Case 2:85-cv-04544-DMG-AGR Document 420-3 Filed 04/23/18 Page 64 of 68 Page ID #:16639 Exhibit 40 REDACTED VERSION OF DOCUMENT FILED UNDER SEAL Exhibit 40 Page 227 Case 2:85-cv-04544-DMG-AGR Document 420-3 Filed 04/23/18 Page 65 of 68 Page ID #:16640 1 I, declare as follows: 2 3 1. This declaration is based on my personal knowledge. If called to testify in this 4 case, I would testify competently about these facts . 5 2. 6 father was abusive for many years and there were fights at school that made me afraid. I 7 am currently being held in ORR custody in the Shiloh Residential Treatment Faciljty, in 8 Texas. 9 3. I am 17 years old. I am from Honduras. I came to the United States because my I was taken into the custody of the Office of Refugee Resettlement ("ORR") in the 10 summer of 2017. I was held at a shelter that was somewhere near Washington, D. C. 11 4. My potential sponsor is my mother. While I was at the shelter I received news that 12 my mother received a negative recommendation because she did not have a job and did 13 not understand my mental health. I felt frustrated and sad because I felt like I would 14 never leave the immigration center and like I would never reunjte with my mother. I 15 wanted to cry by myself so I stood near a window. The staff panicked and claimed that I 16 was trying to jump out the window. The staff then grabbed and four people held me 17 down. Each person held me down by one of my extremities, one on each thigh and one 18 on each arm. As the staff held me down I struggled against the staff I tried bite a woman 19 that was holding my arm, but it was only to try to get the staff off of me. 20 5. 21 2017. The staff at the shelter told me that I was being transferred because the 22 reunification process with my mother would be faster and easier at the next center. This 23 was not true. The process to reunify with my mother has still been taking a long time. I 24 was not told why I was transferred and I did not have an opportunity to object to the 25 transfer. 26 6. I was transferred to Shiloh Residential Treatment Center ("Shiloh") in September Since I came to Shiloh, I have not had a 30-day review. 27 28 1 Exhibit 40 Page 228 Case 2:85-cv-04544-DMG-AGR Document 420-3 Filed 04/23/18 Page 66 of 68 Page ID #:16641 1 7. I have been to court one time since I came to the United States. I think there was a 2 attorney there representing all the kids, but I do not remember speaking to an attorney 3 about my case. 4 8. 5 morning is Prozac, and I am told the other five are vitamins. I am told the four pills I At Shiloh, I take six pills in the morning and four pills in the night. One pill in the 6 take at night are vitamins. I do not know if my mother gave her permission for me to take 7 the pills. 8 9. I have told staff that I do not want to take the medication, but they have told me 9 that I need it and that I will get a report if I do not take it. A report means I would have 10 to stay at Shiloh for thirty more days. I have seen other kids getting reports and having to 11 stay at Shiloh longer because of the reports. 12 10. 13 told me that I am now in a lower level. I do not know what this means. On Tuesday, he I have been seeing Dr. Ruiz one time a week about my medications. Dr. Ruiz has 14 said that he "released me." He said that I have gotten better and that there is no reason 15 for me to stay here. He said that I have not got any reports, but that if! was to get a report 16 I would need to stay. 17 11. While at Shiloh, I have seen other kids get forced injections. I am not sure how 18 many times. I have seen a girl named ialllllllget a forced injection because she was 19 not controlling herself Two people had to hold her down while she got the injection. 20 She then sat in a chair and fell asleep for about an hour and a half. 21 12. Kids at Shiloh are also forced to take a strong medication during the day that 22 makes them fall asleep. I have seen this happen probably three times to a girl named 23 lllllllwho came here recently. One time around 11 a.m., we were outside playing and 24 two girls got into a fight and called each other nrunes. I tried to help stop the fight by 25 grabbing one of the girls to take her away. The staff told me not to touch her or I would 26 get a report, which means I would have to stay at Shiloh for 30 more days. The staff then 27 came and got behind the other girl to keep them from fighting. Then, they t o o k - 28 away and gave her a strong pill. I saw her later and she looked weird and dizzy, like she 2 Exhibit 40 Page 229 Case 2:85-cv-04544-DMG-AGR Document 420-3 Filed 04/23/18 Page 67 of 68 Page ID #:16642 1 was about to fall asleep. She then came inside and put her head on the desk and fell 2 asleep for about three hours. When she woke up, she told me she had a headache. 3 13. 4 open, including at night when we go to sleep. A staff person sits all night in the hallway 5 and monitors us through our open doors. In addition, whenever I speak over the telephon 6 a case manager is always present and the telephone is always on speaker. 7 14. 8 the hallway of the house where I sleep and in the cafeteria. 9 15. At Shiloh, there is a lack of privacy. The doors to our rooms always have to stay I am also under constant surveillance. My room has a camera. There are cameras in I do not know where the Prison Rape Elimination Act (PREA) telephone is located 10 in this facility. 11 16. I was recently told that my case was submitted to the government and that we are 12 waiting on a response. My mother now has a job and understands my mental health. I 13 miss my mother and younger brother so much, and I just want to be with them. It's been 14 five years since I have been without them. I do not want to be locked up in here. I would 15 be much happier if l could be with them. 16 17 18 I declare under penalty of perjury that the foregoing is true and correct. Executed on this 19 1st day of December, 2017, at Manvel, Texas. 20 21 22 23 24 25 26 27 28 3 Exhibit 40 Page 230