Case 3:16-cv-03539-LB Document 84-11 Filed 10/05/17 Page 2 of 4

ELIZABETH O. GILL (SBN 218311)

JENNIFER L. CHOU (SBN 304838)

AMERICAN CIVIL LIBERTIES UNION FOUNDATION
OF NORTHERN CALIFORNIA, INC.

39 Drum Street

San Francisco, CA 9411 1

Telephone: (415) 621?2493

Facsimile: (415) 255-8437

Email: egill@aclunc. org

Email: jch0u@aclunc. org

BRIGITTE AMIRI (pro hac vice)

AMERICAN CIVIL LIBERTIES UNION FOUNDATION
125 Broad Street, 18th Floor

New York, NY 10004

Telephone: (212) 549?2633

Facsimile: (212) 549-2652

Email: bamiri@aclu. org

Email: bhauss@aclu. org

MELISSA GOODMAN (SBN 289464)

AMERICAN CIVIL LIBERTIES UNION FOUNDATION
OF SOUTHERN CALIFORNIA

1313 West 8th Street

Los Angeles, California 90017

Telephone: (213) 977-9500

Facsimile: (213) 977-5299

Email: mgoodman@aclusocal. org

DANIEL MACH (pro hac vice)

AMERICAN CIVIL LIBERTIES UNION FOUNDATION
915 15th Street NW

Washington, DC 20005

Telephone: (202) 675?2330

Email: dmach@aclu. org

Attorneys for Plaintiff

THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

AMERICAN CIVIL LIBERTIES UNION OF 
NORTHERN CALIFORNIA, JANE DOE, on 
behalf of herself and others similarly situated, 


Plaintiffs, 


 

 

 

Civil No. 3: 16-cv-3539?LB

DECLARATION OF JANE DOE

 

DON WRIGHT, Acting Secretary of Health
and Human Services, et al.

Case Document 84-11 Filed 10/05/17 Page 3 of 4

Defendants.

 

 

 

U.)

10.

11.

1, Jane Doe, hereby declare and state as follows:

I submit this declaration in support of Plaintiffs? motion for a temporary restraining
order.

I came to the United States from my home country without my parents.

I am 17 years old.

I was detained upon arrival, and am currently in a shelter in Texas.

I am pregnant. I have decided to have an abortion.

1 have sought and obtained a judicial bypass of Texas?s parent consent law.

Both an attorney ad litem and a guardian ad litem were appointed to assist me in the
judicial bypass. They both speak Spanish and have explained what is happening to me
and my legal rights.

This declaration has been translated for me by my ad litems so that I know its
contents and it states the truth.

I had an appointment scheduled for September 28, 2017, with a licensed health care
facility in Texas for an examination by a licensed physician who specializes in
obstetrics and gynecology, and to obtain options counseling.

I had an appointment scheduled for September 29, 2017, for the abortion.

I have been told my ad litems that Defendants prohibited me from traveling to the

health care center for the examination, counseling, and ab01tion.

 



 

 

12.

13.

14.

15.

16.

17.

Case Document 84-11 Filed 10/05/17 Page 4 of 4

Defendants have forced me to obtain counseling from a religiously af?liated crisis
pregnancy center where 1 was forced to look at the sonogram.

Defendants have been talking to me about my pregnancy feel like they are trying to
coerce me to carry my pregnancy to term.

Defendants told my mother about my pregnancy, and are trying to force me to tell her
as well.

1 do not want to be forced to carry a pregnancy to term against my will.

I do not want to proceed in court using my real name because I fear retaliation because
I am seeking an abortion. I do not want my family to know that I am seeking an
abortion.

I agree to be a class representative for similarly situated individuals.

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

Dated: October 4, 2017

2909

Jane Doe