Case 1:18-cv-01458-PLF Document 12 Filed 06/25/18 Page 1 of 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA M.G.U., et al., Plaintiffs, v. U.S. DEPARTMENT OF HOMELAND SECURITY, et al., Defendants. § § § § § § § § § § No. 18-cv-1458-TSC Civil Action ERRATA NOTICE To correct redaction errors in compliance with Local Civil Rule 5.4(f), Plaintiffs attach to this notice the correctly redacted Exhibits 1 and 3 to their Application for Temporary Restraining Order. The attached ECF No. 12-1 replaces the document previously filed as ECF No. 8-1. The attached ECF No. 12-2 replaces the document previously filed as ECF No. 8-3. June 25, 2018 Respectfully submitted, TEXAS RIOGRANDE LEGAL AID, INC. ________________________________ Jerome Wesevich D.D.C. Attorney No. TX0125 Amanda Chisholm Texas Bar No. 24040684 Peter McGraw Texas Bar No. 24081036 1331 Texas Avenue El Paso, Texas 79901 (915) 241-0534 jwesevich@trla.org Attorneys for Plaintiffs Case Case 1:18-cv-01458-PLF 1:18-cv-01458 Document Document 8-1 12-1 Filed Filed 06/22/18 06/25/18 Page Page 1 of14of 4 DECLARATION OF A.P.F. I, A.P.F., make the following declaration based on my personal knowledge and declare under oath pursuant to 28 U.S.C. § 1746 that the following is true and correct. 1. I am the father of C.P.R. My daughter is twelve (12) years old. 2. I was separated from my daughter very late on June 4th or in the early morning hours of June 5th. 3. First the officials told me that my daughter was going to place called Casa Hogar, but they did not tell me where Casa Hogar was located or how long she would be there. 4. I have asked other immigration officials where my daughter is, but none of them are able to tell me where she is. 5. I called J A R called him two (2) times. J , the grandfather of C.P.R., and he told me that C.P.R. has A R told me that C.P.R. was very worried and was desperate to be with me. C.P.R. does not know where she is. 6. I worry about my daughter constantly. I am not able to speak with her directly. I do not know if she is well cared for. I do not know if she has been sick. I do not know if she has been sleeping well or eating well. Not knowing anything about my daughter is torture. I am not able to sleep. I desperately want to be with her. Case Case 1:18-cv-01458-PLF 1:18-cv-01458 Document Document 8-1 12-1 Filed Filed 06/22/18 06/25/18 Page Page 2 of24of 4 Case Case 1:18-cv-01458-PLF 1:18-cv-01458 Document Document 8-1 12-1 Filed Filed 06/22/18 06/25/18 Page Page 3 of34of 4 Case Case 1:18-cv-01458-PLF 1:18-cv-01458 Document Document 8-1 12-1 Filed Filed 06/22/18 06/25/18 Page Page 4 of44of 4 Case 1:18-cv-01458-PLF Document 12-2 Filed 06/25/18 Page 1 of 7 DECLARATION OF M.G.U. I am the mother of W.M.G., J.V.G., and G.V.G. We entered the United States together. They separated me and my children 14 days after the first day at the detention center in Dilley, TX. Now, I am in a detention center in Pearsall, TX without my children. I do not know when I will be able to see my children again. I am able to speak with them two times each week for only 10 minutes each time, but sometimes I am not able to speak with them because there are problems with the telephone. Sometimes the telephone says, “your voice is not recognized” and I need to call again. Also sometimes the telephone says “your call is disconnected.” The calls are very expensive so I am only able to call when I have money, but when I do not have money, I am not able to communicate with my children. In one month I only received one free call from the center. Also, sometimes my children do not answer. When I am able to call, G.V.G. is not able to give me information about his circumstances because he is only two years old and too young to communicate how he is. J.V.G. cannot communicate either by phone. He is a child that communicates with emotion and actions so it is difficult for him to communicate how he is. W.M.G. is able to communicate a little, but he is not able to tell me how G.V.G. is because they are only together for one hour each day. They feel more comfortable and confident to say more in person than over the telephone. They have never needed to do this before because we were always together, so this type of communication is uncomfortable. I do not know the people who are caring for them so I worry every day. I have never seen my children’s room either, nor the school, the cafeteria, nothing. So I am not able to know if they are safe. The Director said that she knows that the news is saying lots of things but the children are fine there and that they are good kids. But she does not say any details. She did not tell me anything about how they are eating, or how they are sleeping, and nothing about the school. I know that they are not “fine” because they cry a lot, especially J.V.G. y G.V.G.. And W.M.G. is always asking “how is your case” because he wants to be together. Case 1:18-cv-01458-PLF Document 12-2 Filed 06/25/18 Page 2 of 7 Like every parent, I want all the information about my children. I want a video of where they are living. I want to know the therapists, the teacher, and all of the people that have contact with my children. Also, I have concerns about the school and I want to know how school is going. I am not able to get this information because of the problems with the telephone, it is too expensive, and if I just have 20 minutes each week to speak, I am going to talk to my children and they are not able to give me this information. Each minute that I do not have this information is anguish. Each minute that I am separated from my children is anguish. I am never at ease without this information and without my children. Case Document 12-2 Filed 06/25/18 Page 3 of 7 1, under pains and penalties of perjury state and declare that the foregoing is true and correct based on my personal knowledge. Executed in j9?aV??ll ,TexasonJune 2:2 ,20l8. Lam-a- CERTIFICATE OF TRANSLATION 1, Fa. certify that the above is an accurate translation of ?I-?ml?s declaration from Spanish to English and that I am competent in both Spanish and English to render such translation. WW Co/Ql Date 1 -11- 11 1 1 1 1 Case Document 12-2 Filed 06/25/18 Page 4 of 7 V0 503 la mac/re 01C 14/. - Eh+ramo5 MnIdoS Jun+os L05 01c: miM (Elem/165 anar _Cf] Ahom 9.51% Cf?? 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