Case 1:18-cv-01458-PLF Document 38 Filed 07/12/18 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA M.G.U., et al., Plaintiff, v. Civil Action No. 1:18-cv-1458 (PLF) KIRSTJEN NIELSEN, et al., Defendants. NOTICE OF SUPPLEMENTAL PRELIMINARY INJUNCTION EVIDENCE Plaintiffs attach the following document for consideration in the preliminary injunction hearing scheduled for July 12: Dkt. No. 38-1 – Declaration of Ashley Martinez dated July 11, 2018 Respectfully submitted, Dated: Washington, D.C. July 12, 2018 TEXAS RIOGRANDE LEGAL AID, INC. /s/ Jerome Wesevich Jerome Wesevich (D.D.C. Bar 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 achisholm@trla.org pmcgraw@trla.org Case 1:18-cv-01458-PLF Document 38 Filed 07/12/18 Page 2 of 2 PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP David J. Ball (DC Bar No. 460055) 2001 K Street, NW Washington, DC 20006-1047 (202) 223-7352 dball@paulweiss.com Steven C. Herzog (admitted pro hac vice) Meredith A. Arfa (admitted pro hac vice) Anand Sithian (admitted pro hac vice) Katherine Kelly Fell (admitted pro hac vice) 1285 Avenue of the Americas New York, NY 10019-6064 (212) 373-3000 sherzog@paulweiss.com marfa@paulweiss.com asithian@paulweiss.com kfell@paulweiss.com Attorneys for Plaintiffs CERTIFICATE OF SERVICE Pursuant to LCvR 5.3, I hereby certify that, on July 12, 2018, I caused to be electronically filed a copy of the foregoing document to be served on all counsel of record using the Court’s CM/ECF system. /s/ Jerome Wesevich Jerome Wesevich (D.D.C. Bar No. TX0125) el al.. KIRSTJEN NIELSEN, et al., Case Document 38-1 Filed 07/12/18 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Plaintiff, Civrl Action No. 1:18-cv-1458 (P1117) V. Defendants. DECLARATION OF ASHLEY N. MARTINEZ 1, Ashley N. Martinez, make the following declaration based on my personal knowledge and declare under penalty of perjury pursuant to 28 U.S.C. 1746 that the following is true and 1. I am an attorney and have been licensed and admitted in the State of California since December 2017. I currently work as a Staff Attorney with Texas RioGrande Legal Aid Inc. and my practice is devoted to immigration matters. I have served in this capacity since February 12, 2018. ER is the Plaintiff in 18-cv-1458. She is currently detained at the El Paso- SPC detention center located at 8915 Montana Ave, El Paso, Texas 79925. I have met with E.F. in person on several occasions since June 20, 2018. Together BF. and I have reviewed documents written in both English and Spanish. E.F. is not able to read or write in English. She is also not fully literate in Spanish; she can read simple sentences and knows how to write some letters and recognize some numbers. To ensure that E.F. understands information included in a written document, I read the document out loud to her in Spanish. If the document is written in English, I translate the document into Spanish as I read the document out loud to E.F. If the document requires E.F. to sign her name, I read the document out loud to E.F. in Spanish, E.F. then communicates to me that she understands what I have read to her, and BF. signs her name using an or Case Document 38-1 Filed 07/12/18 Page 2 of 2 4, On June 21, 2018, I visited BF. in detention to obtain a declaration. BF. provided the declaration that has been ?led in 18-cv-1458 as ECF Document No. 8-2. E.F. provided this statement to me orally in Spanish. 1 translated E.F.'s statement and wrote the statement in English. When I completed the written statement 1 read it back to E.F. out loud in Spanish. E.F. stated that she understood the statement and that it was true and correct. I personally watched E.F. sign her name using an on page 5 of ECF Document No. 8-2. I then signed the certi?cate of translation below signature. I declare under penalty of perjury pursuant to 28 U.S.C. 1746 that the foregoing is true and correct to the best of my personal knowledge. Executed in El Paso, Texas on July 11, 2018. ASHLEY N. MARTINEZ