6.

1

While showing me where to sign and initial, he also mentioned to me that he

2

would put an ankle shackle on me. He used the Spanish word “grillete,” which means “shackle.”

3

He then showed me the ankle shackle, with its GPS monitor attached. This was the first time that

4

I became aware of the need to wear an ankle shackle.
7.

5

After my release from detention, I started making the $420 monthly payments. In

6

total, I made 16 monthly payments for a total of $6,720. I made my last payment to Nexus in

7

August 2015. At that point, I realized that my total payments to the company ($8,890)

8

represented more than my bail amount. As I learned from immigration attorneys that my asylum

9

case with the Immigration Court could take years to resolve, I decided that it would be unfair for

10

me to keep making payments to Nexus, when in reality I had already covered my bail amount

11

and more, so I decided to not make any further payments to them.
8.

12

In late September 2015, I saw an article in La Opinion that raised questions

13

regarding Nexus’ business practices, in particular its use of ankle shackles. The article mentioned

14

Casa de la Cultura de Guatemala as an entity that was investigating this issue. I then decided to

15

approach Casa, where I met Byron Vasquez, who interviewed me regarding my dealings with

16

Nexus.

17

9.

On September 30, 2015, I was invited to Casa de la Cultura for a press conference

18

organized by the Guatemalan consulate, which I attended, and during which I spoke about the

19

events contained in this declaration.

20

10.

Nexus never offered me free legal services in connection with my immigration

21

case. In fact, I was not even aware that the company offered such services to anyone until I saw a

22

report on Univision Noticias on October 1st, 2015, in which a representative for the company

23

claimed that Nexus offered free legal services to its clients.

24

11.

I believe that Nexus took advantage of me by hiding the true nature of their

25

business practices involving the ankle shackles until after I was already out of jail, when Nexus

26

created a high pressure environment to force me to sign documents that I did not understand

27

because they were in English, even though all of my oral communications with Nexus have

28

always been in Spanish.
NEFI MORONIS FLORES’ DECLARATION IN SUPPORT OF DEFENDANTS’ SPECIAL MOTION TO STRIKE
THE COMPLAINT PURSUANT TO CODE OF CIVIL PROCEDURE SECTION 425.16

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