Case Document 445-2 Filed 06/29/18 Page 1 of 3 Page ID #:17994 Exhibit A Case 2:85-cv-04544-DMG-AGR Document 445-2 Filed 06/29/18 Page 2 of 3 Page ID #:17995 1 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 2 3 4 5 JENNY LISETTE FLORES, et al., Plaintiffs, 6 7 8 9 v. JEFFERSON B. SESSIONS, Attorney General, et al., 10 Defendants. 11 ) ) ) ) ) ) ) ) ) ) ) ) Case No. 85-4544-DMG (Px) DECLARATION OF MANOJ GOVINDAIAH, ESQ. 12 13 I, Manoj Govindaiah, declare as follows: 14 1. 15 agency that promotes justice by providing free and low-cost legal services to 16 underserved immigrant children, families, and refugees in Texas. RAICES is the 17 largest immigration legal services provider in Texas. As Director of Family 18 Detention Services, I oversee RAICES’ work at Texas’ family detention centers— 19 in particular, its work at the Karnes County Residential Center in Karnes City, 20 Texas. 21 2. 22 services to families detained there. Families reach us through word of mouth, 23 various sign-up sheets, referrals, and through our Karnes hotline. RAICES 24 provides legal services to an estimated 90% of the families detained at Karnes. 25 3. 26 administrative and other purposes. Our internal statistics show that in the year 27 between July 1, 2017 and June 26, 2018, we provided legal services to 5,177 28 families units detained at Karnes. Nearly all the families we worked with during I am the Director of Family Detention Services at RAICES, a nonprofit RAICES visits the Karnes facility four to five times each week provide legal RAICES routinely updates and maintains data on our work at Karnes for 1 Case 2:85-cv-04544-DMG-AGR Document 445-2 Filed 06/29/18 Page 3 of 3 Page ID #:17996 1 that time period had bona fide fears of persecution in their home countries. Indeed, 2 approximately 5,000 family units we served received positive credible fear 3 determinations by an asylum officer or an immigration judge, and were permitted 4 to pursue their asylum claims in immigration court. 5 4. 6 have a fear of return received expedited removal orders and were generally 7 deported from the United States within a few days afterwards. In contrast, the small minority of families who indicated that they did not 8 9 I declare under penalty of perjury of the laws of the State of California and 10 the United States that the foregoing is true and correct to the best of my knowledge 11 and belief. 12 13 Executed this 27th day of June 2018, in San Antonio, Texas. 14 /s/ Manoj Govindaiah Manoj Govindaiah 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2