Supremacy Case

Exhibit F

Exhibit F

Declaration of Plaintiff Youras Ziankovich

in Support of Complaint

I, Youras Ziankovich, pursuant to 28 U.S.C. § 1746, declare as follows:

  1. I am the Plaintiff in this action. I am an attorney licensed in the State of New York since 2014 (Attorney Registration No. 5196329) and currently reside in Montgomery, Texas.

  2. I have never been licensed to practice law in the State of Colorado.

  3. From 2015 to 2018, I engaged exclusively in federally authorized immigration representation pursuant to 8 C.F.R. § 1292.1(a)(1), without invoking or relying upon any Colorado state licensure.

  4. In 2018 and again in 2020, the Colorado disciplinary authorities imposed suspensions upon me despite my nonlicensure and transmitted their orders to federal agencies including EOIR and USCIS. These transmissions triggered reciprocal discipline at the federal level.

  5. In February and November 2019, EOIR imposed immediate and final suspension based solely on the Colorado orders. No independent fact-finding, jurisdictional hearing, or due process opportunity was provided.

  6. The State of New York later imposed reciprocal sanctions without independent review, thereby compounding the harm caused by Colorado’s extraterritorial action.

  7. As a result of these events, I remain indefinitely excluded from federal immigration practice. I am unable to represent clients before EOIR, BIA, or USCIS, and I cannot seek reinstatement due to EOIR’s categorical ineligibility policy for attorneys suspended anywhere in the United States.

  8. Colorado requires a petition for reinstatement for any suspension longer than one year. However, I was never licensed in Colorado and therefore cannot apply for reinstatement. The only available path is a discretionary ruling from the same Presiding Disciplinary Judge, who previously served in the Office of Attorney Regulation Counsel and personally initiated and transmitted the disciplinary process—a structurally impossible route, rendering the ban effectively permanent and unreviewable through any available state or federal procedure.

  9. This situation has resulted in profound reputational harm, financial losses, professional disqualification, and a chilling effect on future lawful practice. It also continues to damage my ability to serve immigrant communities who seek competent legal representation.

  10. On February 21, 2025, while I was being wrongfully detained abroad, my family received an official letter from the Office of the Special Presidential Envoy for Hostage Affairs (SPEHA) within the United States Department of State, confirming that I had been designated a “wrongfully detained U.S. national” pursuant to the Robert Levinson Hostage Recovery and Hostage-Taking Accountability Act. I did not receive the letter personally due to the conditions of my detention, but I have reviewed it since my release. A true and correct copy is attached hereto.

  11. The events described in this lawsuit—including the unjust and extraterritorial sanctions imposed upon me and the resulting disqualification from federal practice—directly contributed to my professional vulnerability, weakened my institutional credibility as a legal advocate, and deprived me of protections that would have otherwise been available through my role and status.

  12. These injuries are ongoing. No tribunal has reviewed the constitutionality of Colorado’s jurisdiction over my federal practice, nor has any federal authority reconsidered EOIR’s reliance on void and extrajurisdictional state action. My professional disability continues daily.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on July 31, 2025.

Youras Ziankovich

United States Department of State

Washington, D.C. 20520

February 21, 2025

To Whom It May Concern:

This letter serves to summarize facts known by or reported to the U.S. Department of State in Washington, D.C. concerning the Belarusian government’s wrongful detention of U.S. citizen Youras Ziankovich.

Pursuant to the Robert Levinson Hostage Recovery and Hostage-Taking Accountability Act, Section 302(c) of the Consolidated Appropriations Act, 2021, Public Law 116-260, the U.S. Department of State has determined that the government of Belarus has wrongfully detained U.S. citizen Youras Ziankovich. He was arrested on April 11, 2021, in Russia before being transferred to Belarus. He is currently held in Mogilev Prison, Belarus. Since his arrest, Mr. Ziankovich has been unable to travel, freely communicate, or complete documentation necessary to manage his personal affairs. The U.S. Department of State has been engaged on Mr. Ziankovich’s case throughout and remains committed to assuring his welfare and securing his release.

If you have any questions, please contact Robert Crotty in the U.S. Department of State’s Office of the Special Presidential Envoy for Hostage Affairs at 202-485-2130 or by email at CrottyRJ@state.gov.

Sincerely,

Dustin Stewart
Acting Special Presidential Envoy for Hostage Affairs

UNCLASSIFIED