IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION CITY OF EL CENIZO, MAYOR RAUL L. REYES, City of El Cenizo; MAVERICK MAVERICK COUNTY SHERIFF TOM MAVERICK COUNTY CONSTABLE PRECINCT 3~1 MARIO A. and LEAGUE OF UNITED LATIN AMERICAN CITIZENS, Plaintiff? v. STATE OF GOVERNOR GREG ABBOTT, in his official capacity; and TEXAS ATTORNEY GENERAL KEN PAXTON, in his of?cial capacity Defendants EL PASO RICHARD WILES, SHERIFF OF EL PASO COUNTY, in his of?cial capacity; and the TEXAS ORGANIZING PROJECT EDUCATION FUND Plaintiff? v. STATE OF GOVERNOR GREG ATTORNEY GENERAL KEN and DIRECTOR STEVE MCCRAW, TEXAS DEPARTMENT OF PUBLIC SAFETY in their of?cial capacities Defendants Civil Action No. [Lead Case] Civil Action No. [Consolidated Case] CITY OF SAN ANTONIO, REY A. SALDANA, in his of?cial capacity as San Antonio City Councilmernber; TEXAS ASSOCIATION OF CHICANOS IN HIGHER LA UNION DEL PUEBLO and WORKERS DEFENSE PROJECT Piainti?fs v. STATE OF GREG ABBOTT, in his official capacity as Governor of the State of Texas; KEN PAXTON, in his of?cial capacity as Attorney General of Texas Defendants Civil Action No. [Consolidated Case] DECLARATION OF REYNA TORRES MENDIVIL 1. My name is Reyna Torres Mendivil, I am over the age of eighteen years and I have personal knowledge of the following statements of facts. 2. I have been serving as Consul General of Mexico in San Antonio since April 2017. I am a member of the Mexican Foreign Service with the rank of Ambassador. From 2013 to 2016, I was Director General for Protection of Mexicans Abroad at the Ministry of Foreign Affairs in charge of overseeing consular protection across the United States, and I previously served as Consul of Mexico in Fresno, California, from 2009 to 2013. 3. As a consular officer I enjoy the immunities and privileges afforded by articles 40, 41 and 43 of the Vienna Convention on Consular Relations (596 UNTS 261; 21 UST 77; TIAS 6820) hereinafter ?the Vienna Convention? but I could testify in court exclusively concerning the contents of this statement, pursuant to an express waiver of immunity to that effect. As Consul General of Mexico in San Antonio, Texas, I am charged with performing all consular functions contained in article 5 of the Vienna Convention, particularly: protecting the interests of Mexican nationals; furthering the development of commercial, economic, cultural and scientific relations between Mexico and Texas; (0) issuing passports and travel documents to Mexican nationals helping and assisting Mexican nationals; acting as notary and civil registrar and in capacities of a similar kind, and performing certain functions of an administrative nature; safeguarding the interests of minors and other persons lacking full capacity who are Mexican nationals; and representing or arranging appropriate representation for Mexican nationals before the Texas tribunals and other Texas authorities, for the purpose of obtaining, in accordance with the laws and regulations, provisional measures for the preservation of the rights and interests of these nationals, where, because of absence or any other reason, such nationals are unable at the proper time to assume the defense of their rights and interests. The Government of Mexico has 11 consulates in the following cities in the state of Texas: Austin, Brownsville, Dallas, Del Rio, Eagle Pass, El Paso, Houston, Laredo, McAllen, Presidio and San Antonio, all charged with performing the same duties previously described within their consular districts. 6. The Government of Mexico keeps statistics of the consular services it provides including the number of travel and other documents issued to Mexican nationals and the number of people seeking assistance from the consulates. 7. In addition, the Government of Mexico also operates the call center ?Centro de Informacidn Asisteucia a Mexicanos? (hereinafter CIAM) to inform Mexican nationals about the protection services provided by the Consulates along with other topics of interest concerning their rights in the United States. After May 7th, 2017, CIAM has registered an increase of 678% in the number of calls from Mexican nationals in Texas, when compared with the period from May to June 2016. 8. As Consul General, 1 have seen a 32.4% increase in the number of consular documents issued to Mexican nationals by all consulates in Texas since enactment of SB4 on May 7th, 2017, compared to those issued in May, 2016. These documents include paSSports, certified cepies of Mexican birth certi?cates, registrations of births abroad and consular identi?cation cards (?matricula consular?). 9. This increase in the requests for documents and calls for information is believed to be caused by fear and uncertainty in the community sparked by the implementation of SB4, as explained by the Consul General of Mexico in Austin in an interview with KVUEABCR 10. Within our 11 Consulates in Texas, the area of consular protection that has experienced the greatest expansion in the menths leading to SB4 is the number of immigrants/4025 90863 ll. 12. 13. civil and family law related cases, which has grown 45%, going from 690 from January to May 2016 to 1000 from January to May 2017. This is consistent with people seeking assistance and calling CIAM with concerns about family separation and preparedness plans. Also, there has'been a sharp increase in people seeking legal representation through the eleven Mexican consulates in Texas. During the 6 weeks previous to the enactment of 8B4 (March 22 to May 6), only 585 people requested legal assistance or representation, while in the following 6 weeks (May 7 to June 20) that number rose to 926, almost a 60% surge. During the above-mentioned period there was also an increase in the number of people seeking information on how to become US. citizens through the ?Dual Nationality WorkshOps? organized by the Mexican consulates throughout the State, going from 3,433 to 4,3 72 people attending the workshops. This shows that the unrest in the community impacts all Mexican immigrants, including Legal Permanent Residents who are increasingly worried about being unjusti?any targeted based on their national origin and thus want to become naturalized citizens to shield themselves and their families from discrimination and other consequences as a result of the enactment of 8B4. The Mexican Foreign Secretary has reiterated Mexico's respect for the United States? legal framework, and the importance of the rule of law and due process in immigration issues. However, considering that one third of Texas? population is Mexican or of Mexican origin, the Mexican Ministry of Foreign Affairs has publicly2 voiced its concerns regarding the impact of the law that if implemented will increase the perception of immigrants as criminals, encourage acts of racial discrimination, and erode the cooperation of the immigrant community with local authorities. 14. Just the anticipation of the adverse impact of the law in the Mexican community will certainly hamper the ll Texas Consulates? ability to carry out their mandate, in connection with promoting commercial, economic, cultural and scienti?c relations between Mexico and Texas.3 Considering that most of its resources will have to be devoted to funding legal defense for Mexican immigrants?, furtherance of those other objectives will be limited. 15. Following the enactment of SB 1070 in Arizona, the Government of Mexico issued a travel advisory to protect their citizens living in the United States. Any reduction in the bilateral economic or commercial activity will be detrimental to both Mexicans and Texans alike considering Texas is Mexico?s main trading partner. Of all the US. states, Texas exports the most to Mexico. In 2016, Mexico-Texas trade totaled USD 172.753 billions 340-the- forei gn~n1inistrv-re may?impact?states-economv/ 1 0 161 05 14;? 7/05/1 5Retrieved from :?wweensus. and ://wmv.census . gov/ forei gn~tradef statistics/ state/ data} imports/ tx.11tml. Accessed on June 22th, 2017. I declare under penalty of perjury pursuant to 28 USC 1746 that the foregoing is true and rd correct. Executed in Bexar County, Texas on the 23 day June, 2017. RE A ES Co eneral of xico in San Antonio