new date and time 

REQUEST FOR RESCHEDULING 

0 Please reschedule my appoinlmenl. Once �fiif���'t:!\\:.11'/-l):l!��i� appointment notice. Make a copy ol '.h" nu11cc for 

your records. rhen marl rlrc ongonal w11h your n:Ac,1 ro BPu. Alex 1111 • . •··- Mfil Hwy, Akx;ondna, VA 22)09-1)�6 

��� �-'::� cc�ir: . I l\ \Jff 

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·v 1.../h��vl�J 0JiJN 19 2017

TENPAINi QA f lEVIEW 9" j'n°

ZJ) ON UN 19 2017 

APl'Ll(.'A 1'10'11'1'\HIEM \Pl'l.lC.\'flO\' 'II \lHFIC l 

17SI · EACl72110014J CKIK9- EAC-17172�1757 

11�1111�1;�11111 1�11111�11��1111 

If you hu,•c uny <1uc.,tion.� rct.tardinR thl"i: nofo.·c, pl-.•ust cull 1-HOO-J7S-52HJ. 

WARNING: D11r to /inured 'it'tlfi,i,: mwlalnl,tv ,n our lohh,· ureu, mil\' pen1111f uho arr 11r1 l'\{ttrr to t1,w:1 u·ith mm:'J"''''"tum or c omplt'IIIIJ,: tlu· hwmemn 

ll'ork,lu•rt should Ut I tllllf'WIY }'(1", /j you'""'" O('l!

II ,w1111d, or IJ4md,,.i:,,,kmh ll'hl'IJ \'1111 ll/>/>t'IIT, the IISCIS ""'Y r('ff '"'""'" \'tll/f tl/1/>hlllllnl''" ,r ,, ,,

dnermmed ymu· m111ri«·, wi/1,merfrre uitl, 1aki11,: your lnomrtr,n 

If this ls an lnttrvlew or hiomelrics 1i1ppnlntmcnt nollcr. pleast' see the h11ck or this notice for Important tnformarton. Form 1-797C 07111/14 Y