Case 2:85-cv-04544-DMG-AGR Document 420-2 Filed 04/23/18 Page 45 of 49 Page ID
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Exhibit 30
REDACTED VERSION OF DOCUMENT
FILED UNDER SEAL

Exhibit 30
Page 169

 Case 2:85-cv-04544-DMG-AGR Document 420-2 Filed 04/23/18 Page 46 of 49 Page ID
#:16572

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I,

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case, I would testify competently about these facts.

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declare as follows:
This declaration is based on my personal knowledge. If called to testify in this
I arrived in the United States at the end of 2014. I have been in six shelters and one

5 hospital. I am currently in the shelter at MercyFirst in Syosset, New York.
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After I an·ived in the U.S., I was in a shelter in Texas and then they transferred me

to a hospital for crazy people. Being there made me feel desperate; I felt like I would go

8 crazy. The walls were all white and they made you sit in a special seat if you misbehaved.
9 I stayed for 14 days.

10 4.

After the hospital, I went to a shelter in BJ Paso, Texas called Southwest Key and

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then to one in Houston. They moved me to Houston because the staff there could give me

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more medicine. I don't remember if I got anything in writing about their decision but I

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don 't think I had an opportunity to challenge it.

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medicine. I took nine pills in the morning and seven in the evening. I don't know what

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medications I was talcing; no one ever told me that. I don' t know what my diagnosis or

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iJJness is. The medicine made me fat. I used to be really skinny. It made me very hungry;

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I used to eat three plates at a time.

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intentionally. They made us act violently so then we bad to be given shots. The staff

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would insult us and call us names like "son of a whore." They often did it in English but I

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understood some English so I would know what they were saying and get really angry.

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was "Hors." He called the medical staff to the classroom to give me shots many times.

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One time, I got angry in class and wanted to leave the classroom. I was sitting down but

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he came and touched me so I got angrier. Then he grabbed me and twisted my ann

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behind my back then lifted up so I felt like my shoulder was braking. I screamed. The

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teacher had done the same thing to one of my fdends.

From Houston, I was moved to Shiloh. ln Shiloh they gave me even more

Some of the staff at Shiloh would provoke the children there and make us angry

Two of the staff members were violent with me. One was a teacher whose name

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Exhibit 30
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 Case 2:85-cv-04544-DMG-AGR Document 420-2 Filed 04/23/18 Page 47 of 49 Page ID
#:16573

1 8.

When he would call the medical staff, they would come and give me a shot to

2 tranquilize me. It happened many times. They would give me the shot and then I would
3 start to feel sleepy and heavy, and like I didn't have any strength. I would sleep for three
4 or four hours and then wake up and slowly start to feel my strength return. When the
5 did th~ they left :me in the classroom near the wall to sleep. I also saw them do that to
6 one of my friends,.

7 9.

Another staffmember at Shiloh was also violent with me twice. I don't know his

8 name; he was older and he retired while I was there. When he grabbed me, he would
9 bend my hand all the way back so it almost touched my wrist It really hurt. I almost
10 cried, but he just laughed.

l 1 10.

I wanted to stop taldng all the medication they were giving me at Shiloh but when 1

12 told the doctors that they told me that I had to continue because it calmed me. I met with
13 two different doctors there; both were men. I said the problem is this place, it makes me
14 angry. I was so scared there, I tried to behave well to get tranSferred.
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Finally, I was transferred to Sky in Chicago in November, 2016. There, the doctor

16 let me begin to stop taking the medications I didn't like. I was right From the day I got to

17 Chicago, I never got angry again. I felt better every day, as I stopped taking so much

18 medication.
19 12.

In May, 2017, I was moved to the Residential Treatment Center at MercyFirst. I

20 don't know why exactly. The staff said I would be treated better here. I didn't want to go
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because I had gotten accustomed to 1he program there but I agreed and I went voluntarily.

22 I don't remember if I was given anythmg in writing.
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I was taken to the hospital three or four times while I was at RTC but 1 never

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stayed overnight. I did not have any discipline problems that I remember.

In October. 2017. I was stepped down ftom theRTC to the shelter atMercyFirst
26 Now, my case worker says she is about to submit the paperwork for me to go to long25

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27 term foster care and live with a family. My only relative in the U.S. is my grandmother's
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#:16574

1 brother and be does not want to sponsor me. I miss my family in Mexico, especially my
2 mom, but I am scared to go back there because ofthe people who threatened to .kill me.
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I have not gotten a notice about a bond hearing o{ a list of legal services.

5 I declare under penalty of perjury that the foregoing is

Executed on this

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Exhibit 30
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