Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1173 Page 22 of 49 I, 2 Ms. G. , make the following declaration based on my personal knowledge and declare under the penalty of perjury pursuant to 28 U.S.C. § 3 4 1746 that the following is true and correct: 5 I. I am a citizen of Mexico and am seeking asylum in the United States. When I 6 came to the United States, I asked for asylum at the border in Nogales, Arizona I am 7 8 9 now in immigration proceedings before an immigration judge to seek asylum .r 2. I came to the United States on or around March I, 2018 with my biological 10 II 12 13 daughter, Y-M-N-P, who is six years old, and blind, and my biological son, J-P-P-G, who is four years old. Both are from Mexico and seeking asylum. 3. When we came to the United States, we reported at Nogales, Arizona and said 14 15 that I wanted to seek asylum. 16 4. Shortly after arriving, I was told that I was going to be separated from my 17 daughter. There were no doubts expressed that I was my daughter' s biological mother 18 19 20 and I have a birth certificate to show our relationship. They did not say that I was a danger to my daughter or was abusive. 21 22 23 24 5. I was sent to the Eloy Detention Center around March 5, 2018. My children were sent to an ORR facility in Phoenix, Ari zona 6. I have not seen my children for one and a half months. I worry about them 25 26 constantly and don't know when I will see them. We have talked on the phone, at first 27 28 18cv0428 Exh. 22, Page 20 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1174 Page 23 of 49 once a week, and now twice a week. They are constantly asking me when we wi 11 be 2 together again. 3 I know that Y-M-N-P- and J-P-P-G are having a very hard time detained all by 4 7. 5 themselves without me. They are only six and four years-old in a strange country and 6 7 8 9 they need their parent. 8. I hope I can be with my children very soon. I miss them and am scared for them. 10 11 9. I declare under penalty of perjury under the laws of the United States of 12 America that the foregoing is true and correct, based on my personal knowledge. 13 Executed in Eloy, Arizona, April ~' 2018. 'l-3 14 15 16 I Ms. G. 17 18 19 20 21 22 23 24 25 26 27 28 Exh. 22, Page 21 18cv0428 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1183 Page 32 of 49 1 1. I, Ms. J. I. L. , make the following declaration based on my 2 personal knowledge and declare under the penalty of perjury pursuant to 28 U.S.C. § 3 4 1746 that the following is true and correct: 5 2. I am a citizen of El Salvador and am seeking asylum in the United States. I had 6 7 8 9 my initial asylum interview ("credible fear interview") on March 27 or 28, 2018. I received a negative finding on my credible fear interview, and I immediately asked for review of the decision by the immigration judge. I have yet to receive a date for my 10 11 12 13 appearance before an immigration judge to review the negative finding. I hope to have the opportunity to present my asylum case in immigration court. My children and I fled El Salvador, and I fear that we will be killed if we return there. 14 15 3. 16 2018, seeking protection from violence in El Salvador. My son J.S.P.L. was born on I arrived at the Texas/Mexico border with my two biological sons on March 13, 17 18 19 20 August 3, 2007 and is ten years old. My son D.A.P.L. was born on March 30, 2014 and is four years old. 4. My sons and I were apprehended with three other women near Roma, Texas by 21 22 23 24 border officials on the morning of March 13th, 2018. The officers put us in the back of their vehicle and drove us to the border station. Everyone referred to the station as an "icebox" or "hie/era." 25 26 5. 27 Later, one of the officers said that they believed I had ties to gangs back to El At the hielera, the officers asked for my information and took my fingerprints. 28 Exh. 24, Page 30 18cv0428 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1184 Page 33 of 49 1 2 Salvador. I have never been a part of or aided the gangs in El Salvador. In fact, gang members severely beat me in front of my children for refusing to comply with their 3 4 orders. My ex-partner is in prison back in El Salvador for involvement with the 5 gangs, but I did not support his involvement, which put my children and me in danger. 6 7 8 9 6. Another officer in the hielera told me that I was going to be transferred to the Immigration and Customs Enforcement ("ICE") Laredo Detention Center in Laredo, Texas. However, J.S.P.L. and D.A.P.L. were not going to be transferred with me. The 10 11 12 13 officer said that children were not allowed at the Laredo facility. 7. That day, March 13, a woman came to pick up my kids. I was given only five minutes to say goodbye before J.S.P.L. and D.A.P.L. were tom from me. My babies 14 15 started crying when they found out we were going to be separated. It breaks my heart 16 to remember my youngest wail, "Why do I have to leave? Marni, I want to stay with 17 18 19 20 you!" My youngest cried and screamed in protest because he did not want to leave my side. My oldest son was also confused and did not understand what was happening. In tears myself, I asked my boys to be brave, and I promised we would be together again 21 22 23 24 soon. I begged the woman who took my children to keep them together so they could at least have each other. She promised she would, and she left with my boys. I was transferred to the Laredo Detention Center. I have been in this detention center since 25 26 then and am heartbroken. 27 28 Exh. 24, Page 31 18cv0428 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1185 Page 34 of 49 1 2 8. It has been 18 days since I have spoken to my boys. I do not know where my sons are, and I am very worried about them. I called the Office of Refugee 3 4 Resettlement to learn about my children, but the office only told me that the boys are 5 ·in a shelter in San Antonio. 6 7 8 9 9. The separation from my sons has been incredibly hard, because I have never been away from them before. I do not want my children to think that I abandoned them. J.S.P.L. and D.A.P.L. are so attached to me. D.A.P.L. used to sleep in bed with 10 11 12 13 me every night while J.S.P.L. slept in his own bed in the same room. Back in El Salvador, my kids became nervous every time I was out of their sight. They would calm down as soon as they saw me, and I assured them that I would not leave them. It 14 15 hurts me to think how anxious and distressed they must be without me. l6 10. I am particularly worried about my older son J.S.P.L. who was not doing well 17 18 19 20 back in El Salvador after he saw MS gang members beat me and threaten me. He did not even want to leave my side to go to the restroom. Before the MS started threatening us, J.S.P.L. was a normal, happy child. He loved to play and study. School 21 22 23 24 was his favorite part of his day. After the MS's threats and beatings, he did not want to go to school anymore, because he was afraid he would not find me when he came back home. Now, his worst fear has come true; I am not by his side. He must be worse 25 26 now that he is suffering all by himself. I am also very worried about my younger son 27 28 Exh. 24, Page 32 18cv0428 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1186 Page 35 of 49 1 2 because he is only four years old. Both of my sons need their mother. I do not know if they are eating, sleeping, or even going to the restroom. 3 4 11. 5 their mother. I have heard that my two sons may have been separated and placed in I brought my sons to the United States to seek safety not to leave them without 6 7 8 9 different foster homes. If this is true, I am even more worried, because now they are with strangers, away from each other. 12. I am desperate to be reunited with both of my sons. I came with the hope that 10 11 12 13 we could come here and live safely together. Instead, I am imprisoned while my two boys are alone among strangers. 13. I would like to be released and reunited with my sons so we can live with 14 15 family in the United States while we pursue our asylum cases. I have an aunt in l6 Virginia who is a United States citizen. If we cannot be released, I would rather be 17 18 19 20 detained together. 14. I hope I can be reunited with my sons very soon. I pray that people put themselves in my shoes and think about how difficult it must be for me as a mother to 21 22 23 be away from my children. I miss J.S.P.L. and D.A.P.L., and I am scared for my little boys. 24 25 26 27 28 Exh. 24, Page 33 18cv0428 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1187 Page 36 of 49 1 I declare under penalty of perjury under the laws of the United States of America that 2 the foregoing is true and correct, based on my personal knowledge. Executed in 3 4 Laredo, Texas, on April 3, 2018. 5 6 7 Ms. J. I. L. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 18cv0428 Exh. 24, Page 34 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1191 Page 40 of 49 Exh. 25, Page 38 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1192 Page 41 of 49 Exh. 25, Page 39 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1193 Page 42 of 49 Exh. 25, Page 40 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1194 Page 43 of 49 Exh. 25, Page 41 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1198 Page 47 of 49 1 2 1. I, Mr. A. , make the following declaration based on my personal knowledge and declare under the penalty of perjury pursuant to 28 U.S.C. § 1746 that the following is 3 4 true and correct: 5 2. I am a citizen of Honduras and came to the United States seeking asylum. I 6 7 8 9 received a negative determination of my initial asylum interview (“credible fear interview”), and an immigration judge affirmed it so I have a final order of removal but have not been deported. 10 11 12 13 3. I came to the United States on or around February 18, 2018 with my biological son, R.Z.A.R., who is three years old. He is also from Honduras and seeking asylum. 4. When we came to the United States, we turned ourselves in at the border in 14 15 Brownsville, Texas, and I said that I wanted to seek asylum. 16 5. Shortly after arriving, I was told that I was going to be separated from my son. 17 18 There were no doubts expressed that I was my son’s biological father and I have a 19 birth certificate to show our relationship. I also had my son’s vaccination records and 20 his passport. They did not tell me that I was a danger to my son or was abusive. They 21 22 23 24 told me that they had to separate me from my son because I had a prior removal order and they did not have any places to detain fathers and children. 6. I was sent to the South Texas Detention Center around February 19, 2018. My 25 26 son was sent to an ORR facility in or near El Paso, Texas. 27 28 Exh. 26, Page 45 18cv0428 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1199 Page 48 of 49 1 2 7. I have not seen him for over two months. I worry about R.Z.A.R. constantly and don't know when I will see him. We have talked on the phone several times, but I 3 4 do not have many minutes and I do not always get an answer when I call. 5 8. I know that R. is having a very hard time detained all by himself without me. 6 7 8 9 My son has already suffered a lot because his mother disappeared about six months ago. He is too young to understand that she was taken from us, but he knows she is gone and he misses her. That has been very hard on him. He is only a three-year-old in 10 11 12 a strange country and needs his parent. 9. I hope I can be with my son very soon. I miss him and am scared for him. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Exh. 26, Page 46 18cv0428 Case 3:18-cv-00428-DMS-MDD Document 62 Filed 04/27/18 PageID.1200 Page 49 of 49 Mr. A. Exh. 26, Page 47