(JON

Case Document 435-2 Filed 06/21/18 Page 1 of 2 Page ID
#:17558

DECLARATION OF AUGUST E. FLENTJE

I, AUGUST E. FLENTJE, declare:

1.I am a Special Counsel with the U.S. Department of Justice.
I am working in conjunction with Sarah Fabian, counsel of
reCord for the instant case. As such, I have personal
knowledge of the following facts and, if called as a
witness, I could and would testify competently thereto.

2. On June 20, 2018, co-counsel Sarah Fabian advised counsel
for Plaintiffs, Peter Schey, by email that the government
would be seeking ex parte relief in this matter. In that
email, she invited Mr. Schey to contact me to discuss the
request.

3.Later in the evening on June 20, 2018, I had the
opportunity to speak briefly with Mr. Schey. On that call,
I explained the nature of the relief we would be seeking in
our ex parte motion, and the fact that we would need to
file for relief some time on June 21, 2018.

4. As our ex parte motion explains, the government is open to
discussing with Plaintiffs or the Court other
options that will permit families to be kept together at
residential facilities during the time needed to complete
immigration proceedings. I am committed to continuing to

engage Mr. Schey on these issues.

 

Case Document 435-2 Filed 06/21/18 Page 2 of 2 Page I
#:17559

I declare under penalty of perjury that the foregoing is

true and correct.

  
 

Executed on June 21, 2018 at Washingto 

   

AUGUST E. FLENTJE