Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 1 of 89 Page ID #:18526 5 CENTER FOR HUMAN RIGHTS & CONSTITUTIONAL LAW Peter A. Schey (Cal. Bar No. 58232) Carlos Holguín (Cal. Bar No. 90754) 256 South Occidental Boulevard Los Angeles, CA 90057 Telephone: (213) 388-8693 Facsimile: (213) 386-9484 Email: crholguin@centerforhumanrights.org pschey@centerforhumanrights.org 6 ORRICK, HERRINGTON & SUTCLIFFE LLP 1 2 3 4 7 8 9 10 11 Elena Garcia (Cal. Bar No. 299680) 777 South Figueroa Street, Suite 3200 Los Angeles, CA 90017 Telephone: (213) 629-2020 Email: egarcia@orrick.com Attorneys for plaintiffs (listing continues on following page) 12 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN D IVISION 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JENNY LISETTE FLORES, et al., Plaintiffs, - vs JEFFERSON B. SESSIONS, ATTORNEY GENERAL OF THE UNITED STATES, et al., Defendants. ) ) ) ) ) ) ) ) ) ) Case No. CV 85-4544 DMG (AGRx)
 EXHIBITS IN SUPPORT OF PLAINTIFFS’ RESPONSE TO DEFENDANTS’ FIRST JUVENILE COORDINATOR REPORTS VOLUME 3 OF 12 [REDACTED VERSION OF DOCUMENT PROPOSED TO BE FILED UNDER SEAL] [HON. DOLLY M. GEE] Hearing: July 27, 2018 Time: 10 AM Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 2 of 89 Page ID #:18527 1 2 3 4 5 6 7 8 9 10 11 12 Plaintiffs’ counsel, continued LA RAZA CENTRO LEGAL, INC. Michael S. Sorgen (Cal. Bar No. 43107) 474 Valencia Street, #295 San Francisco, CA 94103 Telephone: (415) 575-3500 THE LAW FOUNDATION OF SILICON VALLEY LEGAL ADVOCATES FOR CHILDREN AND YOUTH PUBLIC INTEREST LAW FIRM Jennifer Kelleher Cloyd (Cal. Bar No. 197348) Katherine H. Manning (Cal. Bar No. 229233) Annette Kirkham (Cal. Bar No. 217958) 152 North Third Street, 3rd floor San Jose, CA 95112 Telephone: (408) 280-2437 Facsimile: (408) 288-8850 Email: jenniferk@lawfoundation.org kate.manning@lawfoundation.org annettek@lawfoundation.org 13 Of counsel: 14 15 16 17 YOUTH LAW CENTER Virginia Corrigan (Cal. Bar No. 292035) 832 Folsom Street, Suite 700
 San Francisco, CA 94104 Telephone: (415) 543-3379 18 19 20 21 22 23 24 25 26 27 28 /// Filed ?07fi6/?18?Pag6?3 01?89?Page" #:18528 1 2 VOLUME 1 3 1. Declaration of Class Counsel, Peter Schey 4 2. List of Licensed Group Homes and Homeless Youth Shelters 5 5 3. Declaration of Lidia 25 4. Declaration of Dilsia R- 29 6 5. Declaration of Josselin 33 7 6. Declaration of Keylin 37 8 7. Declaration of Iris 41 9 8. Declaration of Dixiana S- 46 10 9. Declaration of Maria Angela 50 11 10. Declaration of Ana Vilma 54 12 VOLUME 2 13 11. Excerpts of Exhibits 58 14 VOLUME 3 15 12. Declaration of Cristobal 224 16 l3. Declaration of Delmis 229 17 14. Declaration of Justin 233 13 15. Declaration of Mayra s_ 242 19 16. Declaration of Ruth 246 17. Ornmitted 20 18. Declaration of Bridis 250 21 19. Declaration of Lourdes 254 22 20. Declaration of Blanca 257 23 21. Declaration of Brandon 8? 262 24 22. Declaration of Fatima O- 265 25 23. Declaration of Nohemi 269 24. Declaration of Doris M- 272 26 25. Declaration of Karen 3? 276 27 26. Declaration of Jefferson 281 28 PLAIN TIFF RESPONSE TO FIRST JUVENILE COORDINATOR REPORTS CV 85 (AGRX) Case Document 459-4 Filed 07/16/18 Page 4 of 89 Page #:18529 27. Declaration of Daise 285 28. Declaration of Alejandra 289 29. Declaration of Dinora 293 30. Declaration of Leydi 298 VOLUME 4 31. Declaration of Floridalma 302 32. Declaration of Anet 309 33. Declaration of Sindy s? 314 34. Declaration of Timofei F- 318 35. Declaration of Cesar 323 36. Declaration of Kevin 329 37. Declaration of Ana P- 338 38. Declaration of Alma 342 39. Declaration of Marlyn 346 40. Declaration of Jeydi 1? 353 41. Declaration of Tarino A- 356 42. Declaration of Denia 361 43. Declaration of Manuel 367 44. Declaration of Alma 374 45. Declaration of Abidalia 37s 46. Declaration of Gladys 382 47. Declaration of BaljitK- 385 48. Omitted 49. Declaration of Edgar 390 50. Declaration of Ermita 394 VOLUME 5 51. Declaration of Fanny Damarys 397 52. Declaration of Nery Baltazar 401 53. Declaration of Selena 404 54. Declaration of Victor 408 55. Declaration of Yeimin 413 2 RESPONSE TO FIRST JUVENILE COORDINATOR REPORTS CV 85-4544-DMG (AGRX) PageID 1 56. Declaration of Anghelo 419 57. Omitted 2 58. Declaration ofSergio _426 3 59. Declaration ofDennis _430 4 60. Declaration of Emilson 434 5 61. Declaration of Erick 437 6 62. Declaration of Gladys 1? 444 7 63. Declaration ofMarcedonio P-447 8 64. Omitted 9 65 Declaration of Sandra_ 451 66. Declaration of Elmer 455 10 67. Declarationononain_. 460 11 68. 12 69. Declaration 466 13 70. Declaration of Geovany 469 14 VOLUME 6 15 71. DeclarationofRicardo 472 16 72. Declaration of Abilio 1? 475 17 73. Declaration ofltzelC-W .. 473 18 74. Declaration of Deny 481 75. Declaration of Bartolo 484 76. Declaration of Minta 487 20 77. Declaration of Noe 490 21 78. Declaration of Rony 493 22 79. Declaration 496 23 80. Declaration of Otoniel 499 24 81. Declaration of Pedro 502 82. Declaration of Lester 505 83. Declaration of Carol 508 26 84. Declaration of Cindy 513 27 85. Declaration of Edwin 518 28 so. Declaration ofElvi 0?525 19 25 RESPONSE TO FIRST JUVENILE COORDINATOR REPORTS CV 85-4544-DMG (AGRX) Case Document 459-4 Filed 07/16/18 Page 6 of 89 Page ID #:18531 87. Declaration ofGregorio 532 88. Declaration ofDenis 536 89. Declaration ofJuanC?542 90. Declaration of Lucia 549 91. Declaration ofNorin _554 92. Declaration ofSkarleth _559 93. Declaration of Carol 8? 564 94. Declaration of David 572 95. Declaration of Elry 579 VOLUME 7 96. Declaration of Eydi 582 97. Declaration of Jesica 585 98. Declaration of Katherine 591 99. Declaration of Kevin 599 100.Declaration of Miguel 606 101. Declaration of Rebecca 613 102. Declaration of Yonder 619 103. Declaration of Elmer 626 104. Declaration of Deny 630 105. Declaration of Juan 634 106. Declaration of Horacio 638 107. Declaration of Melannie o? 642 108. Declaration of Vicenta 647 109. Declaration of Miriam 650 110. Declaration of Loida 653 111.Declaration ofLoida 656 112. Declaration of Genoveva 659 VOLUME 8 1 13. Declaration of Aurelia 662 114. Declaration of Ana 665 115. Declaration of Celestino 668 116. Declaration of Jose 671 4 RESPONSE TO FIRST JUVENILE COORDINATOR REPORTS CV (AGRX) Case Document 459-4 Filed 07/16/18 Page 7 of 89 Page #:18532 117. Declaration of Braylin 674 118. Declaration of Ventura 1? 677 119. Declaration of_ 680 120. Declaration of Christy 683 121. Declaration of Graisy 1_ 686 122. Declaration of Martin 689 123.Declaration ofEdras 692 124.Declaration ofElena 125.Declaration of Heydi 17? 698 126. Declaration of Magdalena 701 127. Declaration of Jorge 704 128. Declaration of Manuel 708 129. Declaration of Mauricio 711 130. Declaration ofRosalvaP-W . 716 131. Declaration of Owen 721 132. Declaration of Alexander 725 133. Declaration of Sera?n S. 728 134. Declaration of Kimberly 732 135. Declaration of Michelle 736 VOLUME 9 136.Declaration ofOrlando 740 137. Declaration of Vanessa . 743 138. Declaration of Alexander 747 139.Declaration of Hazlyn 751 140.Declaration ovaa 3?755 141. Declaration of Gladys 759 142.Declaration of Maria 763 143.Dec1aration of Lexyer 767 144.Declaration ofCesia B- 771 145.Declaration ofAlan c_ 775 146. Declaration of Juan 780 147. Declaration of Edwin 784 RESPONSE TO FIRST JUVENILE COORDINATOR REPORTS CV (AGRX) Case Document 459-4 Filed 07/16/18 Page 8 of 89 Page ID #:18533 148. Declaration of Leticia 788 149.Declaration of Sandeep S- 792 150. Declaration ofManish K-796 151. Declaration of Devis 800 152. Declaration of Sachin 803 153. Declaration ofRaul 807 154. Declaration of Yasmin 810 155. Declaration ofDiXia 813 156. Declaration of Angel 817 157 Declaration 822 158. Declaration of Lesv1a 825 159. Declaration of Patricia 828 160.Declaration ofAlba s_833 841 163. Declaration ofLizethR-. 844 164. Declaration ofMaira 847 165 Declaration of Yenny 850 VOLUME 10 166. Declaration ofBrenda 853 167. Declaration of Griselda 857 168.Declaration of Keila 861 169. Declaration of Rosa P- 865 170. Declaration of Saudi s? 869 171. Declaration of Santos 872 172. Declaration of Sandra 876 173. Declaration of Wendy 879 174. Declaration of Dulce 883 175. Declaration of Maria 887 176. Declaration of Herlinda 891 177. Declaration of Yoj ana 895 178.Declaration ofV11ma_ 899 RESPONSE TO FIRST JUVENILE COORDINATOR REPORTS CV (AGRX) case Db'cument 459-4 Filed 07/16/18 Page 9 of 89 Page #:18534 179. Declaration of Noredith 903 180. Declaration ofRocio ..907 181. Declaration of Iris E- 911 182. Declaration of Mirza 0_ 916 183. Declaration of David 920 184. Declaration of Noliba 924 185. Declaration of Bryseyda 928 186.Dec1aration ofAlbaP_ 932 187. Declaration of Josue 936 188. Declaration of Sara 939 189.Declaration of Beysi 943 190. Declaration of Besy 947 VOLUME 11 191. Declaration of Blanca 952 192.Declaration of Gladis 3? 956 193. Declaration of Lucia 960 194. Declaration of Maria 965 195. Declaration of Nora 969 196. Declaration ofSonia 974 197. Declaration of Yerica 979 198. Declaration of Esperanza 984 199. Declaration of Maria del 989 200. Declaration of Glenda 992 201 . Declaration of Maira 996 202. Declaration of Jessica 1000 203. Declaration of Karla 1004 204. Declaration of Madelin 1007 205 Declaration of Claudia 1010 206. Declaration of Yaneth 1013 207 .. 208. Declaration of Gabriel 1020 209. Declaration ofMateo A?u. RESPONSE TO FIRST 1U VENILE COORDINATOR REPORTS CV 85-4544-DMG (AGRX) Case Document 459-4 Filed 07/16/18 Page 10 of 89 Page #:18535 210.Declaration ofDanie1H?1027 VOLUME 12 211.DeclarationofFe1ipe_ 1031 212.Declaration of Leonardo 1035 213.Declaration ofMaudin 214.Declaration ofEdwin 1042 215.Declaration of Victor 1046 216. Declaration of Gustavo 1050 217. Declaration of Romeo 1054 218. Declaration ofWilder . 1058 219. Declaration of Jhony 1062 220. Declaration of Luis 1065 221 . Declaration of Sayra 1068 222. Declaration of Roger 1071 223.Declaration ofDiego 14-1074 224. Declaration of Kevin 1078 225. Declaration of Elmer 1083 226. Supplemental Excerpts of the Deposition of Phillip Miller 1087 RESPONSE TO FIRST JUVENILE COORDINATOR REPORTS CV (AGRX) Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 11 of 89 Page ID #:18536 Exhibit 12 224 and correct to the best of l. 10. 11. Case Document 459-4 Filed 07/16/18 Page 12 of 89 Page ID #:18537 I of CRISTOBAL Rm declare under penalty of perjury that the following is true my now ge an reco ection. My date of birth is 01/07/1988. My son?s name is - He is seven years old and he was born on 06/10/201 1. My son and are from Guatemala. I, CRISTOBAI. We left Guatemala because I was facing discrimination from the Spanish speakers. I was assaulted at gunpoint when driving a taxi. My seven year old son was there. They asked me questions about my job and demanded half of my salary. I believe they were gang members. After that, they sent me threatening notes at my home. They physically attacked me but we were able to escape. They called me offensive names used to refer to people like me who do not speak Spanish as our ?rst language. We ?ed Guatemala in fear and were detained together at the border about six days ago near El Paso, Texas. I believe that it was on about 06/23/2018. We were taken to a facility nearby. We were handed a two page document in Spanish and were told that we needed to sign them by an of?cial who spoke only English. I signed because they made us sign, one by one. They gave us about ?ve minutes to read it but I could not fully understand it because I have a limited education. We do not have a copy of this document. They only asked us for some information and locked us up. We were not provided a list of free legal services. The of?cers at the facility did not speak any Spanish and they spoke to us only in English. I did not understand anything that they were saying except the word ?Guatemala.? My son and I stayed together all the time, in the same cell with ten other people. We had a sink and toilet in the same room. We all had to share the same bathroom and use it in front of everyone. We had no privacy. The room was about two by three meters. We did not have access to a shower. There was no water for us to drink. We were thirsty and we would ask for water and they would tell us to drink from the sink above the toilet. We did not get any clean water that entire time. My son only got one juice. They did not give us food. We could not shower. We were not given clean clothes. The cell was very cold. The air conditioner was very strong so it was freezing in there. We slept with aluminum blankets. We slept on the hard ?oor and did not have mattresses. There were some rooms with mattresses and some with mats. The of?cers would not turn off the lights. We did not have a sense of what time of day it was, whether it was daytime or nighttime. I felt very confused. Page 1 of 4 225 12 13. 14. 15. l6. l7. 18. 19. 20. 21. 22. Case Document 459-4 Filed 07/16/18 Page 13 of 89 Page ID #:18538 . After about ?ve hours, from 11PM to 4AM, my son and I were taken to another facility by bus. This happened on 06/24/2018. The trip was about twenty minutes. We were held for two days and two nights. My son and I were always together during this time. 1 received two sheets of paper that had my legal rights and my son?s legal rights. They were written in Spanish and they gave us time to read it and sign it. However they did not give us a a copy of either of these papers. We were not provided a list of free legal services. They gave us two minutes to call my family to inform them that I had been detained. The of?cials spoke English so I could not understand them. The room that we were in had a toilet and a sink in it, similar to the ?rst facility that we were at. There was very little privacy. They did not give us water, so I had to drink water from the sink. They gave us two disposable cups that we had to use for the time we were there. I received two disposable cups and my son received two. The water tasted like it had a lot of bleach in it. It also smelled like bleach. I remember my son being very thirsty because he could not drink the water. He complained that it tasted too much like bleach to drink. I saw an of?cial with pure water and my son and I begged him several times for water, but he refused and kept telling us to use the sink. My son is seven years old. They gave us three meals, which consisted of whatever food was left over in the facility. Sometimes it was bags of ?sh and cookies, sometimes it was burritos. Some of the bun?itos they gave us were reheated and very dry. My son and the other children would not be able to eat this food and so they were always hungry. Some of the of?cials there would not feed the children if they were sleeping, so some children had to skip meals. This happened to my son and me. I tried to ask for his meal so that I could give it to him later, but the of?cer refusedeat that meal. They did not let us shower for days. Before we were transferred to Berks, we were given ?ve minutes to shower. We were not given clean clothes. Prior to this they took the toothpaste that I had from my journey and threw it in the trash. We could not brush our teeth. This facility was also very cold, similar to the ?rst place that we stayed. They had two mats in the cell. The result of us had to sleep on the ?oor. We had aluminum blankets like the last place. My son slept on the ?oor with me. There were seven adults and seven children in the same cell. The size of the cell was about the same as the ?rst one we were in, about two by three meters. They always had the lights on like the last place so it was very dif?cult to sleep and we could not tell what time of day it was. One of?cial turned off the lights for one hour because the children were still awake and playing. My son and were taken out of that facility on approximately 06/26/2018 and were transported together to the Berks facility. We received a written notice about our rights in Spanish but it was not explained to my son who is under 14. We did not receive any written notice about our right to a hearing before an immigration judge. We did not receive any information about a hearing for my son nor any information about any bond opportunities. We also were not told about any possibilities to be released on certain conditions. They Page 2 of 4 226 Case Document 459-4 Filed 07/16/18 Page 14 of 89 Page ID .18539 told us to Sign a paper in Spanish that told us why we were being housed here but I do not have a copy of it. 23. While at the Berks Facility I have spoken with somebody from an organization that I do not remember. We spoke for about ten minutes about my fear to return to my country. The officials at the facility say that I need to wait until someone from immigration comes and I can talk to them more about my situation. I do not know when I will have my interview. 24. My son and I have been at the Berks facility for about three days. We are waiting to have our interview. I, Cristobal swear under penalty of perjury that the above declaration is true and complete to the best of my abilities. This declaration was provided in Spanish, a language in which I am ?uent, and was read back to me in Spanish. Page 3 of4 227 Case Document 459-4 Filed 07/16/18 Page 15 of 89 Page ID #:18540 Ceru?cate of Translauon I, Guadalupe Aguirre, certify that I am ?uent in English and Spanish and that I read the above declaration to 465 Guadalupe A g??rrc Empire usticc Center 30 South Broadway, 6?h Fl. Yonkers, NY 10701 00 307? Date Page 4 of4 228 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 16 of 89 Page ID #:18541 Exhibit 13 229 Case Document 459-4 Filed 07/16/18 Page 17 of 89 Page ID #:18542 Declaration of I, Delmis declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. 1. My date of birth is February 12, 1993. My son?s name is? and my daughter?s name is? My daughter is 9 year old and was born on April 19, 2009. My son- is 2 years old and was born on August 11, 2015. My children and I are from Honduras. We all left Honduras because our lives are being threatened due to our political beliefs. I would participate in political protests which prompted life threatening messages sent to my home and being gassed on multiple occasions. We presented ourselves at the border about June 6, 2018. We crossed the border and walked for about 10 minutes before the border patrol stopped us. We were taken to the ?dog house? that same day. At the dog house, we were brought in soaking wet since we had just swum across river. When we walked into the dog house, it was awful. My daughter was crying because she was wet and freezing. We were given almninum blankets but that was not enough to temper the cold air in the dog house. We wore the same wet clothing for two days. The cold was unbearable. My son is still suffering from a terrible cough and cold from how cold the dog house was those 4 nights. It was impossible to sleep. The guard would come in and check on the people at all hours of the night. They never turned the lights off so it was impossible to get rest. The guards would come in every 1.5 hours. Some guards were better than others. Certain guards would yell at us and lose their patience because we could not understand them. There were 8 women in my cage at the dog house. It was very tight quarters because all eight women had their children with them as well. The food was limited. The adults were given reheated burritos that tasted stale. I could barely eat the burrito. The kids were given chicken with some pasta. However, the worst thing was the water. I had to plug my nose to be able to drink it. It came out of the faucet and smelled terrible. I only drank a small amount of water when really thirsty because the water tasted very bad and the smell was terrible. I was at the dog house for two days before they took us to another facility for a shower. That was the ?rst time that we were offered clean clothes. We later returned back to the dog house. We spent a total of four days in the dog house. This has been the worst four days of my stay in the U.S.. I believe that it was on or about June 10, 2018, that we were transferred by bus to ICE facility in Dilley, Texas. The treatment at the ICE facility has been better than the treatment at the dog house. There was no medical attention available at the dog house. We did not see a doctor until we arrived at Dilley. Page 1 of 3 230 Case Document 459-4 Filed 07/16/18 Page 18 of 89 Page ID #:18543 8. Upon arrival, we were given food and medical attention. However, the medical attention here is tough because it takes hours to get medication. They do not consider emergency situations over less urgent situations. My son has had a strong cold, including a fever and sometimes his fever spikes high and I am far down in the line. It takes up to two hours to get him medication. 9. I was not given any information about legal services until we arrived at Dilley I, Delinis swear under penalty of perjury that the above declaration is true and complete to the best of my abilities. This declaration was provided in Spanish, a language in which I am ?uent, and was read back to me in Spanish. P. I A . Date Page 2 ol'3 231 Case Document 459-4 Filed 07/16/18 Page 19 of 89 Page ID #:18544 Certi?cate of Translation 1, Luisa Muskus, certify that I am ?uent in English and Spanish and that I read the above declaration to Delmis in Spanish. I {fa Muskus Orrick, Herrington and Sutcliffe 609 Main St. Houston, Texas 77002 0t, llaixf? Date 232 Page 3 of 3 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 20 of 89 Page ID #:18545 Exhibit 14 233 Case Document 459-4 Filed 07/16/18 Page 21 of 89 Page ID #:18546 (backwash - '1 I I ,1 A k-?(\QCoKch?x?Qx?. \?dM 13 s?SkM we Aex a gs c1 60/1005. \2 ?avg m. \Ne? S\\Jk??Q?r .. SW53. . Qw ?Cm-*4 ?szf?morkag .. CQDQE 9T5v\% ?qmokx?rx CW \?rx . Safe; meme ?>611 0% We?vna??c~ :3sz0. s4.\ we"? [{me Katee/1? q. \wk We?; (hi MSW 0; \33 .. CA. $91. (:39le gm \Noap ., 0A2 \Q?Ovm? . 234 Case Document 459-4 Filed 07/16/18 Page 22 of 89 Page ID #:18547 QawA March; ?r my Q4?Ar_m?gd?~ 3M.) e\quz A D\t Ra? 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A .- ,w Gui- a YOw/hf L40 MPGa/nv ki/70 Orn/ol 2A. n< DkW/l b- . /nmv Ada/(pk fulfL Egg/P a) I 11.? w? {inw/IM - 00232; 30$ Ema odpm?m Umcm mu 9? mo Umom 353% :Cx/Var/ ?(My may/3 (an/m VPHWI. 0.1?v {094% me/J 33?. 7V .. A44 We mp4 (40% t. O/anxn! ng O). <4/70rl .KV WELT 9404/ $0.64 770419970 {bx/P1,; Lay/n} V4.93 ET XV (CAN 9GP Wxipfn. 9/1 Em. Par/Ti Pro/B V9 .UN :01/u UP x/Io (.th 3D . ?avA/VbV gm Wm ?/nymf/ .. Ru! {v $1 /Voa?uw.r ?fe/V Y0 25 (WJ EVC 90 /r0v Nab Case Document 459-4 Filed 07/16/18 Page 28 of 89 Page ID #:18553 Certi?cate of Translation I, Michael Bochenek, certify that I am fluent in English and Spanish and that I read the attached declarationto . 0 Spanish. WW Michael Bochenek Human Rights Watch 350 Fifth Avenue, 34?h Floor New York, New York 10118 (718) 724 9016 Dated: McAllen, Texas June 3? ,2018 241 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 29 of 89 Page ID #:18554 Exhibit 15 242 Case Document 459-4 Filed 07/16/18 Page 30 of 89 Page ID #:18555 Declaration of Mayra I, Mayra declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. 1. I was born on April 14, 1989 in Mexico. My son?as born on March 24, 2009. He is 9. My daughter ?Was born on October 10, 2015. She is 2. They were both born in Mexico. 2. I came to the United States because my family was threatened by gangs. I traveled alone with my children. I was also ?eeing domestic violence. 3. On May 31, 2018 at 1 pm, we crossed the bridge at Nogales and told the immigration of?cials that we were seeking asylum. They asked for my children?s birth certi?cates and my identi?cation. They took the information and directed me to an of?ce. At the of?ce, they took our belongings and searched us. There was a table with cups of water, cookies, and small boxes of cereal. 4. We were put in a small cell with ten other people, all women and children. There were three benches and no room to move around. There was a large trash can, but no toilet or sink. It was very cold and each of us only had an aluminum blanket. We went to get mats to sleep on, but there were not enough and I was only able to get mats for my children. 5. The of?cials allowed me to make a phone call. They gave me papers to sign but did not tell me what they were. 6. The of?cials woke me up at 2am to ?ngerprint me. I had to wake up my son as well to be fingerprinted. 7. The next morning at 10am we left the immigration of?ce. It was a ?ve-hour drive. My daughter asked the officer for water and he refused. 8. An hour later, we arrived at another of?ce and were given water that smelled and tasted dirty. We did not drink it. We were taken to a room with an open toilet. There was a camera above it. My son used the toilet, but my daughter did not because she felt uncomfortable. The room was very dirty. We were there about an hour. Page 1 of 3 243 Case Document 459-4 Filed 07/16/18 Page 31 of 89 Page ID 556 9. After a long drive, we were locked in another cell. I begged for water for my daughter but the officials would not give us any. My daughter started crying. The officers told me to shut her up. They gave us ham sandwiches that were bad, and a container of foul?tasting water. 10. The cell was extremely cold. We were each given thin mats and rough, dirty blankets. We were till freezing. The room had a bench and open toilet, which meant there was not enough room to sleep. I asked for water and explained that the water in the container tasted bad. The officer brought more water but it tasted the same. 11. I was menstruating and asked to shower alone, but the of?cer refused and forced us to shower together. There was some soap on the ?oor, but we were not given toothbrushes or toothpaste. 12. The morning of June 2, we were given sandwiches and nothing to drink. We went in a car to the airport and ?ew to Karnes. At the airport, they threw away all our clothing and personal belongings and gave us new clothes to wear. 13. When we arrived at Karnes, I was told that we have the right to a lawyer and given a list of lawyers. We were given a sandwich and water bottle. It was not enough water and we were very thirsty. It had a lot of chlorine. 14. My daughter was given pants which were too big for her. When I asked for a smaller size, the woman told me that they don?t have tight pants here like in my country. She was very rude. 15. My son is badly traumatized. He has been wetting his bed and is fearful all the time. He saw someone bound with chains and asked me whether I would be chained in the same way. He also overheard a woman say that she had been separated from her children, and asked me whether we would be separated as well. He wonders when we will get to the United States. I do not tell him that we are already here. He wouldn?t believe that the United States would treat us this way. 16. My son had the chance to talk to his uncle, who told him that there is a present waiting for him. When we were placed in deportation proceedings, I told my son that we were going back home. He is upset that he will not get to see his uncle and get his present. 17. He tells me not to cry and that things will be alright. He is trying to protect me and his sister while also experiencing his own trauma. This entire experience and the push pull of the roles he has is sure to give him long-term problems. After screening, he has quali?ed here for services due to the extent of his trauma. He begins his treatment on Friday. Page 2 of 3 244 Case Document 459-4 Filed 07/16/18 Page 32 of 89 Page ID 18. My daughter has serious trouble sleeping. They won?t allow me to give her formula in a bottle, saying she is too old. She is accustomed to having a bottle at night which she sucks for comfort. She needs that more than ever. It might help her sleep as it is calming. I, Mayra swear under penalty of perjury that the above declaration is true and complete to the best of my abilities. This declaration was provided in Spanish, a language in which I am ?uent, and was read back to me in Spanish. Date Certi?cate of Translation 1, Ana Bueno, certify thatI am ?uent in English and Spanish and that I read the above declaration in Spanish to Mayra a ueno Date Page 3 of 3 245 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 33 of 89 Page ID #:18558 Exhibit 16 246 Case Document 459-4 Filed 07/16/18 Page 34 of 89 Page ID #:18559 cl i RUTH 1, Ruth ?declare under penalty of perjury that the owmgis true an correct tot esto my knowledge and recollection. 1. I was born on December 25 1989 in Honduras. My son i? _e was born on November 21, 2010 and is 7 years old. 2. We came to the United States due to violence. My stepfather is a gang and he and other gang members tried to rape me. 3. We entered the United States on June 4, 2018 at Hidalgo, TX. Immigration of?cers found us. They did not ask us anything or tell us any information. The ?rst time I was called with my son was when we were at the station. They called us and asked us our name, date of birth, took our picture, and they took our ?ngerprints. 4. We were taken to a building where we stayed for three days. I was put in a room, and the of?cials took my son to another room. They told me he could not be with me. I told them he had a fever, but the of?cials told me that it was not really a sickness. They only wanted to know if he had something like high blood pressure. 5. They put me in a room that was freezing. It had a concrete ?oor and cement benches. There were around 30-40 women. Around half had their children with them. There was a baby who was only 1 year old. The women told me that children who are under around 6 stay with their parents. 6. The children in our room couldn?t sleep because of the cold. They were crying the whole time. We got aluminum blankets but they didn?t help much. 7. We received a sandwich three times a day, but the meat was bad and made the children?s stomachs hurt. The children also got cookies and juice for snacks. We had a thermos of water, but it was bad quality and had too much chlorine. My son later told me that the water was nasty and he did not drink it. There was not enough water for all of us. 247 Case Document 459-4 Filed 07/16/18 Page 35 of 89 Page ID 8. 10. ll. 12. 13. #:18560 The children in the room got sick. They vomited, coughed, and had fevers. The women with children were not allowed to bathe them. The of?cials asked if the children needed medical attention, but told their mothers that coughs and fevers were not real sicknesses. They would not provide medicine. I was so afraid that my son, who already had a fever, would get sicker due to the cold. They called me to talk to an of?cial on the second day. He told me I would have a hearing, but did not tell me that I could have a lawyer or how to ?nd a lawyer. He gave me a phone number and told me that I could call if I had been separated from my son. I got really scared that they might take my son and I wouldn?t be able to ?nd him. I saw my son a couple times at a distance but I never got to speak to him. I was terri?ed. I did not know if they would hit my son. I worried that he would not be able to sleep without me there. Later that day, I saw the of?cials leading my son somewhere. I asked where they were taking him, but they would not tell me. For 24 hours, I had no idea where was devastated. On the fourth day, June 7, I was taken to court. They shackled my hands and feet and put me on a bus with 25 men and women who were all shackled. We were on a bus for two hours. I still did not know where my son was and was terri?ed. At the court, they told me that I had the right to a hearing. I was assigned a lawyer for the ?rst time. I only talked to the lawyer for about ?ve minutes before the judge came. The judge told me that I could plead guilty or not guilty, but I would need evidence to show that I was not guilty. They said I was guilty if I crossed the river. I said that I had crossed the river, so I declared myself guilty. All the parents asked about their kids, but the judge said he was not there to handle the children. He was just there to sentence us for the crime of crossing the river. The judge declared us ?not guilty? and I was returned to the perrera. Shortly a?er we got back, a nice of?cial looked to see if my son was still in the perrera. After I found out he was there, he took me to see my son. He was in a cell with other children and he was crying. After that, they allowed me to stay in the same cell as- 248 Case Document 459-4 Filed 07/16/18 Page 36 of 89 Page ID #:18561 I stayed in the perrera in the same cell during four days. He was given three meals a day. He was usually given a milk, fruit, juice and either a burrito or sandwich. He was also given a snack, usually a juice and a cookie. lie ate all the food he was given. He was always hungry and this was not enough food for him. The aluminum blankets were not enough and he was still cold. They did not ask if he was sick nor did he get any medical attention, It was hard to sleep, we were always woken up throughout the day. It was always noisy. Either people were being yelled at or people were crying, especially children due to separation. The of?cials would also kick people if they did not wake up when they were called to go somewhere. IS. -was given a change of clothes and they washed his muddy clothes. 16. After the perrera, we were both transferred to Dilley and we have been here 20 days. She has seen CARA lawyers. have asked for asylum but my case was denied and CARA lawyers appealed. My case was approved today, June Her aunt is her sponsor and she lives in Manchester, NH. 1, Ruth _swear under penalty of perjury that the above declaration is true and complete to the best of my abilities. ?l?his declaration was provided in Spanish, a language in which I am ?uent, and was read back to me in Spanish. Date Qertl?cate of Translation l, Yolanda Rodriguez, certif that I am ?uent in English and Spanish and that I read the above declaration to Ruth _in Spanish. Yolanda Rodriguez . I I- (l L. Date? 249 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 37 of 89 Page ID #:18562 Exhibit 18 250 Case Document 459-4 Filed 07/16/18 Page 38 of 89 Page ID #:18563 mus-WA? (I, declare under penalty of perjury that the following is I, BRIDIS true and correct to the best of my knowledge and recollection. 1. My date of birth is December 8, 1994. My son?s name is? He is 4 years old and he was born on July 10, 2014. My son and I are from Honduras. We left Honduras because my sons step?dad was part of the MARA 18 (gang) and I didn?t know. He threaded to kill me and my son if I left him. He became physically and emotionally abusive. We presented ourselves at the border about June 15, 2018. When I was apprehended by Border Patrol I was asked if anyone else was with us. We had walked hours trying to turn ourselves in. We were tired and thirsty. My baby was dehydrated. I begged for water and although the of?cer had some he denied me water. We sat down and waited for another of?cer to come. He had water and gave us a small cup of water but it wasn?t enough. . After about an hour we were taken to the ?Yelera?. At the yelera I were asked questions and processed with ?ngerprints and pictures. I was not told my rights, not that I had a right to a lawyer or a phone call. They did provided us with juice only to drink and an alumn blanket, but no food at all. We were put in a small room with about 25 other mother and children. There was no space to sit or lay. The room had two toilet seats with no privacy and no sink. Around the wall there was like a cement bench where people could sit but they were full and crowded. The temperature was extremely cold. Children were crying at all times. A lot of children including mine were shivering. Human heat was not enough to warm the babies. Hours later like at 8-9pm we were called and transported to the ?perrera? in a mini-bus with about ten other people. When we arrived I had an interview with an immigration of?cer who asked me questions like why did I leave my country. I told him why. I also told him that I that I had an accident where I hit my head that causes me headaches and short term memory. He then screamed at me and told me I was lying and that he was going to deport me immediately. I started to freak out. I didn?t want to go back to my country. I was frighten. I was sent back to my cell where I was given two aluminum blankets and two mats. There was a lot of crying in there too. We were not given food. Restrooms were over?owed and smelled terrible. I was there 4 days and couldn?t sleep with the cold temperatures. Of?cers also told us to not sleep profoundly. I once over slept and woke up late to get breakfast and was denied. Of?cer sent us back and told me to wake up on time next time. Food was provided three times a day. Usually a nasty sandwich, water, and an apple. My son didn?t eat much of it. The little he did it made him sick. I was not told about my rights or rights to a lawyer or phone call. I asked if I could make a phone call but was denied. I was not allowed a shower until the day before we came to Dilley. I was given a toothbrush, toothpaste and towel for my son and l. Page 1 of 3 251 Case Document 459-4 Filed 07/16/18 Page 39 of 89 Page ID #:18564 9. On the fourth day we were put in a big bus with about twenty other people. It was about four hours away. 10. The day we arrived at Dilley we were treated very nicely. We received new clothes, shoes, toothpaste, toothbrush, towels, combs, food, medical exams, and nice comfortable beds. We were allowed a shower and our rights were told our rights, told me I had a right to a lawyer and provided me with a list of many lawyers. We haven?t gotten sick. We are treated well and my son seems comfortable. I just want to leave and feel free. 1, swear under penalty of perjury that the above declaration is true and complete to the best of my abilities. This declaration was provided in Spanish, a language in which I am fluent, and was read back to me in Spanish. ob HZ Date Page 2 of 3 252 Case Document 459-4 Filed 07/16/18 Page 40 of 89 Page ID #:18565 Certi?cate of Translation I, ANA BUENO, certify that I am ?uent in English and Spanish and that I read the above declaration to BRIDIS in Spanish. Ana 8W in ?g Page 3 of 3 253 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 41 of 89 Page ID #:18566 Exhibit 19 254 Case Document 459-4 Filed 07/16/18 Page 42 of 89 Page ID #118567 Declaration of mums?Amm? I, Lourdes number_), declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. 1. My date of birth is September 17, 1989. My daughter?s name is She is 5 years old and he was born on January 9, 2013. My daughter and I are from Honduras. 1 left my country of origin due to fear of violence against myself and my daughter by the Maras gang. I was once chased down and assaulted by the Maras (and was knocked unconscious) and my daughter suffered an attempted kidnapping on one occasion by the Maras. We presented ourselves at the border in Reynosa, Mexico on or about May 4, 2018. We were taken to a facility known as the Perrera (Dog House). Conditions at this facility were de?cient on various fronts; Food was scarce. We were fed a burrito, chips and one bottle of water for breakfast and lunch and one ham sandwich and a bottle of water for dinner. We were not fed anything else. Hygiene at his facility was very poor. We were not allowed to shower except for once in six days and toilets were dirty and over ?ooding every day. After six days in this facility, my daughter and were taken to Dilley, where we have been held for 48 days. Medical conditions at Dilley are poor, as described below. Medical care at Dilley are poor. Medical attention typically takes several hours. Lines to obtain medicine always take several hours. On one occasion, my daughter had fever and we visited the doctor?s of?ce. The ?rst doctor that helped us said that Lourdes did not have a fever and dismissed us, but this ?nding was rejected by a second doctor that we saw on the same day. This doctor told me that Dilley does not prescribe antibiotics at the facility, so despite the fact that my daughter had an infection she was only prescribed ibuprofen to reduce the fever. A?er four days of having a fever, the doctors ?nally prescribed antibiotics. In my experience, other detainees has suffered from similar experiences. During my stay at Dilley, I have not been allowed to call my family since I cannot pay for my calls. I have been told that I can ask for credit to make calls, but several other detainees have expressed that on several occasions the facility denies requests for calls. I, Lourdes swear under penalty of perjury that the above declaration is true and complete to the best of my abilities. This declaration was provided in Spanish, a language in which I am ?uent, and was read back to me in Spanish. 4s; (lla sumo June 28,2018 Page 1 of 2 255 Case Document 459-4 Filed 07/16/18 Page 43 of 89 Page ID #:18568 Certi?cate of Translation 1, Emilio Grandio Urrea, certify that I am ?uent in English and Spanish and that I read the above declaration to Lourdes _in Spanish. 4% Emilio Grandio Urrea Om'ck, Herrington Sutcliffe 609 Main St. ?oor 40, Houston, TX, 77002 Date Page 2 of 2 256 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 44 of 89 Page ID #:18569 Exhibit 20 257 Case Document 459-4 Filed 07/16/18 Page 45 of 89 Page ID #118570 Declaration of mm_ mm? 1, BLANCA declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. My date of birth is January 13, 1993. My daughter?s name is Britney She is 4 years old and was born on October 5, 2013. My daughter and I are from Guatemala, where we ?ed because of death threats and extreme violence. To start, I was repeatedly physically abused and raped by my brother-in-law for the last six years. My sister does not know because he threatened me with a gun if I ever spoke of it. My brother-in-law is actually Britney?s father and she is the product of his abuse. She does not know. He threatened to kill me if I told anyone. However, I cannot blame her for his violence towards me. I tried to tell the police about his abuse but they ignored my pleas. He owns a bar in town and even when the ?dry? law is in place for Election Day, the police allow him to serve alcohol. I have seen him threaten people with his gun and hit them in the head with his pistol when they leave his bar too drunk. He is a very violent man who the police do not bother at all. The event that ?nally triggered me leaving Guatemala was when the gangs came to our town and saw me with my daughter. The gangs asked me to join their band and when I refused, I was beaten and raped multiple times by these gang members which has left my in a state of anxiety and fear. Following those events, gang members repeatedly stalked and threatened me and my daughter. I was forced to ?ee. I have only spoken to my mother once since I left and she told me they are looking for me. I left a son in Guatemala; my mother cares for him. The gang members do not know that he is my son. They only threatened me and Britney. We presented ourselves at the border about May 24, 2018. When I crossed the border, my daughter and I walked for about 45 minutes and a man stopped us and told us he would take us to safe place with food. We were taken to the Ice House. When we got there, they took our shoe laces, searched our hair and checked our entire bodies backs and stomach. It was very uncomfortable for me particularly because I was searched by a man and I have suffered both physical and sexual abuse by men in the past. It was extremely crowded in the Ice House. There was about 35 women with children in one large room. I slept there for one night, sitting on the ?oor by the bathroom. It was very uncomfortable and extremely cold. I believe that it was on or about May 25, 2018, that I was taken to the dog house. At the dog house, I was again searched by another of?cial, which triggered much anxiety for me. I also asked for a phone call to tell my family where I was and that I was alive but the of?cial would not let me. At the dog house, it was also very cold but at least here we had a mattress to lay on. However, the of?cials would get upset if we used more than 2 aluminum blankets. I started to get sick at the dog house. I experienced headaches, chills, bodyaches, and a fever. I asked for medication for my headaches, but the of?cials told me there was no doctor on site. I did not shower for 5 days. The only bathrooms were the small plastic bathrooms that do not ?ush. The of?cials told us that there were too many people and we could only Page 1 of 4 258 Case Document 459-4 Filed 07/16/18 Page 46 of 89 Page ID 10. 11. #118571 shower after we had been there for ?ve days. I never showered at the ice house or the dog house. My daughter was also not permitted to shower. Both of us were covered in dirt and dust from our walk through the desert after we crossed the river. Up to this point, I was not given any sort of legal notice. I was not informed of any legal resources or rights with respect to Britney either. Every night they would wake us up between roll call and call all of our names by country. We would have to wake up and say ?present? at the both the ice house and the dog house. Finally, I was taken to the ICE facility in Dilley, Texas. When I arrived, I was given medical attention. We were required to wait there all day. They had to con?rm that Britney had all of her vaccines. You see a lot of sick kids here at Dilley. You see kids with chicken pox and also some throwing up in the cafeteria. Britney caught a small cold after we arrived at Dilley. The conditions are better here than the dog house and ice house, however, it is hard to get medication. In Guatemala, I took sleeping medication and medication for my anxiety and depression, but here it has been hard to get. I stand in line for 1.5 to 2 hours each time I have to get my medicine. When I arrived in Dilley, Texas, I was permitted a phone call of three minutes. I used it to call my friend who lives in the US. and he sent me a Western Union card to be able to buy more phone time. I have used the card to call my family. I also use it to go to the store but it is extremely expensive so I just eat what is given during the meal times. The food here is often heavily laden with condiments and upsets my stomach. Britney has lost her appetite a bit here - she is only eating fruits. She is nervous because the kids tell her that she may have to go back. She is terrified of her uncle who she has no idea is actually her father. Sometimes I am noti?ed that I have an appointment with a lawyer and two hours later I am told it is cancelled. So far I have spent 30 days at the ICE facility in Dilley, Texas. It is not a bad place but my depression is getting bad because it feels like a prison. Britney asks me when we will be able to leave, but I do not have an answer for her. I know that we cannot leave until the judge hears my case. I have been allowed to talk to one lawyer from CARA since I have been here. As far as legal rights, I do not understand the process completely. I know that if I am denied twice that I will have to go back to Guatemala. I do not know what will happen to Britney. They have not told me but I assume she will have to go with me. This all terri?es me and it keeps me from sleeping at night. I was interviewed by 3 ICE agents. I could not understand the ?rst two very well and ?nally the third had a translator. However, I was so nervous that I was not able to speak clearly. I was told to sign some documents but they were all in English. I am not sure what I signed. I was given copies but they are all in English. I was asked to return on Monday to see the judge but I am not sure what to expect. Page 2 of 4 259 Case Document 459-4 Filed 07/16/18 Page 47 of 89 Page ID #:18572 I, BLANCA swear under penalty of perjury that the above declaration is true and complete to the best of my a ities. declaration was provided in Spanish, a language in which 1 am fluent, and was read back to me in Spanish. Page 3 of4 260 Case Document 459-4 Filed 07/16/18 Page 48 of 89 Page ID #:18573 Certi?cate of Translation 1, Luisa Muskus, certify that I am ?uent in English and Spanish and that I read the above declaration to Blanca in Spanish. Ref? 4 (Lyisa Muskus Orrick, Herrington and Sutcliffe 609 Main St. Houston, Texas 77002 (riot-701% Date Page 4 of 4 261 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 49 of 89 Page ID #:18574 Exhibit 21 262 Case Document 459-4 Filed 07/16/18 Page 50 of 89 Page ID #:18575 Declara 'on 1' 3mm* 1, BRANDON declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. 1. My date of birth is August 1, 2003, I am 14. I am from Guastatoya, Guatemala. 2. My family left Guatemala because we feared for our lives. My father supported a local man who was running for sheriff. The man became sheri? and gave my father a job. My father did not like working for the sheriff, so he quit. Two weeks later, my father moved to the United States for a new job. The sheriff was upset that my dad quit and moved to the United States. Two or three months later, I was at home with my mother and brothers when someone shot ?ve bullets at my house. The next day, my mom submitted an application for Mexican visas. We got the visas a couple of months later and left Guatemala a few weeks later once we ?nished the school year. We took the bus from Guatemala to Tijuana and stayed in Tijuana for one night before presenting ourselves at the border. 3. My mother, my two brothers and I presented ourselves at the border on July 4, 2018 around 3:00 in the afternoon. We were taken to the San Ysidro Facility. I was separated from my mother and youngest brother. The guards then placed in a room with my older brother and about seven (6) other young men, all under the age of eighteen. I was given a thin mattress and one blanket. 4. Around 3:30pm after I arrived, I was given a cheeseburger and some apple juice. I was given the same thing for dinner around 7:00pm. Around 11:00pm or 12:00am, I was given a bologna and cheese sandwich. We have access to water at all times. I am usually hungry between my meals, but I have not been given any snacks. I like meal time because that is the only time I get to see my mom and younger brother. There is air conditioning in the room and it is very cold all day. I have to use my blanket all of the time. I would like another blanket, but I am not comfortable asking for one. 6. The lights in the room are very bright and are on all day and night. There are no windows to the outside, so I don?t know what time it is. My brother and I talk about how frustrating it is. Since I arrived, I have not been able to shower or brush my teeth. There is no soap in my room and no towels. I had a toothbrush when I came here, but they took it away when I got to the facility. No one has allowed me to brush my teeth and no one has told me when I will be able to take a shower. 263 Case Document 459-4 Filed 07/16/18 Page 51 of 89 Page ID #:18576 Certi?cate of Translation 2i [fig/J? . ceitify that I am ?uent in English and Spanish and that I read the above declaration to ER FWD cw in Spanish. Name: Meme 2ka Organization: Address: Date i 4W UWV Mme? meg . and oompwme mlx? vc declara?QFWU 1?1 0i m6 Mtim@- was WM man/h: ML ?4 WW6 264 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 52 of 89 Page ID #:18577 Exhibit 22 265 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 53 of 89 Page ID #:18578 Declaration o Fatima O I, Fatima O , declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. 1. My date of birth is 26 Feb 1991. My daughter's name is years old and was born on 2 April 2006. My daughter and I are from Honduras. She is 8 2. I left Honduras because my ex-husband was stalking me. 3. We presented ourselves at the border about May 15, 2018. I believe that it was on or about 12:00 PM. We were taken to the "dog cage" for five days. In the "dog cage," people were to sleep on mats that were two inches thick on the floor. Several babies were crying. There was no access to showers. The food was one burrito for breakfast, one burrito for lunch, and bread with a spread for dinner. On the second or third day there, my daughter soiled herself from peeing and pooping and wanted to wash her private parts. She was used to cleaning her private parts every day. I asked ifl could clean her because her underwear were soiled. The guards said, "No." They said that they only have 10 showers. She remained in her dirty underwear until we arrived at Dilley several days later. We were not able to sleep at the "dog cage." 4. The food was one burrito for breakfast, one burrito for lunch, and bread with a spread for dinner. At the "cold place" there was only bread there for eating. 5. In both places it was very, very cold. It was extremely cold in the "cold place." 6. Lights were on all the time and were never turned off, even in the night. It made it very hard to sleep. 7. After 5 days, my daughter and I were taken to another place where we were held for 1 day. 8. In the "cold place" there was only white bread with spread to eat. There was again no access to showers. People had to sleep on the floor without anything underneath. For blankets we had aluminum blankets. It was very cold. 9. I did not have legal notice until arriving to facility in Dilley. On the first day arriving to Dilley my daughter had a very bad fever and I took her to get medical help. They said that I would have to come back the next day or day after and that I should just put a rag on her head and that they could not help me that day. The next day I was able to get her to the medical professionals. 10. My daughter and I were taken out of that facility on or around May 20, 2018. 11. My daughter and I have been at the Dilley location for about 38 days. We are planning to wait to see what happens with the attorney to see ifwe have to be deported back or not. We do not know what will happen. My daughter has had to talk a lot in the court but she does not like to and asks "Mom can I please stop?'' Page 1 of3 266 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 54 of 89 Page ID #:18579 12. I am unaware of current status and keeps waiting to hear back about case status. I, Fatima O swear under penalty of perjury that the above declaration is true and complete to the best of my abilities. This declaration was provided in Spanish, a language in which I am fluent, and was read back to me in Spanish. .2. B- o(p_ l B Date Page 2 of3 267 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 55 of 89 Page ID #:18580 Certificate of Translation ·eff certify that I am fluent in English and Spanish and that I read the above declaration to Fatima Spa h Willamette University Clinical Law Program 245 Winter Street SE Salem, OR 97302 Date Pagel of2 268 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 56 of 89 Page ID #:18581 Exhibit 23 269 Case Document 459-4 Filed 07/16/18 Page 57 of 89 Page ID #:18582 . NDHEMI Malawi IMMLW vi: 9% Hed? is own. in ?u 5&st W13 kmowlufsa Ml m; W15 c?Lere. op birH/x Is m5 dam SESENH JAMS :le3 12/05. [2012- cm- 1cm QMWUK- 2 j: (42% WHWL 3: 0x W) 06 924/. Me, pour I. We.- ex 341$ "Samoan? NMQ My WW I 4.15.. new} mag-4, n. Is} 3.. J: ri?jb-J m. .7..- {Lad-4+ 3.. sigma cu?rhf'l- M. 12 um?; Laf- 4; H1 53?: bid/xiv, J: w+ Tamra?J :5 art? Av 6m.- Qrul L-r Ini? 3km. 5?;ng 11. ,5 N0 ?444? taut-J-) hT?Tf?iFu" dih- ?L?vwr* Na *hakf-ICg, but 1&1; 4-4 moi??9 ?Jr ?1?34 ?53:119.. Qer??gg W?d? gaum?rL 4 Lu My! all 11.! ?'1waan rs k-n-LarL. ?Li. MHVS-SWC. ?wk-g ?499'. Case Document 459-4 Filed 07/16/18 Page 58 of 89 Page ID #:18583 1: SW ML W5 DQW Mug Hud- Hm mkwa??e :1me :5 12. Hibia?r :Hhhas. Thu . WQS PWGEMQ ILA ox NMCL Ema/1 was PM basic: t3 SPMUEM 3W 2?2, 2018 fut-?aim: 4 gm ?5mg ?Auk +Lu+ 49(th EBSUIL ask?4) gnu.) VIA-J ?L?i?e 'l-p HPWY Na. m: 675- 373 4/5/ 271 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 59 of 89 Page ID #:18584 Exhibit 24 272 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 60 of 89 Page ID #:18585 Declaration of Doris M I, Doris M declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. 1. My date of birth is June 5th, 1976. My son's name is He is two and a half years old and was born on November 18 th , 2015. My son and I are from Honduras. 2. We presented ourselves at the border about May 19, 2018. At first we stayed at the cold facility. We stayed there for 8 days. It was very cold like a freezer. My child and I had to sleep on the floor. We all had to sleep very close to each other and it was difficult to sleep. I was only able to take one shower with my son in the 8 days that we were there. They gave us toothbrushes and toothpaste. 3. At this place we were only given one sandwich for the morning, one for the middle of the day, and one at night. There was not regular water to drink. 4. It was very cold. It was like a freezer. 5. The lights were on all of the time. In the middle of the night the lights were kept on. 6. After 8 days, my son and I were taken to another place where we were held for 9 days in the place they call the dog cage. 7. They had bottles of water and burritos for the morning and middle of the day and a sandwich at night. It was very cold and they only gave us small blankets out of aluminum. We again had to sleep on the floor on very small mats. We both could not sleep because it was so cold. We had to keep moving our bodies. My son became very sick at this place and had a fever and was vomiting. He was vomiting for 4 days. In "La Perrera," they gave him medicine to stop the vomiting. After he took the medicine, he stopped vomiting. 8. My son and I were never given any documentation regarding the law or my legal rights. I was able to speak to a lawyer once I arrived to the place in Dilley. 9. My son and I were taken out of that facility on May 26, 2018. 10. My son and I have been at the current location in Dilley for about 32 days. I was told that I am not able to stay, but my son is able to stay. My plan is to wait longer to see if I can stay. I do not know what to do. 11. The lawyers tell me that for my case I can try to wait to see what happens. It is not certain if I will be able to stay. Page 1 of 3 273 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 61 of 89 Page ID I, Doris M swear under penalty of perjury that #:18586 the above declaration is true and complete to the best of my abilities. This declaration was provided in Spanish, a language in which I am fluent, and was read back to me in Spanish. Date Page 2 ofJ 274 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 62 of 89 Page ID #:18587 Certificate of Translation I, Amber Rieff, certify that I am fluent in English and Spanish and that I read the above declaration to Doris M in Spanish. Willamette University 245 Winter Street SE Salem, OR 97302 Date Page 3 of3 275 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 63 of 89 Page ID #:18588 Exhibit 25 276 Case Document 459-4 Filed 07/16/18 Page 64 of 89 Page ID #:18589 Ala? 0 km ?a 14?? - We: _me 5/22/93? in 27}: Ssllan- +1409. S.m5 Mekmmras A . W43 qra (bait..- - g? -0me LL. ge U345. QHth-?aarel?eq . we $m ??A_oq3 5:5 . 3mg ?prom. gm Wan/{ix (Led? _Mpa/ebge ?Kiddie/cl. 04? eprrL2P+- _l we; mi Mama/65 :1 arm/L ?,hW i? My :0 ., (tame. j/3 Wig/{E7 ?7 3513ch 1:201! my ??a?/imem .. 14M .. mi}? 40:13 A .0 are we 5 PM- V1040 Wing/{1a (EM . 50745. W630 Max/26?; W3 5 Lat/?14% .. dz!) 7173 MW -0 Mam 3 41500664707 Case Document 459-4 Filed 07/16/18 Page 65 of 89 Page ID #:18590 (7 Mi (UJCL :W?g?fwm all mg iWShewthvia/f? Gum/49A (Ga/l? {of} (JJ ?jgarg?? 144,00) who/gc (Se Ck) Ratio (Ar% .17) (WL mg: a fr, sun/lad, . wt (9 bit/:7 we? L06, Wed-'1 MO gluten? bow/M 47M :2 Mgr?? mm:? 9:12?? SWEW (W eLe gifm aw am far? @269 burn. ma 64.63% ML a Cu \Hluj vw?gg: LW 5 gain! 415?; {am} a 14% W3 ow as umus ?mrotw i? She Us?? WM Wow) ?mm WM Viv-or use/L4 no Case Document 459-4 Filed 07/16/18 Page 66 of 89 Page ID #:18591 an? 3'13 Wei quay/Q I a?eqk 0M3: In Paar?rah. :3)an mac ?/Ou/Mmk\ Mj - elm/r ?a?w a- . hm ?ab/2 mw ova/g ?rm is .9342ch . Sylounok 1?5? (20?6/4? TDHK?laxtg Lao?u.) (Jo?e: She/p {$530 me??w a: 1:916 611+ he. Qf/k (Aneh_ ?Wm E94 is 051(L?91m W6 gm 51% ani: w! ?Lil 4, "Mr/kc? 279 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 67 of 89 Page ID #:18592 Certificate of Translation I, Michelle Brané, am fluent in the English and Spanish languages and I certify under penalty of perjury of the laws of the United States that I read the above statement back to _Karen B who verified that it was true and correct. _____ ___________________ Michelle Brané Women’s Refugee Commission 1012 M Street, Suite 1100 Washington DC, 20005 (202) 750 – 8596 McAllen, Texas 280 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 68 of 89 Page ID #:18593 Exhibit 26 281 Case Document 459-4 Filed 07/16/18 Page 69 of 89 Page ID #:18594 Declaration of E- I, Flor declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. 1. My date of birth is 11/27/1989. My son?s name is Jefferson _He is nine years old and he was born on 8/24/2008. My son and I are from Guatemala. 2. I left Guatemala because I am afraid to return to Guatemala due to violence by the father of my son and because I cannot survive economically in Guatemala without help from my son?s father, which he doesn?t provide. 3. We crossed the border on Sunday, June 10, 2018. It was about three days ago. I believe that it was somewhere in Arizona, but I don?t know where exactly. 4. We were taken to a Border Patrol facility about one half hour away from where we had been picked up. It was very crowded in the cell where they put me with five other women and all their kids. Neither my son or I received any rights information or a list of free legal services. I was able to make a phone call to a friend, but was not infon'ned of the right to call an attorney. 5.The food at the ?rst place they took me was adequate. G. The temperature in the ?rst place was okay, not too cold, not too hot. 7. The lights were on the whole time we were then; it wasn?t possible to know if it was day or night. 8. After one day my son and I were taken to another place where I am now, and we have been here since Monday in the afternoon and it is now Wednesday morning (1.5 days). 9. The food here is okay, but it?s not enough to fill us up. They give us a burrito, crackers and juice, and it?s the same thing, over and over. 10. It is extremely cold here. They gave us aluminum blankets that are like paper and they don?t keep you warm . It was so cold that we were shivering. 11. NeitherI nor my son have been given any rights notices or a list of attorneys. We want to talk to an asylum officer. Page 1 of 3 282 Case Document 459-4 Filed 07/16/18 Page 70 of 89 Page ID #:18595 I, Flor swear under penalty of perjury that the above declaration is true and complete to the best of my abilities. This declaration was provided in Spanish, a language in which I am ?uent, and was read back to me in Spanish. 65,73,153 Date Page 2 of 3 283 Case Document 459-4 Filed 07/16/18 Page 71 of 89 Page ID #:18596 Certifigatg of I Iansla? on 1, OF certify that I am ?uent in English and Spanish and that I read the above declaration to in Spanish. @275:an (pr/T43? Date Page 3 of 3 284 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 72 of 89 Page ID #:18597 Exhibit 27 285 Case Document 459-4 Filed 07/16/18 Page 73 of 89 Page ID De?al??g? of 1, DAISE number?), declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. 1. .19 10. My date of birth is December 3, 1979. My daughter?s name is Keylin and her A number is She is sixteen years old, and she was born on December 19, 2001. My daughter and I are from Honduras. I left my country, because my life had been threatened and I had been held up at gunpoint three times. We presented ourselves at the border about eight days ago, June 21, 2018. We were taken to the Custom and Border Patrol Facility in McAllen, Texas, which we call the Ice Box. The Ice Box was freezing, and my daughter and I were shivering the entire time. We were so cold that my daughter was miserable. We were given food, but the food was frozen and not ?t for consumption. It smelled so bad that we went hungry instead of eating it. My daughter and I were hungry the entire time we were at the Ice Box. We were give a mylar blanket but no mattress pad. After about one day, my daughter and I were taken to another facility, known as the Dog House, where we held for four days. We were immediately separated at the Dog House and stayed separated the entire time. We were allowed to talk to each other only once for ten minutes in the three days we were there. My daughter was very frightened and depressed the entire time. She is still depressed and has nightmares and a lot of anxiety because of the separation. The female guards yelled at my daughter a lot, called her names and made fun of her and the other children. The female guards would not let her sleep and kicked her to keep her awake. They also called the children ?lthy and told them not to throw anything on the ?oor the way they would at home in their country. The female guards made my daughter and the other girls strip naked in front of them and ogled the girls before their showers. My daughter was scared of the guards, because they were really angry all the time. The Dog House is even colder than the Ice Box, and my daughter and I were shivering the entire time. My daughter was so cold that she had severe pain in her leg. The guards told her that if she was hurt she would have to stay in the Dog House longer, so her daughter did not ask for medical care. The guards also would not allow the daughter to have an additional mylar blanket, so her daughter had to hide an extra blanket that someone who was leaving gave her to try and warm up her leg. We were not given mattress pads to sleep on. Page 1 of 3 286 Case Document 459-4 Filed 07/16/18 Page 74 of 89 Page ID 11. The food at the Dog House was the same as EWQ House. It was frozen and smelled badwent hungry the entire time we were there. 12. We did not have any toothpaste or a toothbrush the entire time we were at the Dog House. l3. The bathrooms at the Dog House were dirty and disgusting. We were told to continue to use them and not to make the bathrooms dirtier, even though the toilets were already over?owing. 14. We were muddy and wet when were apprehended, but we were not allowed to shower or change for ?ve days. 15. We were housed in dog cages and my daughter was constantly moved without telling me. This made me fearful for her safety and further traumatized my daughter. 16. After four days we were moved to another Ice Box, where we were reunited and where we stayed for one day. We were not given food or water the entire day. 17. My daughter acted very different when we were reunited. She was depressed and did not talk much. 18. After one day, we were moved to another Dog House that was different than the first one. We stayed at this Dog House for one day and night. We were separated again immediately when we arrived at the second Dog House. 19. The second Dog House had the same gross food as the ?rst frozen sandwiches that smelled bad. Again, we did not eat much and went hungry the entire time. 20. After the second Dog House, we were moved to the Dilley facility. 21. There are no current plans for our release I, Dasie swear under penalty of perjury that the above declaration is true and complete to the best of my abilities. This declaration was provided in Spanish, a language in which I am ?uent, and was read back to me in Spanish. Date Page 2 of 3 287 Case Document 459-4 Filed 07/16/18 Page 75 of 89 Page ID Certi?cate of Translation #118600 I, LAURA M. FLORES, certify that I am ?uent in English and Spanish and that I read the above declaration to Dasie _in Spanish. .iiama?. E5 twig LAURA M. FLORES t? RAICES 4092 TPC PARKWAY, APT 953 SAN ANTONIO, TX 78261 704 Date Page 3 of 3 288 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 76 of 89 Page ID #:18601 Exhibit 28 289 Case Document 459-4 Filed 07/16/18 Page 77 of 89 Page ID 18602 Declaration of ALEJANDRA I, Alejandra declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. 1. My date of birth is April 24, 1987. My daughter?s?name is? She is 2 1/2 years old and she was born on January 20, 2016. My daughter and I are from Mexico. I have three other children: ?who was born on October 24, 2007, _vh0 was born on September 28, 2006 and ?who was born on December 7, 2004. 2. Describe Reason for leaving country of origin. I heard reports in the newspapers about girls in the area have been kidnapped from middle schools. My daughter-s l3 and I had already kept her home from school for a year. I am worried that she would be kidnapped from school. 3. We presented ourselves at the border abOut 5 am yesterday, July 5, 2018 and we were not admitted to the facility until 2 pm. We were taken to the San Ysidro - Pedestrian West Facility. 4. The children were given food at about 3 pm. .was given chicken nuggets. The food was warm. She also received juice. Myself and my other children were provided no other food until 6:00 am the next morning. During this time, I was able to give -formula. In the morning, the children, including - were given com?akes and milk. There was a meal again at noon. The children were given cold cheese sandwiches. The sandwich was only bread and cheese. They also received small bags of carrots and celery. They also received juice. In the time that we have been here, the children have received one hot meal. 5. There is formula for-at all times? you can make that with the water in the room. There is no hot water or soap to wash baby bottles. I am using a bottle that I brought with me. 6. The water in the room is drinkable and disposable cones to drink out of are provided. 7. I am staying in a room with my four children. There are two toilets and one special needs toilet in the room. There is toilet paper available and there are feminine hygiene products. We are able to use baby wipes and diapers but there is no baby powder or anything to treat diaper rash, if it happens; There are four sinks in the room three of them are built into the toilets and one is separate. There is no soap and no paper towels. No toothbrushes and no toothpaste. There is no door on the toilet and people in the room can see the person on the toilet. There are half walls between. 8. The temperature in the facility is comfortable and it is clean. The lights are on all of the time, including at night. 9. We did not receive a mat for sleeping when we arrived. When we arrived there were approximately 5 0 people in the room and there was not any additional room for more mats. The room was very crowded. We have all received one blanket, including all of the children. It is very crowded in the room. On the Page 1 of 3 290 Case Document 459-4 Filed 07/16/18 Page 78 of 89 Page ID 03 ?rst night, my daughte-wet herself while she was sleeping because there were so many people on the ?oor that you would have to walk over people to get to the toilet. She couldn?t step over everyone. The next day some people were removed and it seems like it will be more comfortable. 10. When I arrived at the facility I was not told anything about the legal rights of my children. There is no ability to use a telephone and there is nothing posted in the facility that I can see about getting help from attorneys. 11. I am trying to take my children to my son?s godmother in California. I have provided her phone number to the customs o??icers but I do not know if they have called her. I, Alejandra _wear under penalty of perjury that the above declaration is true and complete to the best of my abilities. This declaration was provided by me in Spanish, a language in which I am ?uent, translated and written into English, a language in which I am not ?uent and was read back to me in Spanish. 71/5 Date Page 2 of 3 291 Case Document 459-4 Filed 07/16/18 Page 79 of 89 Page ID . #:18604 Certi?cate ot'Translation I, Robert Perez, certify that I am ?uent in English and Spanish and that I read the above declaration to Alejandra in Spanish. -- x, a :A??ogcrl Peng Orrick, .l-lerring Sutcli?'e 405 Howard Street San Francisco, CA 94015 24% if Daffc Page 3 of 3 292 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 80 of 89 Page ID #:18605 Exhibit 29 293 Case Document 459-4 Filed 07/16/18 Page 81 of 89 Page ID #:18606 rawn??W? e? Din/wrap ?a/m RmAvfaLS/ barn [1'17-2000- Wuhan/v7 l-er&uva, S, T?m Crs?r @6113 k? gamma? (3.963% lie/4* bu. task-I?. (0mm 4., Mn-u-e?t?nLCka IFS {run 3w drur ?0 PM 49!" 44W:~tp) (Lav-3n. Hc 66% G32 new VCLO Cam In 41?? gem w??gw SIM Cm bare-M hungck 0?6 She (ecdxe. OLA. M3: gl bu/i?C?s?odgamJ VOW we 30% EWONcle/e uu-c. ca?o 5594 ?Ha. femur UAW pg Um; 711?? Wag. 1 51,20 31/14 .quIv-fw??Zmee Dal-W [0 Wow ?e r'l'l/Q/ 5L0 64??ka 294 Case Document 459-4 Filed 07/16/18 Page 82 of 89 Page ID #:18607 14 .?wa or km) to {i A ?91.53. gm. ab?/F ban/:2 ?L?w r?nJeK [boktnr ?17? 5% hi Lug; I mg?. WM ml 11.3111 LINDA WM cl-Q rm L9 Us ?Iv-ark us Jr? ?Hm [Dr-clan: ?~me Ina/? cacti-vi 4" HM MAJ 1-4-5; WM: ??aw 61?0th mag M. \qwue kza?o? uLweH. Bf}? l'o Ste-9:9. we $11190 (Aoar M-e amt/? [bl/m CS m4 Q0654 ?3?ng J?u. :5 mo Ml Hut-1 lam/5n U?nJ?h g?mu\a/ gnu-?k H1- avg: Haz Mat DADA Mr\r W8 00? [mot/k stuw Ill/Mr: Mate. 4% aska?dmg LL Ina/g Acm?rwk Mimi: Realm/{L QM M5 Lama mm a mm mm m. ?55:15?3 ?ng . TIAMI [as/fl mm: '9 #142 wwv.Ao' 295 Case Document 459-4 Filed 07/16/18 Page 83 of 89 Page ID #:18608 Car Jm WW khan-3 mac/{Jr MIMI Lu?. For?) IwJSL1: [Cm Laura EMA vow?1w chm. wvxa? our?m. Cuba/E2 wk ?rLa?xo??Gewm. WA 9314/5! #31317;wa 296 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 84 of 89 Page ID #:18609 Certificate of Translation I, Michelle Brané, am fluent in the English and Spanish languages and I certify under penalty of perjury of the laws of the United States that I read the above statement back to _Dinora C _, who verified that it was true and correct. _____ ___________________ Michelle Brané Women’s Refugee Commission 1012 M Street, Suite 1100 Washington DC, 20005 (202) 750 – 8596 McAllen, Texas 297 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 85 of 89 Page ID #:18610 Exhibit 30 298 Case Document 459-4 Filed 07/16/18 Page 86 of 89 Page ID #:18611 Declaration of A LEYDI I, Leydi (A number?), declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection. I. My date of birth is October 27, 1985. My daughter?s name is? (A number She is nine years old and she was born on January 14, 2009. My daughter and I are from Honduras. We left Honduras to escape death threats from gang members. We crossed the border on June 2, 2018. We crossed the river with a large group in Arenosa and walked for two hours, and we finally saw some agents wearing green outfits. I think they were from immigration. They took our information but didn?t ask whether we feared to return to Honduras or if we were seeking asylum. They took all of our Shoelaces, hair ties, and our documents and put us in a bus. We drove for about half an hour and arrived at La Hielera (?The Icebox?). At La Hielera, we were put in a crowded cell with about 25 people. There wasn?t enough room for everyone to lay down except when the officials would take some people out to take their fingerprints. Then we could take a turn to lay down. It was extremely cold. All we got was a thin metallic blanket. It was very hard to wrap the blanket around my daughter and myself to keep warm. Plus, we had to sit directly on the cement ?oor, which was very cold. Laying on the floor gave me a bruise. We didn?t get any type of cushion to sit or lie on. We were barely able to sleep I couldn?t sleep at all, and my daughter only slept a little bit leaning up against my lap. The lights were on at all times. There were two bathrooms in the cell, but they weren?t private. There was only a waist high wall. Also, because the cell was so crowded there were pe0ple laying down in the bathroom area. There was a thermos with water, but there was nothing in it when we got there. I asked for some more and they gave it to us. The water tasted like chemicals. It hurt my throat. For food, all we got was a sandwich with two pieces of bread and a little slice of meat, plus juice. The sandwich was frozen. When we first arrived all we got was a cookie and some juice. There wasn?t enough food, so we were very hungry. I had to give my daughter my food so that she would have enough. My daughter was sick with a fever, so we opened the door to get a little air circulation. The guard came by and slammed it shut, and we couldn?t open the door again after that. 0 one asked if we needed medical assistance. We didn?t get the chance to shower or change our clothes. My legs were wet and muddy from crossing the river, but I didn?t get any dry clothes. When I talked to the official, all he did was take my information and fingerprints. But no one gave me any papers or information about my daughter?s rights. . The next day, June 3rd, 2018 at around 5 pm. we were taken in a bus about 30 minutes away to La Perrera (?The Dog Cage?). When we arrived there were three completely full cells. They put us in the hallway to sleep. The next day there was enough room for us there were about 30 or 35 people to a cell. In some cells there were just women, in others just children. Page 1 of3 299 Case Document 459-4 Filed 07/16/18 Page 87 of 89 Page ID #:18612 9. In La Perrera, I saw children crying in a cage. Their mothers were in one cage, and their children were in another, crying for their mothers. The youngest children were about five or seven years old. I saw a very young girl crying for her father. I?m not sure why I was not separated from my child when younger children were separated from their mothers. The mothers tried to reach their children, and I saw children pressing up against the fence of the cage to try to reach out. But officials pulled the children away and yelled at the mothers. 10. The officials were yelling at us all the time. They made us wake up three times in the night to make us line up and go through a list. In the middle of the night, they would kick us to wake us up. There were women who asked the officials not to be rude, but the officials said that it wasn?t their problem. The only thing the officials said was that it wasn?t their fault that we came to this country illegally. They said they were just following orders. They would get angry when people would share food. 11. I had a Video interview. The man on the other side asked for my information, whether I had family here, and why I left Honduras. I told him that I left because of a death threat from a gang. The next day, an official came to my cell with my file. He told me that they were going to send me to another place because my case needed to be explained more. But I didn?t get any papers with any information about my daughter?s rights. 12. On the third day at La Perrera, my daughter and I were able to take a shower. Then on June 6,2018, we were sent to Dilley, where we are currently being held. 13. At Dilley we are allowed to stay out only until 8 pm. and then we have to go to our rooms. My daughter has a cough this morning and I haven?t taken her to the doctor because I have seen that other children have gone and their coughs have not gotten better. If someone gets really sick, they have to take you to the hospital. 14. I had my credible fear interview on June 22, 2018 and received a positive determination the day before yesterday. Now my daughter and I are just waiting to be released to live with a friend who lives in Louisiana. I have been told how to ?nd out when my court date is and I plan to ?nd a lawyer and attend all of my immigration appointments so that my daughter and I can obtain asylum and be safe in the United States. I, Leydi swear under penalty of perjury that the above declaration is true and complete to the best of my abilities. This declaration was provided in Spanish, a language in which-I am ?uent, and was read back to me in Spanish. 6/28/55? Date Page 2 of 3 300 Case Document 459-4 Filed 07/16/18 Page 88 of 89 Page ID #:18613 Certi?cate of Translation I, Virginia Corrigan, certify that I am ?uent in English and Spanish and that I read the above declaration to Leydi _in Spanish- Virginia/Corrigm/ Youth Law Center 823 Folsom, Suite 700 San Francisco, CA 94107 02/ 27/1? Date Page 3 of3 301 Case 2:85-cv-04544-DMG-AGR Document 459-4 Filed 07/16/18 Page 89 of 89 Page ID #:18614 CERTIFICATE OF SERVICE 1 2 I, Peter Schey, declare and say as follows: 3 I am over the age of eighteen years of age and am a party to this action. I am 4 employed in the County of Los Angeles, State of California. My business address is 5 6 7 8 9 10 11 256 S. Occidental Blvd., Los Angeles, CA 90057, in said county and state. 
 On July 16, 2018, I electronically filed the following document(s): • EXHIBITS IN SUPPORT OF PLAINTIFFS’ RESPONSE TO DEFENDANTS’ THIRD JUVENILE COORDINATOR REPORTS VOLUME 3 OF 12 [REDACTED VERSION OF DOCUMENT PROPOSED TO BE FILED UNDER SEAL] with the United States District Court, Central District of California by using the 12 13 14 15 CM/ECF system. On July 16, 2018, I also served true and correct copies of the above documents to the interested parties by sending copies to the email address of Defendants’ Counsel, 16 17 18 19 Sarah Fabian. /s/Peter Schey Attorney for Plaintiffs 20 21 22 23 24 25 26 27 28 1