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UNITED STATES DISTRICT COURT
FOR T H E SOUTHERN DISTRICT OF FLORIDA
WEST PALM B E A C H DIVISION
No.: 9:10-cv-80771-KLR

Roy Magnifico, Roma Lim, Rezza Real,
Jeanette Halup, Bonifacio Ramos,
Lucille Liwag, Ross Ripotola, Raul
Rueda, Aries Caluya, Aris Ordonez,
Ritche Relampagos, Percival De Quiros
Jose Auingan, Denlit Fausto, Cesar
Ramos, Irene David, Arnold Laxamana, and
Robert Bautista,
Plaintiffs,

V.

Roberto Villanueva, Redelina Fernandez,
Star One Staffing, Inc., Star One Staffing
International, Mary Jane Hague, John
Carruthers, and Ruth Carruthers,
Defendants.

Declaration of Plaintiff Jose Auingan
COMES N O W Jose Auingan who declares under penalties of perjury and states as follows:
1. M y name is Jose Auingan. I am one of the Plaintiffs in this case.
2. I was recruited to work for Star One Staffing by Bobby Villanueva.
3. 1 had been working at a hotel restaurant in Manila for over 10 years. Because I needed to
earn more money to support my wife and children, I became interested in employment
opportunities abroad.

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4. I met Bobby Villanueva in 2006 in Manila. He told me that I should apply at JES
Manpower to work for Star One in the U.S. Based on the promises he made, I decided to
pursue a job with Star One and to give up my current position at the hotel.
5. In October or November of 2006, Bobby came to the Philippines with his wife, Lina, and
Mary Jane Hague and John Carruthers. They were introduced to us as the bosses and
owners of Star One. Bobby and Lina interviewed us and told us what kind of employees
they wanted. They did not want employees who were messy, did not like to help or
women who were pregnant.
6. I spent about $2,350.00 in expenses to come from the Philippines to the U.S. to work for
Star One. 1 was required to pay a fee of about $2,000.00 to the recruitment agency, $100
for my visa application, $100 to an attorney, about $97.00 for a medical exam, and about
$53.00 to the Philippine Overseas Employment Administration.
7. I did not have enough money to pay for all the fees, so 1 signed over the title to my land
and house and my severance pay to JES. I have never gotten the title of my land and
house is still with the JES.
8. When 1 arrived in the U.S. in November 2006,1 was picked up by Lina and taken to a
residence of Star One. About forty people shared this residence. Some of the bedrooms
were actually other parts of the house that were made into bedrooms, like a curtained off
room. Bobby and Lina also lived in the house.
9. Some of us did not have work right away and others did not have work for a month or
more. When I got paid for the first time, I saw that over $400 was deducted from my pay
and I was not paid at the proper rates.
10. Bobby told Lina how many people were needed in each place and Lina assigned us to our
work. Bobby would sometimes come to check on us at work. I had to work for very long
hours and was always tired, dizzy and stressed. I also became sicker during this time,
usually having fevers or colds. I felt 1 had no choice but to work as many hours as I
could, healthy or sick, tired or rested.
11. One of my co-workers escaped from the house and Lina called someone from the police
department. We were told that our co-worker would be easy to find because they had her
social security number. This experience terrified me and made me never want to leave
Star One. When other workers escaped, Lina told us that they thought they had escaped
for good, but Star One had their social security numbers and it would be easy to track
them down.

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12. Bobby always made threats to us. He told us that we would be taken to jail if we escaped
and did not have any papers. He said it would be easy to track us with our social security
numbers.
13. Lina also told us that, if we left the house, it is easy for Star One to track us down
because Star One knew all of our social security numbers. Lina had a connection to a
police officer, and one of the owners of Star One is a judge.
14. Bobby and Lina also kept my original immigration document that was proof that my H 2B visa had been granted.
15. Bobby and Lina said we could never leave because they had our immigration papers and,
if we escaped, then they could have the police find us and have us deported. 1 really felt
like I had to keep working for Star One.
16. Lina was always fighting with other workers when they did not want to work or were
tired. Workers were just not able to say no to working long hours. They would be
punished by providing no work to them at all. Star One would retaliate if a worker did not
want to work by refusing to give them other shifts.
17.1 tried to work every shift they gave me no matter how tired I was because if my shifts
were reduced, then I wouldn't be able to send money home to my family in the
Philippines and they were depending on me.
18. Bobby took some of us to New York, where the living conditions were also really bad. In
one of the houses, we ran out of hot water and the single toilet clogged up a lot.
19. The deductions from our pay also increased to $800 while we were in New York. This
meant I had very little to send home to my family.
20. M y family suffered badly for two months when Star One did not pay me or provide me
with work like they had promised. I had no money to send to my family and it was very
painful for me.
21.1 was afraid for myself and my family while 1 was working for Star One and after I left.
22.1 suffered because of what happened when 1 was at Star One. 1 was constantly depressed
and felt stressed about what would happen to me and my family.

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23.1 had problems sleeping because of what Bobby and Lina did and was under constant
stress while I was working for them.
24.1 feel that my life was ruined by what Bobby and Lina did to me.
25. For about a year after I left Star One, I still felt fear and stress and I had a hard time
sleeping because of what had happened to me. I also felt ashamed by what had happened.
1 D E C L A R E UNDER PENALTIES OF PERJURY T H A T THIS FOREGOING S T A T E M E N T
IS T R U E A N D CORRECT.
Date

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UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
No.:9:10-cv-80771-KLR

Roy Magnifico, Roma Lim, Rezza Real,
Jeanette Halup, Bonifacio Ramos,
Lucille Liwag, Ross Ripotola, Raul
Rueda, Aries Caluya, Aris Ordoriez,
Ritche Relampagos, Percival De Quiros
Jose Auingan, Denlit Fausto, Cesar
Ramos, Irene David, Arnold Laxamana, and
Robert Bautista,
Plainfiffs,

V.

Roberto Villanueva, Redelina Fernandez,
Star One Staffing, Inc., Star One Staffing
International, Mary Jane Hague, John
Carruthers, and Ruth Carruthers,
Defendants.

Declaration of Plaintiff Robert Bautista
COMES NOW Robert Bautista who declares under penalfies of perjury and states as follows:
1. My name is Robert Bautista. 1 am one of the Plaintiffs in this case.
2.

1 was recruited by Bobby Villanueva to work for Star One in the United States.

3. 1 was working as a waiter in a hotel in Saipan for about 13 years when 1 learned about a
man named Bobby Villanueva who was recruiting Filipino workers to work for him in
the U.S. Bobby got my contact information from a co-worker and began contacting me
about working for him.

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4. Bobby interviewed me by phone and offered me a job with Star One. Because of the
promises Bobby made about my pay, the type of work, and benefits offered, I accepted
the position with Star One, left my job, and bought a plane ticket from Saipan to the
Philippines. 1 believed that this job would help me to better support my family.
5. In addition to my plane ticket from Saipan to the Philippines, I was required to pay about
$99.39 for my visa fee, $ 100 for an attorney fee, $100 for a medical exam and $140.24 to
the Philippine Overseas Employment Adminisfration. In total, this was about $439.63 in
expenses to come from the Philippines to the U.S. to work for Star One.
6. 1 arrived in Miami in November 2006. When 1 arrived at the house, 1 was surprised by
how many people were living there. 1 was then moved to a house in Boca Raton, but the
living conditions were also not good there. They had almost thirty people living in the
house and we had just two bathrooms. We slept in bunk beds and sometimes on the floor.
When Bobby later moved us to New York, the house there was even worse and more
crowded.
7. 1 was tired all the time from working so much. 1 was made to be a driver for Star One so
would have to drive people to and from work and wait for them to finish working so 1
could drive them home. 1 did not get paid for the hours I spent driving.
8. People were all scared and tired because Bobby and Lina always threatened us about
cancelling our visas. We were always made to feel like we didn't have a choice as to
whether or when we worked.
9. After workers left Star One, Bobby and Lina were very upset. Bobby told us we were
here to work and we had to follow their rules. Bobby said that, if we tried to leave Star
One, they would send our picttire to the police and get the police to look for us. He also
said we would be escorted to the airport to be deported back to the Philippines.
10. Bobby and Lina did not want any other Star One employees to leave and let us all know
that, if we left, they would call the police and immigration.
11. Bobby and Lina said they could use our social security numbers to find us and that they
would give our photographs to the police so they could find us and deport us.
12. When 1 heard Bobby and Lina's threats, 1 felt like 1 had to work no matter what they paid
me.

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13. If we had our visas revoked, Bobby and Lina said we would not ever be able to work in
the U.S. again and I could not go back to my old job either.
14. Even though Bobby did not pay me what 1 was owed or what he had promised, 1 was too
scared to say anything because of his threats.
15.1 was also scared because Bobby and Lina had connections to the police and because the
owner of Star One, Mary Jane, was married to a judge. During a meeting we had in the
Philippines, they introduced him to us as a Florida judge. Because of these connections,
when Bobby said they would have our visas revoked or deport us and we could never
work in the U.S. again, I believed him. They were very powerful people and we all knew
this.
16. 1 was worried all the time about my wife and children because they were depending on
me. 1 never knew how much pay 1 would get.
17. 1 was afraid of risking being deported like Bobby said because my family would be lose
everything.
18.1 was also scared of what Bobby would do if 1 tried to leave and he called the police and
immigration. It did not seem like I had a choice to do anything other than stay with
Bobby.
19. While 1 was at Star One, 1 felt so much stress.
20. After Star One, 1 was still so worried all the time. 1 had a hard time sleeping and was
nervous a lot. Even when fiiends were just looking for me in my house or wanted to talk,
1 was hiding from them. 1 felt very afraid even once 1 was safe.
21. Sometimes I still worry for my own safety and for my family's safety.

1 D E C L A R E UNDER PENALTIES OF PERJURY T H A T THIS FOREGOING STATEMENT
IS TRUE A N D QORRECT.

m

Date:

Robert Biutista

3

2 2oa

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UNITED STATES DISTRICT COURT
FOR T H E SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
No.: 9:10-cv-80771-KLR

Roy Magnifico, Roma Lim, Rezza Real,
Jeanette Halup, Bonifacio Ramos,
Lucille Liwag, Ross Ripotola, Raul
Rueda, Aries Caluya, Aris Ordonez,
Ritche Relampagos, Percival De Quiros
Jose Auingan, Denlit Fausto, Cesar
Ramos, Irene David, Arnold Laxamana, and
Robert Bautista,
Plaintiffs,

V.

Roberto Villanueva, Redelina Fernandez,
Star One Staffing, Inc., Star One Staffing
International, Mary Jane Hague, John
Carruthers, and Ruth Carruthers,
Defendants.

Declaration of Plaintiff Aries Caiuya
COMES NOW Aries Caluya who declares under penalties of perjury and states as follows:
1. My name is Aries Caluya. I am one of the Plaintiffs in this case.
2. When 1 left my country to come to work in the U.S., I was hoping to help my family from
their financial hardships back home. 1 am ashamed to admit that instead of helping them,
1 became a burden to them.
3. In 2005,1 was hired by the owner of San Villa Ship Management Company, Jose "Jo Jo"
Villanueva, to work as a waiter for Royal Palm Yacht Club in Florida. 1 received a visa
and arrived in Miami on November 24, 2006.

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4

Jo Jo's brother, Roberto "Bobby" Villanueva picked us up at the airport along with his
wife Lina and a driver. When we got into the car, Bobby asked us to give him our
passports and I-94s, which we did.

5

While working for Jo Jo, we were threatened and were not paid properly. I stayed quiet
because I was afiraid for my safety and wanted to be given work because 1 have my
parents to support and debts to pay in the Philippines.

6

We heard that Bobby and Jo Jo had a dispute and that Bobby left Jo Jo's company.
Bobby told us to leave his brother and instead join Bobby's company. Star One. Bobby
knew we were working long hours and not given overtime pay and said things would be
better i f we worked for him.

7

Bobby assured us there was no need to exit the country to transfer to a new company. He
assured us there were jobs available, that he would pay us overtime pay, we would have
better housing accommodations, and that, if we stayed with him, we can get immigrant
visas after three years and bring our famiUes to the U.S.

8

For three weeks, we lived in a house in Miami with Bobby and Lina. Some of us slept in
the living room on chairs and in the kitchen. We were given no work. Bobby told us he
was taking care of everything and showed us a labor department approval to prove our
visas were being processed.

9. When 1 worked for Bobby, like with Jo Jo, 1 was also threatened and was not paid
properly. I continued to be afraid for my safety.
10 Bobby took us to meet Ernesto Ramos who worked for a Florida congressman. Bobby
and his wife Lina were there and Bobby again assured us not to worry about our visas.
11 Bobby and Lina took a group of us to New York to work. When we arrived, we lived in a
hotel for three weeks without work. We cooked our food in the bathroom. When some ot
us became fioisfrated, Bobby threatened to deport us because some of us complained.
12 1 was sent by Bobby to work at Glen Head in New York. 1 was paid very little and slept
on an airbed on the floor of a shared room. We were not paid enough to buy our own
food and relied on Lina's cooking and sometimes took home leftovers from guests ot the
country club.
13. Bobby and Lina always told us that, if we escaped from Star One, they will inform the
border patrol, police enforcers, and the immigration office. Bobby said he had
connections in immigration and labor so we didn't stand any chance against them at all.
He said we had to dance to his music. 1 believed what they said.
14.1 felt afraid while I was working for Bobby and after I escaped.

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15. M y time at Star One was very painful and humiliating. I was forced to keep quiet and
endure what was asked of me.
16.1 felt like I was a dog working for Star One and felt boxed in and trapped. 1 felt like 1 was
not free because of Bobby and Lina's threats.
17.1 lost a lot of weight when 1 was working for Star One. I think I lost about 30 or 40
pounds. We worked very hard, there was not enough food or time to eat, and a lot of
stress.
18. While at Star One, 1 was always tired and scared. It was a terrible time in my life.
19.1 had trusted Bobby and Lina because they were elders trom my country and they showed
us that they were successful. After Star One, 1 was afraid to talk to other people from the
Philippines. I did not want to trust anyone from my country.
20.1 was worried that Bobby might trace me after I left Star One and it was hard for me to
sleep. 1 was very afraid.
1 D E C L A R E UNDER PENALTIES OF PERJURY T H A T THIS FOREGOING S T A T E M E N T
IS TRUE ANt) CORRECT. /
Date:
'Arifes Caluya

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46

UNITED STATES DISTRICT COURT
FOR T H E SOUTHERN DISTRICT OF FLORIDA
WEST P A L M BEACH DIVISION
No.: 9:10-cv-80771-KLR

Roy Magnifico, Roma Lim, Rezza Real,
Jeanette Halup, Bonifacio Ramos,
Lucille Liwag, Ross Ripotola, Raul
Rueda, Aries Caluya, Aris Ordonez,
Ritche Relampagos, Percival De Quiros
Jose Auingan, Denlit Fausto, Cesar
Ramos, Irene David, Amold Laxamana, and
Robert Bautista,
Plaintiffs,

V.

)

)
)
)
)
)
)
)

Roberto Villanueva, Redelina Fernandez,
Star One Staffing, Inc., Star One Staffing
International, Mary Jane Hague, John
Carruthers, and Ruth Carruthers,
Defendants.

)
Declaration of Plaintiff Irene David
COMES N O W Irene David who declares under penalties of perjury and states as follows:
1. M y name is Irene David. I am one of the Plaintiffs in this case.
2. After my son was bom, 1 worried because 1 wasn't earning enough money, so 1 was
trying to find a better job. My husband was unable to find any work. When 1 found out
how much money 1 could make working in the United States I thought it would be the
best solution for my family.
3. 1 worked with JES Manpower Agency in the Philippines to find a job. JES told me about
Bobby Villanueva and Star One. 1 was interviewed by JES and later by Bobby, who said 1
passed the interview.
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4. I spent about $2,450.24 in expenses to come from the PhiUppines to the U.S. to work for
Star One. I was required to pay JES a fee of $2,000, about $100 for my visa application,
$100 for an attorney JES said we had to use, about $110 for a medical exam, and about
7,200 Philippine Pesos to the Philippine Overseas Employment Administration.
5. 1 did not have enough money to pay all of the required fees so I had to get a loan which
was secured by my parent's property. I am still making payments on my loan in the
Philippines.
6. After 1 got my visa and arrived in Miami to work for Star One, Bobby took me and others
to a staff house and introduced us to his wife, Lina.
7. The living conditions in the Miami house were terrible. There were about forty people
living there. About sixteen of us were sleeping in the storage room behind a curtain
because there was not enough room in the other parts of the house. The room had about
eight bunk beds in it. Bobby and Lina had their own bedroom and bathroom in the house
while everyone else had to share the rest of the rooms and just two bathrooms.
8. I would have to wake up around 4:00am to get in line for the bathroom. If 1 wanted a
shower, I would have to give up sleep and get up very early. This usually meant 1 only
slept for two or three hours a day in Miami.
9. After I saw all of the living conditions in the staff house 1 was so disappointed. I never
expected to live in a place like this.
10. Bobby moved some of us to a staff house in Boca Raton where the conditions were also
bad. There were about thirty people in this house. The house had 6 rooms, five used by
staff and one room for Ted Ravelo, Bobby's manager.
11. We were so crowded in the housing that 1 had no privacy in the Star One staff housing
which made it difficult to sleep.
12. There was not enough food in the staff houses to feed everyone and it was not very high
quality. I did not feel I could not complain about the food because I was scared.
13. While I was working for Star One, Bobby had all the work schedules. He knew who
should be where and when the staff could work at other places.
14.1 once became so tired from no sleep and too much work that my supervisor at the
country club let me go home early one day. When Ted found out I was at the staff house
resting, he informed Bobby that I was home early. They made me get up and go to work
at another place and told me I had to work until 11:00 that night. I could not say no
because i f I did, I would not get shifts, my hours would get cut, or I would be threatened.

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15.1 felt I did not have a choice but to keep working whenever they told me to. Even i f I was
tired or sick I felt 1 had no choice but to work.
16.1 received my first paycheck after working for over a month and saw that was different
than what Bobby had promised. There was $433 was deducted for housing, food and
transportation, there was no allowance, and 1 was not paid overtime like he had promised.
When we asked about the deductions, Bobby said that, if he did not take the money from
our pay, the government would take it. He also told me that the money was not mine.
17.1 did not understand the laws in the United States. 1 was also afraid Bobby might cancel
my visa i f 1 asked too many questions.
18. Every time we asked questions about our pay, deductions, and advances, Bobby told us
"take it or leave it," and that, if we left Star One, the police would arrest us.
19. It was easy to believe the threats because Bobby and Lina had a relationship with a police
officer who I met.
20. Bobby would tell us how close he and Lina were to the police and what good fiiends they
were. 1 believed Bobby and Lina could use the police to hurt us because they were
connected to a judge and they had a relationship with a police officer who I had met.
21. When I wasn't paid properly, I was too afraid to ask Bobby for my money back. If I got
deported, 1 would not be able to provide for my family and my parents would lose their
property.
22. During the winter of 2006, some colleagues started escaping in the middle of the night.
After the escapes, Bobby and Lina would call meetings with me and the other Star One
workers.
23. Bobby and Lina told us that they cancelled our escaped colleagues' visas, called the
police, and that the police were going to take them to jail and then deport them to the
Philippines in handcuffs.
24. Lina told us, "I never sleep, guys, 1 am watching you every minute."
25. Bobby said things to us like, "You can't go far away, because 1 have friends in the police
and if I call they'll be looking for you and you'll go to jail."
26. Bobby also told us that, i f we tried to leave, we would be arrested, taken to the airport,
deported immediately and would not be able to come back to the United States.
27.1 believed Bobby when he said the same thing would happen i f I left Star One. I was so
worried all the time that 1 would be put in jail and then deported. I couldn't work i f I had
a criminal record and my visa was cancelled and never be allowed to come back. I would

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46

be a criminal, and I would lose everything. I was so afraid of what would happen to me
that I felt I had to stay and work for Star One.
28. It was hard to sleep, and I worried about doing my work and following the rules.
Because of the way I was treated, all I wanted was to stop working for Star One.
29. We did not know the rules of regulations in the United States and so we were scared and
followed whatever Bobby and Lina said, even though it was against our wills.
30. In April 2007, Bobby told me that I had to go to New York and work. I felt trapped and
feh I had to accept whatever Bobby told me to do.
31. When Bobby kept my original 1-94, it made me more afraid of what would happen to me.
32. Once we were in New York, the deductions from our pay increased to about $800 a
month so Star One was paying me even less.
33. When the season started to get slow in New York, I worked as many hours as I could but
would not make enough to cover the deductions from my paycheck. When this
happened, Bobby would give us a mandatory cash advance. Bobby would then take the
cash advance out of the next paycheck. I did not want Bobby not to do this. I did not
want to owe him any money.
34. In mid-2007, when another worker escaped, Bobby called another meeting. He was very
mad. Bobby said that he cancelled his visa and called the police. He told us that he was
keeping his salary and had his 1-94.
35. In November 2007, there was no heat in our New York staff house and no hot water. We
had to boil water for our showers. There was not any food at the house. Star One was
still deducting about $800 a month from my paychecks for housing, food and
transportation even though they were not providing those things. It was really bad.
36. During the time I was working for Star One, I felt a lot of stress and fear.
37.1 got headaches all the time while 1 was working for Star One. It was a burden to know I
could not do anything without Bobby and Lina's permission. I could not decide for
myself and that was very hard for me.
38. As a result of what happened at Star One, 1 felt worried all the time - even after I was no
longer working for them.
39. After I escaped, I was afraid that Bobby would find me. I was afraid of Bobby for a long
time because he has power to harm me and my family. He has connections with the
police and a judge. I have had nightmares about Bobby.

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40.1 did not want to talk to other people after 1 left Star One because I was afraid of what
Bobby. I was worried because I didn't know what he might want to do to me. 1 am still
afraid that he could do me or my family physical harm.
41. M y ability to trust people was hurt by what happened with Star One. For several years
after what happened, I was living in paranoia. Even now, it is very hard for me to trust
people after what Bobby and Lina did to us.
I D E C L A R E U N D E R PENALTIES OF PERJURY THAT THIS FOREGOING S T A T E M E N T
IS TRUE A N D CORRECT.

5

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UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
WEST P A L M BEACH DIVISION
No.:9:10-cv-80771-KLR

Roy Magnifico, Roma Lim, Rezza Real,
Jeanette Halup, Bonifacio Ramos,
Lucille Liwag, Ross Ripotola, Raul
Rueda, Aries Caluya, Aris Ordonez,
Ritche Relampagos, Percival De Quiros
Jose Auingan, Denlit Fausto, Cesar
Ramos, Irene David, Amold Laxamana, and
Robert Bautista,
Plaintiffs,

V.

Roberto Villanueva, Redelina Fernandez,
Star One Staffing, Inc., Star One Staffing
Intemational, Mary Jane Hague, John
Carmthers, and Ruth Carmthers,
Defendants.

Declaration of Plaintiff Percival De Quires
COMES N O W Percival De Quiros who declares under penalties of perjury and states as follows:

1. M y name is Percival De Quiros. I am one of the Plaintiffs in this case.
2. 1 was recruited in the Philippines to work for Star One in the U.S.
3. In the Philippines, there are agencies that place people with overseas jobs. Some are
illegal and I avoided them. Some are legal and people can find the legal ones by going to
the Philippine Overseas Employment Administration office. They are a govemment

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office and have a Hst of the legal agencies. JES Manpower was one of the legal agencies
that I contacted around April 2006.
4. I was working as a team leader at a food establishment at that time.
5. I had interviews in the Philippines with Bobby Villanueva from Star One Staffing before
I was hired. He asked questions like, "If I hire you, what can you do for the company?" I
told him I would do my best and work hard. Bobby also knew that 1 had a job at the time.
After Bobby's questions, he told me that 1 passed the interview.
6. I had to spend about $3,040.00 to come from the Philippines to the U.S. to work for Star
One. I was required to pay a placement fee of about $2,500.00, $100 for my visa
application, $140 to an attorney, $100 for a medical exam and $200 to the Philippine
Overseas Employment Administration.
7. I did not have money to pay for all the fees so I had to borrow money from my aunties,
my uncle, a friend of mine, and my sister. M y sister was working at a bank and she was
able to take out a loan for me. It took me a long time to pay off all of money to my
relatives and to the bank and to the bank I also had to pay the interest.
8. Before we came to the U.S., Bobby Villanueva made many promises to us. Free food and
accommodation was just part of what he promised. I also believed what Bobby told us
about wages. The houriy rate was to be $6.78 and exceeding 8 hours in a day would be
overtime. 1 later learned that what Bobby told us in the Philippines was not true. But
when 1 realized that, it seemed to be too late to do anything because I was already in the
U.S. and it didn't seem to be possible to leave Bobby.
9. When 1 first arrived in Miami, Bobby and Lina brought us to the accommodation where
they also lived. At that time, 1 was happy that I came to the United States to work. I
didn't know 1 would be spending many months moving from one crowded house to
another, working for Bobby and Lina without proper wages. I also didn't know that I
would be in constant fear of being put in jail or sent back to the Philippines i f I were to
leave Star One.
10. The house we lived in Miami was very crowded. In my room, there were three double
deck beds so sometimes there were six people sleeping in that room. There were only two
bathrooms for us and we always waited in line to use them. Sometimes we needed one to
one and a half hour adjustment to our schedule just to use the bathroom.

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11. When I was later moved to Boca Raton, it was so crowded that they put a double deck
bed in the corridor upstairs and I was assigned to occupy one of those beds. I couldn't
sleep well in the corridor as there was always movement as people went to work and
arrived from work.
12. When I first came to Miami, I did not have a job for a few weeks and became anxious
because Bobby told us that the job would be waiting for us when we arrived. I had
calculated how much money I would make by the end of the month and how much I
would send home. But I was jobless and could not start paying off my debt. In the
following weeks, I was assigned just part time work in different places.
13.1 felt like I had been lied to by Bobby, but also felt like I should not complain because
Bobby was the boss and he controlled where we worked and when we worked.
14.1 did not have any money because I was only working a little bit. Bobby said he would
give us a cash advance. I knew it was going to be deducted from my paycheck once I
started earning wages. In addition to the money I owed in the Philippines, now I owed
money to Bobby.
15.1 was already afraid of Bobby and Lina because they controlled our work. They knew we
had a lot of debt and made us believe we would be sent back to the Philippines if we did
not follow their orders.
16. Bobby and Lina started to threaten us very seriously after a worker left Star One Staffing
in the middle of the night. On that morning, Bobby and Lina told us one of our colleagues
left. They were in a hysterical mood and threatened us. Lina said that, if we did left like
that, our name and face would be all over T V and the newspapers. Bobby said we would
be caught immediately because he had many coimections in Miami. He also said we
would be put in jail and deported to the Philippines. Lina was shouting at us saying i f we
would do that we would be "Wanted" and would be caught right away.
17.1 believed that Bobby and Lina were trying to find our colleague who escaped and were
trying to deport her. I became afraid of them even more because they said that would
happen to us too i f we left Star One. It was a very serious thing. I was never in jail and
the thought of it scared me.
18. Even though I tried not to think about it, 1 felt afraid that I would be arrested and put in
jail or deported i f I tried to stop working for Bobby. They knew my name and had a copy
of my passport so I thought they could find me easily. I also believed Bobby had a lot of
powerful coimections and that he could do exactly what he threatened to do.

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19.1 knew Bobby had many connections because I met some of them. When we first came to
Miami, Bobby introduced us to a Filipino police officer. Bobby also knew a judge. I
believed Bobby had the power to have us arrested and deported.
20. After our colleague escaped, Bobby and Lina continued making threats to us all the time.
They said things like that we would be arrested, put in jail, and deported to the
Philippines. I believed them because I did not know the law in the United States.
21. Lina also made us afraid to leave Star One. She told us not to speak to other Filipinos.
She was also verbally abusive and scary. She talked to us like she was the commander in
the military. She would yell and curse a lot. She also controlled the food we ate and made
us feel ashamed i f she caught us taking food without permission. Lina yelled and made us
feel embarrassed if we didn't do exactly what she told us to do.
22. Even thought we were pressured to work as Bobby scheduled, Bobby did not pay us
proper wages. First, he deducted money from our paychecks for housing, meals and
transportation. We were surprised by these deductions and we often felt like we were
working just to cover the deductions.
23. They told us we had to do extra work duty even if we needed rest. 1 could not refiise
because 1 was afraid of deportation. They knew we incurred much debt to come to the
U.S. and we needed to keep working to pay. It was a threat to us.
24.1 continued to feel like I would be arrested and put in jail i f I stopped working for Bobby.
He would say things like, "If you want to leave you can, but you will be caught
eventually." He also ordered that we tell him if we had any idea about someone helping
others to escape.
25. When he moved us to New York, Bobby continued to threaten us by saying some of us
would not have our visas renewed. He also reminded us that we would be caught by the
police if we left Star One. At the group meetings he held with Star One employees in
New York, Bobby also informed us he would now be taking even more money from us
and that our deduction would be over $800.
26. When I was there, I had a hard time focusing because I was thinking of my situation and
my family in the Philippines and what would happen to me. There were so many things
in my mind and I did not know what to do. I did not have peace of mind.

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27.1 had difficulty sleeping at night for a long time after 1 escaped from Star One. I would
think too much about what has happened and what would happen to me next.
28.1 was depressed and felt a lot of stress as a result of what Bobby and Lina did.
1 D E C L A R E U N D E R PENALTIES OF PERJURY THAT THIS FOREGOING STATEMENT
IS T R U E A N D C O R R E C T ^

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UNITED STATES DISTRICT COURT
FOR T H E SOUTHERN DISTRICT OF FLORIDA
WEST PALM B E A C H DIVISION
No.: 9:10-cv-80771-KLR

Roy Magnifico, Roma Lim, Rezza Real,
Jeanette Halup, Bonifacio Ramos,
Lucille Liwag, Ross Ripotola, Raul
Rueda, Aries Caluya, Aris Ordonez,
Ritche Relampagos, Percival De Quiros
Jose Auingan, Denlit Fausto, Cesar
Ramos, Irene David, Amold Laxamana, and
Robert Bautista,
Plaintiffs,

V.

Roberto Villanueva, Redelina Fernandez,
Star One Staffing, Inc., Star One Staffing
Intemational, Mary Jane Hague, John
Carmthers, and Ruth Carmthers,
Defendants.

Declaration of Plaintiff Denlit Fausto
COMES N O W Denlit Fausto who declares under penalties of perjury and states as follows:
1. M y name is Denlit Fausto. I am one of the Plaintiffs in this case.
2. Through the recmiting agency JES Manpower in Manila, Philippines, I was introduced to
Bobby Villanueva during 2006. He interviewed and hired me. He told me that JES
Manpower Agency would take care of things in the Philippines and the other agency. Star
One, would take care of things in the U.S.
3. During an orientation, Bobby explained what we would do in Florida and that the owner
of Star One was a Judge in the United States. Bobby Villanueva said that we would make
$6.78 per hour. Bobby Villanueva promised that everyone who worked for Star One
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would get transportation to Florida and free housing and food while they worked there.
He also said all the workers would get an allowance.
4. I spent about $2,445.48 in expenses to come from the Philippines to the U.S. to work for
Star One. I was required to pay a fee of about $2,000.00 to the recruitment agency, $100
for my visa application, $100 to an attorney, about 5,000 Philippine Pesos for a medical
exam, 400 Philippine Pesos for required training and 7,200 Philippine Pesos to the
Philippine Overseas Employment Administration.
5. When we arrived in the U.S., Bobby picked us up from the airport and took us to a house
in Miami. The living conditions were horrible. I slept in a small room with four other
people. The room had two bunk beds -plus a mattress on the floor because another bed
would not fit in the room. Lina and Bobby had their own private bedroom and bathroom
in the house.
6. A few days later, Bobby told us that we couldn't leave the house alone. He told us that i f
we left, they would call their friends in the police, who would look for us and arrest us.
He also said we could be deported because he would have his fiiend in immigration
cancel our visas and then we would be in the US illegally.
7. After one of our colleagues escaped, Bobby and Lina told us that they called the poUce
and the police were going to take her to jail because she left without notice or anything.
Bobby said, "1 called immigration and cancelled her visa." He said the police would put
her in jail and then she will be deported. He said the same thing would happen to us if
we left that way. Lina told us she was always watching us and did not sleep and Bobby
said that we could not get far because he had fiiends who were police and they would
look for us.
8. Bobby and Lina told us again that i f we left, they would call the police and have us
arrested and we could be deported. Bobby told us we would be taken to the airport,
deported immediately and would not be able to come back to the United States. I was so
worried all the time that I would be put in jail and then deported. 1 believed Bobby when
he said the same thing would happen i f I left. I couldn't work i f I had a criminal record
and my visa was cancelled
9. When my colleagues got their first pay, there was $433 deducted for housing, food and
transportation. The other workers asked Bobby why he took money for those things,
because he said they were free. Bobby said that those things weren't free in America.
Bobby said that either he took that money or the United States govemment would take
the money.
10. When I was upset about the deductions from my pay, Bobby told me that I had a contract
with Star One and that i f I tried to leave I would not be able to find a job because the
owner of Star One was a judge. I was scared because I did not know anyone else in the
United States. If I left Star One I had nowhere to go and did not know anyone who could
help me. Bobby kept telling me that Star One was ran by powerful people and i f I left.
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they would find me. Every time we asked questions about our pay slips and the
deductions and advances, Bobby told us "take it or leave it," and that i f we left the police
would arrest us.
11. While I was in Miami, Bobby and Lina continued to remind us about how close they
were to the police, what good friends they were. I believed Bobby and Lina could use the
police to hurt us because they said their business partner was a judge and they were
fiiends with police officers.
12. Bobby had told me there was a job waiting for me in the U.S., but I waited for about a
month before I had any work. Bobby sometimes had me perform work in Star One's
office. After about two months, I was still waiting for a regular job. Bobby eventually
told me I was going to work driving a golf cart at a country club. Bobby also told me that
if I did not take the job he would send me back home to the Philippines. He told me that
Star One was my employer and i f I said no to a job they could send me back home
because I worked for them.
13. Bobby made me work in many different places. Many times Bobby told me that i f I did
not work when he said to that he would take me off the work schedule and send me home
to the Philippines.
14.1 felt I had to do what Bobby said. I needed to make money to support my family and pay
back my loans. 1 knew that i f I got sent home I would not have a job and I would not be
able to pay back my loans or send money to my family. I felt I did not have a choice
because I needed to pay back my loans because the interest was rising. 1 had a big
responsibility to my family so I had to keep working all the time.
15. Lina yelled when we told her we needed more food and she said we ate too much. She
would yell i f anyone got sick and couldn't work. She yelled at anyone who was sick for
sleeping too much, because they couldn't work as much.
16. Sometimes when I was resting in the house, Lina would make me clean the house, wash
the dishes, cook for her, clean the bathroom or give her a pedicure or foot spa. When
Lina told me to do those things, I felt I had no choice but to do them. I knew that i f I did
not do them, Lina would not put me on the work schedule. I never got paid for doing any
jobs around the house.
17.1 felt scared all the time. I was working so many hours, but I wasn't sure i f Bobby was
going to give me enough of the money I was earning. 1 was worried all the time about
my parents and brother. They depended on the money I was sending home to the
Philippines, and Bobby wasn't paying me all the money I earned. I also still had to pay
off my loans that I had gotten to come to the United States.
18.1 got an ulcer when I was working for Star One in Florida.

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19. In the spring of 2007, after many hours at the Glen Head Country Club, I could not
breathe and had heart pains. I went to the hospital and the doctor said my breathing
problems and chest pains were from too much work and that I need rest. When I got
home I begged Bobby for another job because my job at Glen Head Country Club was
very physical. Bobby told me he could not find me another job or he would have to do it
for everyone. He told me he would send me back to the Philippines i f I did not continue
to work at my job. He said he had plenty of people and someone else could take my spot
at the Glen Head Country Club. I did not think I had a choice but to keep working so I
could pay off my loans.
20. In August, 2007,1 continued to work at the Glen Head Country Club. I could not breathe
again. The manager then called 911 and took me in an ambulance to the hospital. The
doctor said it was too much work again.
21. The first time I got sick in spring of 2007, the bills came to the house in Miami and Lina
screamed at me. I embarrassed and scared. Star One was supposed to pay for my medical
bills but never did. When the bills came after I got sick for the second time, they were in
my name. Bobby told my manager at the Glen Head Country Club that Star One would
pay my medical bills but they never paid for these bills. I got a letter from a collection
agency saying the bills were not paid. 1 asked my manager to talk to Bobby. Bobby got
really mad because he did not want me talking to my manager about Star One not paying
my medical bills. Star One and Bobby never paid the bills and I am still trying to pay
them all o f f I owed about $3,000 in medical bills.
22. In November 2007, there was not any food at the staff house in New York, there was no
hot water or heat and there was no transportation. Star One was still deducting the $800
from my payslip for food, housing and transportation even though they were not
providing them.
23.1 felt stress, anxiety and felt depressed as a resuh of what was happening with Star One.
While I was at Star One, I felt worried and scared all the time. After escaped, I had to go
to therapy to help me deal with these things.
24. Sometimes I still get scared about Bobby.
25.1 worry for my family in the Philippines. Bobby has all of my personal and financial
information, and he travels to the Philippines regularly.

I D E C L A R E U N D E R PENALTIES OF PERJURY T H A T THIS FOREGOING S T A T E M E N T
IS T R U E A N D C O k R E C T .
,
r
Date:
Denlit Fausto

4

r

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46

UNITED STATES DISTRICT COURT
FOR T H E SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
No.:9:10-cv-80771-KLR

Roy Magnifico, Roma Lim, Rezza Real,
Jeanette Halup, Bonifacio Ramos,
Lucille Liwag, Ross Ripotola, Raul
Rueda, Aries Caluya, Aris Ordoiiez,
Ritche Relampagos, Percival De Quiros
Jose Auingan, Denlit Fausto, Cesar
Ramos, Irene David, Amold Laxamana, and
Robert Bautista,
Plaintitfs,

V.

)

Roberto Villanueva, Redelina Femandez,
Star One Staffing, Inc., Star One Staffing
Intemational, Mary Jane Hague, John
Carmthers, and Ruth Carmthers,

)
)
)
)

Defendants.

)

Declaration of Plaintiff Jeanette Halup
COMES NOW Jeanette Halup who declares under penalties of perjury and states as follows:
1. M y name is Jeanette Halup. 1 am one of the Plaintiffs in this case.
2. I was recmited in the Philippines by JES Manpower to work as a waitress for Star One
Staffing in the U.S. Because my husband and 1 were poor and could hardly buy what w
needed, I wanted to find a better job than the one 1 had in the Philippines.

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3. I met Bobby Villanueva and Lina Femandez at the office of JES Manpower in Manila.
Bobby interviewed and hired me and assigned me to my work location in the U.S.
4. 1 had to spend about $2,729.00 to come firom the Philippines to the U.S. to work for Star
One. I was required to pay a recmitment fee of about $2,000, about $100 for my visa
application, about $100 for an attomey, about $97 for a medical exam, about $140 to the
Philippine Overseas Employment Administration and about $292.00 in other expenses.
5. 1 arrived in Miami to work for Star One in December 2006. This was my first time to be
outside of my country and to be far away from home. 1 was nervous and scared but at the
same time 1 was happy to work so 1 could help my family.
6. Lina picked me and some other Star One employees up at the airport and brought us to
Star One's Miami staff house. About forty people lived in the house. 1 had to find a
vacant bunk bed in a space that they put curtains around to make it look like a room.
7. Lina was always shouting at us and spoke aggressively. She reminded us that she was the
one feeding us and used many bad words. She also required us to do many household
chores and cooking. 1 once woke up early in the moming to Lina yelling and screaming at
us. She was angry because she found clean pots and pans in the sink and said they should
have been put in the cabinets. She began to throw the pots and pans to the floor. The area
where about sixteen of us were sleeping was very close to the kitchen and so we all woke
up with fear.
8. Lina wanted us to be quiet in the house because, if the neighbors complained about noise,
they would discover there were many of us living in the house. Lina and Bobby said only
a certain number of people can live in a house in Miami. And if they found out we exceed
that number, the neighbors would call the police and put us in jail.
9. Atfer a co-staff member escaped from the house, Bobby reported it to the police and the
police came to the house. 1 was the one who opened the door and was very scared and
shaking. Affer the police left, we were called to a meeting by Bobby and Lina. They said
the same thing will happen to us if we escape. They will report us to the police. The
police will search for us and put us in jail and send us back home.
10.1 was sure Lina and Bobby would find me and punish me i f 1 escaped. They always said
they had many connections in America. They have a relative who is a police officer in the
Miami police. He stopped by the staff house many times.

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11. Bobby would tell us that, if we escaped, he would catch us. A picture of our co-staff who
escaped was posted on our wall like a "wanted" person.
12. Every time we had a meeting, Bobby and Lina told us that, if we escaped, they could
easdy find us through our social security number. They said the police would find us
deport us back to the Philippines with handcuffs.
13. When 1 arrived in the U.S., I expected to have a job because that is what JES and Bobby
told me, but had to sit around the house for about a month. Bobby finally assigned me to
work in a hotel and country club.
umeio
14. We were picked up after one shift and shuttled to another location to work. We did not
hke this, but we could not do anything about it. Sometimes we worked a lot but you
could not complain abotit being tired because Bobby and Lina would get mad and take
you otf the work schedule and you ended up with no work at all.
15. Even though our jobs and pay and housing were not like what Bobby had told us 1 tried
to stay quiet and just do what 1 was told because 1 was afraid for my safety 1 also had a
family to feed and debts to pay in the Philippines.
16. In Miami, we would have to wake up early and wait to use the bathroom because there
were only two bathrooms for all of us. 1 was often awake before dawn so 1 could have
some pnvacy. Even then there were already other workers waiting in line.
'!ith?
"^'2007, we had a small house
with two bedrooms and it was also crowded. Bobby increased the deductions from our
pay when we were in New York and there was no work for us when we first amved.
18.  n New York, Bobby continued to tell us about the police and what would happen if we
nd t °t
1'"''"'^
""^ "'^^P^
- P ^ ^ ^ d to the immigration
and that, with our social security and bank account information, they will easily find us
He said some ot our co-workers who escaped in Miami were already deported to the
Philippines. 1 was so afraid.

my family and son m the Philippines. I stayed quiet because 1 did not want Bobby to be
angry at me.
j ^
20. At Star One, 1 was always so tired and scared.

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21. M y time working for Star One was humiliating. It was painful for me to be in that
situation. 1 had to keep quiet and endure what was demanded of me.
22. After 1 escaped, I was still very afraid. I have feared for my safety and the safety of mv
family.
J
:i
23. Because of what happened at Star One, I still have a very hard time trusting my
employers. 1 always have doubts and that makes my jobs since Star One harder and more
stressful for me.

Is ™ " A N ^ o f R E c f ° ' ' ' " ' " " ' ^ ™ ' ' ' '

FOREGOING STATEMENT
Date:

Jeanette Hal

4

0? \TY

\ \ ' ^

 Case 9:10-cv-80771-KLR Document 127-1 Entered on FLSD Docket 07/30/2012 Page 38 of
46

UNITED STATES DISTRICT COURT
FOR T H E SOUTHERN DISTRICT OF FLORIDA
WEST P A L M BEACH DIVISION
No.: 9:10-cv-80771-KLR

Roy Magnifico, Roma Lim, Rezza Real,
Jeanette Halup, Bonifacio Ramos,
Lucille Liwag, Ross Ripotola, Raul
Rueda, Aries Caluya, Aris Ordonez,
Ritche Relampagos, Percival De Quiros
Jose Auingan, Denlit Fausto, Cesar
Ramos, Irene David, Amold Laxamana, and
Robert Bautista,
Plaintiffs,

V.

Roberto Villanueva, Redelina Femandez,
Star One Staffing, Inc., Star One Staffing
Intemational, Mary Jane Hague, John
Carmthers, and Ruth Carmthers,
Defendants.

Declaration of Plaintiff Arnold Laxamana
COMES N O W Amold Laxamana who declares under penalties of perjury and states as follows:
1. M y name is Amold Laxamana. I am one of the Plaintiffs in this case.
2. In 2006,1 was working as a waiter in Saipan, Northem Mariana Islands. I had worked at
the hotel for almost 11 years. One of my co-workers told me about a man named Bobby
Villanueva who was recmiting Filipino workers to work for him in the U.S. M y coworker gave Bobby my phone number and Bobby began calling my phone several times
to talk about working for him.

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3. I decided to take the job with Bobby because the $6.78 per hour rate he told me I would
make was much higher than my current pay, especially with the overtime hours and all
the benefits he described.
4. Bobby told me that, if I wanted to accept his job I had to quit my job in Saipan right away
and buy a plane ticket to fly back to the Philippines to meet him and process my
immigration papers. Even though I worked at my job for 11 years and I would have to
pay my own way back to the Philippines, he made the job sound like an opportunity I had
to take to help my family. So I resigned fi-om my job at the hotel and bought a plane
ticket and flew back to the Philippines.
5. In addition to my plane ticket from Saipan to the Philippines, I was required to pay about
$100 for my visa fee, $100 to an attomey, 5,000 Philippine Pesos for a medical exam and
7,200 Philippine Pesos to the Philippine Overseas Employment Administration. In total,
this was about $437.68 in expenses to come from the Philippines to the U.S. to work for
the defendants.
6. When 1 got to Miami to work for Star One, Lina Femandez picked me up at the airport
and took my passport. Then they took me to a house that had about 30 people living in it.
They did not have any bed sheets or blankets that 1 could use so I had to use a bath towel
for a blanket. A few days later they drove us from Miami to Boca Raton, Florida to the
house that we would live in while we worked there. Just like the Miami house, they had
almost thirty people living there. We had only two bathrooms to use. We slept in bunk
beds and sometimes people would sleep on the floor.
7. I was always exhausted because of the hours 1 worked for Star One but I could never
count on having a day off to rest. It seemed like they did not want to see us having any
time off and they wanted to keep us working all the time. We were working double shifts
and working on our days o f f They would walk around and check our bedrooms and say,
"We need you to come and help at the country club." If you said you wanted to take some
time to rest, they would say, "You are here to work. If you don't want to work, let us
know so we can cancel your visa." Everyone was constantiy scared and tired because
Bobby and Lina and other supervisors were always threatening everyone all the time
about cancelling their visas. It became very stressful having them constantly threatening
to cancel our visas if we did not work whenever they told us to.
8. Bobby told us that if anyone tried to leave like some other workers had he would send a
picture of us to the police so the police would be looking for us. When he said that about
the police I knew 1 couldn't risk leaving so I felt like I had to stay no matter what.

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9. Bobby and Lina had a connection with a poUce officer. They said that, if we left Star One
they could find us easily because we would have to use our social security numbers. They
said that they would blow up our photos and give them to the police and tell them that we
were here illegally so that if the police found us we would be put in jail or deported.
10. When Bobby and Lina said they would tell the police if we left, it made it seem hopeless.
11. Bobby and Lina also threatened that they would have us deported back to the Philippines
if we tried to leave.
12. Bobby and Lina said that if they revoked our visas, then we could never work in the
United States again. I knew if I had my visa revoked I could not even return to my old job
because that would require a U.S. visa also.
13. Everyone knew that the owner of Star One was married to a judge. So when Bobby and
Lina said they would have our visas revoked and we would never be able to work in the
U.S. again, I believed them.
14.1 felt scared all the time. I was afraid of what would happen if I tried to leave Bobby and
then he called immigration and the police on me. I would not risk being deported because
me and my family would lose everything.
15. When Bobby told me about the job before I took it, he made it sound very different. He
made it sound like we would be comfortable. But it was not like that. A lot of us were
hungry sometimes and the house was overcrowded.
16.1 was very surprised when 1 got my first paycheck because I worked hard and thought I
had made a lot of money. However, there were deductions fi-om my pay for food, housing
and transportation. It was different than I had been told and even worse because I never
understood why Bobby would deduct transportation charges from my paycheck because I
was assigned to be a driver for Star One and to drive people to and fi-om work. It seemed
like I was paying Star One to be their driver.
17.1 was working so many hours but 1 never knew i f Bobby would pay me for the hours 1
was working. Also, because of all the deductions fi-om my pay, I wound up owing Star
One money. Sometimes 1 didn't have any money to send to my family. No matter how
much 1 worked and spent time driving day and night, my paycheck did not really change.
18.1 worked at my last employer for 11 years. I never had anything like this happen to me
before. When I came to the U.S. to work for Star One, I never expected that our situation

3

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46

would be like it was. Because of what happened, I felt really depressed and my body was
tired and I was totally affected. While I was working for Star One, I felt like 1 could not
do anything and it was really hard. Usually 1 was worrying because I was scared about
what would happen.
19.1 still feel worried about what Bobby might do to me and my family. I feel scared of
retaliation.

1 D E C L A R E U N D E R PENALTIES OF PERJURY T H A T THIS FOREGOING S T A T E M E N T
IS TRUE A N D CORRECT.

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46

UNITED STATES DISTRICT COURT
FOR T H E SOUTHERN DISTRICT OF FLORIDA
WEST P A L M BEACH DIVISION
No.: 9:10-cv-80771-KLR

Roy Magnifico, Roma Lim, Rezza Real,
Jeanette Halup, Bonifacio Ramos,
Lucille Liwag, Ross Ripotola, Raul
Rueda, Aries Caluya, Aris Ordonez,
Ritche Relampagos, Percival De Quiros
Jose Auingan, Denlit Fausto, Cesar
Ramos, Irene David, Amold Laxamana, and
Robert Bautista,
Plaintiffs,

V.

Roberto Villanueva, Redelina Femandez,
Star One Staffing, Inc., Star One Staffing
Intemational, Mary Jane Hague, John
Carmthers, and Ruth Carmthers,
Defendants.

Declaration of Plaintiff Roma Lim
COMES N O W Roma L i m who declares under penahies of perjury and states as follows:
1. M y name is Roma Lim. I am one of the Plaintiffs in this case.
2

While working at a hotel in Manila, I started to look for work opportunities abroad so that
I could support my children. During that time, I was recmited to work for Star One
Staffing.

3

I was interviewed by Bobby Villanueva during August 2006. He described the job at Star
One Staffing to me and said I would be paid well, provided free food, housing and
transportation. He showed me photos of staff in nice uniforms and of the country clubs.

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4. After the interview, I was told to go to JES Intemational and learned I had been hired by
Star One Staffing.
s

T was reauired to pay about $2,338.76 to come to work for Star One in the U.S. I had to
$1,949.00.1 was also required to pay about $97^44 ^0^^^^^^^^
fee, $97.44 for a visa application, about $48.72 for a medical exam, and about $146.16 to
the'philippine Overseas Employment Administration.

' ZIESTS'SSL

6. I did not have this money since I was barely making ends meet and had to borrow it from
a lending company.
7. At that time, I was solely financially responsible for my 'children a^^^^^^^^
arranged to leave my children with my rnother while I ^^^^^/^ J^^^J^^^^
Staffing. She would look after them while I worked m the United States.
8

I

I arrived in Miami in November 2006 with several other people recruited from the
PhSppinestowork^^^
Femandez.

9

At first I was taken to a house with about thirty people living in it. Each bedroorn had
b u l bedsln it and people were also sleeping in a storage area. There were only two
bathrooms for us and we needed to wake up early because "
s
d^^^^^
for
them. I was uncomfortable. I was later taken to live m an apartment with a work
supervisor and about six other people living in it.

10 I had to work more than I had been promised. Even on days I had off, I was on call to
work at o L locations. I was extremely tired from working so much. One day was so
tired I fell asleep on the bathroom floor of the hotel where I was working. I feh really
Tad for doing this but could not stay up any longer after working constant hours without
rest.
11 I could not ask for days off because Bobby and Lina got mad and I was afraid of them.
• Also i^^^^^^^^^ not want to work, they would punish you by not giving yo^-yj
f^
all later. I feh I could not complain because they were in charge and controlled where we
worked and when we worked.
12 Lina was loud all of the time. She would repeatedly let us know that, if we did not feel
uS JorL ng, we would lose our immigration stahis and the police would arrest us and
send us blck fo the Philippines. She said this to me almost every time I would see her.
n

T ina would sav things like, "If you don't continue to work for Star One, you will easily
yon^ social'security number and deported back to the Philippines.
The first step we will take is to report you to the pohce and immigration.

iTZ^'^olX

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14 I believed Lina because I knew she and Bobby had police friends. I had seen a police
' officer visit them. Lina would also tell us that the judge that owned Star One knew what
Star One was doing and that it was not doing anything wrong.
15.1 felt like I could not do anything about my siUiation because I was very afraid of what
the police and judge could do to me.
16 I was also very afraid of Bobby. Like Lina, he would repeatedly mention his connections
with the police and judge. He would say that Mary Jane, the president of Star One, had
connections with the United States Embassy in the Philippines and that was the reason
everyone was able to get their visas. I knew that Bobby had a lot of connections in the
U.S. and Philippines.
17 When someone escaped, Bobby would call a meeting and remind us that anyone who
escaped was reported to the police. I was afraid and felt trapped and did not want to get
into h-ouble with the police. I kept working because of this.
18. We were not paid what we were promised. I did not get my first paycheck until January
2007 and was upset when I found out about all the deductions. They took about $400 per
month for food, housing and fransportation even though we were promised it would be
provided for free. This was not fair but I did not think I could complain. I was very
scared.
19. Bobby and the people he supervised held my original 1-94. When this happened, it made
me feel very bad and that I could not leave without my documents.
20. When Bobby took us to New York, he continued to tell us that he would call the police
and we would be tracked down by our social security numbers if we escaped.
21.1 felt completely controlled by Bobby because of the threats and also because of the
deductions and cash advances that put us into debt with thenl.
22. The number of meetings that we were required to attend increased while we were in New
York. Bobby and Lina would tell us to think before we left because, i f we left,
immigration would find us. Lina told me about my friend who had escaped and that they
had sent immigration looking for her.
23 I was afraid when I was at Star One. Even though I knew Bobby and Lina were not doing
the right thing, I feh I had to follow them. I feh a lot of shame for continuing to work for
them.
24.1 was afraid to leave my room during days off I did not tiiist anyone.

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25. Even at work I v^ras afraid to do something Bobby would disapprove of because I knew he
would find out everything. I fried to be very careful to do what Bobby and Lina wanted. I
feh so much stress.
26,1 feh desperate after working hard for long hours and barely receiving any pay.
27. Because of what happened with Star One, I feh worried all the time. I also had a hard
time ever feeling safe.
28. For about three years afler I left Star One, I was scared for my family and about what
Bobby might do to us. I always told them to lock the doors and stay home. I knew that
my family and I had to be carefiil for our safety. I still sometimes worry about this.
29. It was so hard to trust anyone after what Bobby and Lina did to us. I had difficulty
talking to and trusting people I did not know. I was afraid that everyone was a spy for
Bobby.
30.1 had to go to counseling for about a year to help me to deal with what happened to me.
I D E C L A R E U N D E R PENAETffiS OF PERJURY T H A T THIS FOREGOING S T A T E M E N T
IS TRUE A N D C O R R E J S T T ^ X

4