Case Document 510 Filed 10/30/18 Page 1 of 6 Page ID #:25435 1 CENTER FOR HUMAN RIGHTS CONSTITUTIONAL LAW 2 Carlos Holguin (Cal. Bar No. 90754) Peter A. Schey (Cal. Bar No. 58232) 3 256 South Occidental Boulevard 4 Los Angeles, CA 90057 Telephone: (213) 388-8693 5 Email: 6 pschey@ centerforhumanrightsorg 7 LEECIA WELCH (Cal. Bar No. 208741) 8 NEHA DESAI (Cal. RLSA Bar NO. 803161) POONAM JUNEJA (Cal. Bar No. 300848) 9 ADAMS (Cal. Bar No. 308638) 10 National Center for Youth Law 405 14th Street, 15th Floor 11 Oakland, CA 94612 12 Telephone: (510) 835?8098 Email: lwelch@youthlaw.org 1 3 ndesai@youthlaw.org 14 pjunej a@youth1aw.org 1 5 cadams@youthlaw.org 16 Listing continues on next page 17 Attorneys for Plainti??s 18 UNITED STATES DISTRICT COURT 19 CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION 20 JENNY LISETTE FLORES, et Case No. CV 85 -4544-DMG . . 21 22 EXHIBITS IN OPPOSITION TO MOTION V- TO MODIFY ORDER APPOINTING 23 JEFFERSON B. SESSIONS, Attorney 24 General, et (11., 25 Defendants. Hearmg: November 9, 2018 26 T1me: 10:00 am. Room: St. Courtroom 8C 27 28 1 Case Document 510 Filed 10/30/18 Page 2 of 6 Page ID #:25436 Counsel for Plainti?fs; continued HOLLY S. COOPER (CAL. BAR No. 197626) Co?Director, Immigration Law Clinic CARTER C. WHITE (CAL. BAR No. 164149) Director, Civil Rights Clinic University of California Davis School of Law One Shields Ave. TB 30 Davis, CA 95616 Telephone: (530) 752?5440 Email: hscooper@ucdavis.edu ccwhite@ucdavis.edu EXHIBITS IN OPPOSTION TO MOTION TO MODIFY ORDER INDEPENDENT MONITOR CV 85 Case Document 510 Filed 10/30/18 Page 3 of 6 Page ID #:25437 1 1, Carlos Holguin, declare that true and correct copies of the following 2 3 documents are attached hereto: 4 INDEX TO EXHIBITS 5 No. Description Page 6 1 Letter from C. Holguin to s. Fabian, August 10, 2018 8 7 2 Reserved 13 8 9 3 Declaration of Carlos Holguin, October 18, 2018 15 10 4 Email from S. Fabian re: Plaintiffs? experts, October 16, 2018 18 11 5 Email from S. Fabian re: background checks, October 16, 2018 23 12 5 -1 Attachment: Background Check Consent Form 29 13 6 Declaration of Amy Cohen, M.D., October 18, 2018 31 14 7 Declaration of Amy Cohen, M.D., August 26, 2018 42 1 5 16 8 HHS-DHS Memorandum of Agreement, April 13, 2018 50 17 9 Declaration of Cecilia Saco, July 14, 2018 (proposed to be ?led partially under seal) 58 18 19 10 Email from S. Fabian re: Cohen access to Shiloh, July 11, 2018 63 20 10-1 Attachment: Shiloh RTC mental health provider admission policy 69 21 22 10?2 Attachment: St. Michael?s attorney visitation policy 77 23 11 Letter from ACF to Shiloh RTC, September 13, 2018 80 24 12 Email from S. Fabian re: risk-evaluations, September 7, 2018 85 25 13 HHS Fact Sheet: Unaccompanied Alien Children Sheltered at 26 omillo LPOE, ornillo, Texas, October 12, 2018 88 27 14 Declaration of Leah J. Chavla, October 18, 2018 92 28 3 EXHIBITS IN OPPOSTION TO MOTION TO MODIFY ORDER APPOINTING INDEPENDENT MONITOR cv (AGRX) Case Document 510 Filed 10/30/18 Page 4 of 6 Page ID #:25438 29. Declaration of E., September 21, 2018 (proposed to be ?led partially under seal) 95 Declaration of E., October 8, 2018 (proposed to be ?led partially under seal) 99 Declaration of G., September 21, 2018 (proposed to be ?led partially under seal) 103 Declaration of C., October 18, 2018 (proposed to be ?led partially under seal) 107 Declaration of E., October 18, 2018 (proposed to be ?led partially under seal) 11 1 Declaration of F., October 18, 2018 (proposed to be ?led partially under seal) 116 Declaration of M., October 18, 2018 (proposed to be ?led partially under seal) 120 Declaration of M., October 18, 2018 (proposed to be ?led partially under seal) 124 Declaration of N., October 18, 2018 (proposed to be ?led partially under seal) 129 Declaration of Y., October 18, 2018 (proposed to be ?led partially under seal) 133 Email from S. Fabian to C. Holguin to S. Fabian, October 19E?mail from S. Fabian to P. Schey, October 18, 2018 144 Declaration of B., September 21, 2018 (proposed to be ?led partially under seal) 151 Declaration of 8., October 18, 2018 (proposed to be ?led partially under seal) . 156 Notice of Placement for B. in a Restrictive Setting, August 12, 2018 (proposed to be ?led partially under seal) 158 4 EXHIBITS IN OPPOSTION TO MOTION TO MODIFY ORDER APPOINTING INDEPENDENT MONITOR CV 85-4544-DMG (AGRX) Case Document 510 Filed 10/30/18 Page 5 of 6 Page ID #:25439 Authorization for Medical, Dental and Mental Health Care for B. (proposed to be ?led partially under seal) 161 Declaration of D., dated October 17, 2018 (proposed to be ?led partially under seal) 164 CFMG Consent to Medication for E., dated August 22, 2018 (proposed to be ?led partially under seal) 172 CF MG Consent to Medication for E., dated August 14, 2018 (proposed to be ?led partially under seal) 174 Declaration of W., dated October 17, 2018 (proposed to be ?led partially under seal) 176 Notice of Placement for D. in a Restrictive Setting, August29, 2018 (proposed to be ?led partially under seal) 181 ORR Authorization for Medical, Dental and Mental Health Care for D. (proposed to be ?led partially under seal) 186 Notice of Placement for L. in a Restrictive Setting, September 28, 2018 (proposed to be ?led partially under seal) 189 OR Authorization for Medical, Dental and Mental Health Care for D. (proposed to be ?led partially under seal) 194 CF MG Consent to Medication for G., dated August 8, 2018 (proposed to be ?led partially under seal) 197 Declaration of Holly S. Cooper, dated October 18, 2018 199 5 EXHIBITS IN OPPOSTION TO MOTION TO MODIFY ORDER APPOINTING INDEPENDENT MONITOR CV 85-4544-DMG (AGRX) Case Document 510 Filed 10/30/18 Page 6 of 6 Page ID #:25440 I declare under penalty of perjury that the foregoing is true and correct. Executed on this 19th day of October, 2018, at Santa Clarita, California. Respectfully submitted, Carlos Holgul'n 6 EXHIBITS IN OPPOSTION TO MOTION To MODIFY ORDER APPOINTING INDEPENDENT MONITOR CV 85