ROBERT S. BREWER, JR. United States Attorney ERNEST CORDERO, JR U. S. Attomeg Callforma Bar No. 131 65 . A. GARABED U.S. Attome Callfomla Bar No. 22 51 1 Unlted States Attomey?s Of?ce 880 Front Street Room 6293 San Dlego, CA 92101-8893 Telephone: 619) 546-7478/7703 19) 546-7751 . Emagl: ernest.cordero%usd01 .gov Emall: mlchael.garabe @usd01.gov Attorneys for Federal Defendants KAJIDOUSA, Plaintiff, V. US. DEPARTMENT OF HOMELAND SECURITY U.S. IMMIGRA ON CUSTOMS ENFORCEMENT U.S. CUSTOMS AND BORD PROTECTION KEVIN K. MCALEENAN, Act1n Secret of MATTHEW T. ALBE CE, Actln Dlrector of MARK A. MOR AN Actln of and PETER FLO S, Dgrector of Field Operations for CBP, San Dlego, Defendants. 5e Document 35-1 Filed 09/09/19 PageID.317 Pagelof? UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Case No.: (KSC) DECLARATION OF SARO OLIVERI Ca. ?e Document 35-1 Filed 09/09/19 PagelD.318 Page20f7 I, Saro Oliveri, declare as follows: I am the Customs and Border Protection Branch Chief at the Port of Otay Mesa. I have held the position for ten years. I have personal knowledge of all facts contained in this declaration. If called upon to do so, I could and would competently testify thereto. 1. As the Branch Chief, I am responsible for the Trusted Traveler Enrollment Center. In this capacity, I have access to the Global Enrollment System maintained by CBP. The GES has been set up to maintain records and information on Trusted Traveler Programs, including Global Entry and Secure Electronic Network for Travelers Rapid Inspection Through the GES, I can check on the history of a person?s enrollment in any of the Trusted Traveler Programs, including his or her current status. 2. In connection with the above-referenced lawsuit, I personally retrieved information from the GES information pertaining to Kaji Dousa. The records indicate she is enrolled in the Global Entry Program which allows expedited clearance for pre-approved, low risk travelers upon their entry into the United States by land, air and sea. Each person enrolled receives a ?known traveler number? that can be used when making airline reservations. CBP maintains a website where program members may login to check their program status. 3. Global Entry and SENTRI are both Trusted Traveler Programs that provide some overlapping bene?ts, but they also have differences. For example, both Global Entry and SENTRI allow for expedited entry at land ports when crossing from Mexico and Canada. However, Global Entry also can be linked to a passport for use when arriving by air. With respect to someone returning to the United States from Mexico on foot or in an automobile, Global Entry and SENTRI provide the same expedited clearance bene?ts. 4. Attached to this Declaration as Exhibit is a true and correct copy of a record I retrieved from the GES. The document has been redacted but contains information showing that Kaji Dousa?s Global Entry card was issued on December 14, 2016 and has never been revoked or suspended. It currently is valid and expires on August 22, 2022. 2 Ca. 5e Document 35-1 Filed 09/09/19 PageID.319 Page30f7 5. I also retrieved information from ATS-L system to determine the dates Kaji Dousa entered the United States over the past eighteen months. This information includes the times she entered the United States through any Port of Entry on the U.S.?Mexico border. Attached as Exhibit to this declaration is a true and correct redacted copy of a record from the ATS-L system indicating that she entered the United States at the San Ysidro Port of Entry four times during the eighteen-month period. Three times, she used her Global Entry card. Speci?cally, she used it when she crossed as a pedestrian on (1) November 27, 2018; (2) January 2, 2019; and (3) April 4, 2019. She also crossed on November 28, 2018, but this time she used her US. Passport. 6. The ATS-L records also indicate that Kaji Dousa was sent to the secondary inspection area during only one of the four crossings at the SYPOE on January 2, 2019. That day, the time between her referral to the secondary inSpection area at the SYPOE, and her release by of?cers questioning her in secondary, was 43 minutes. Months later, on April 4, 2019, she again presented herself at the SYPOE using her Global Entry card. This time, she crossed without referral to the secondary inspection area. I also note that on August 6, 2019, she left New York City on a ?ight to the Bahamas without incident. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct to the best of my knowledge. Executed on August 15, 2019 at 4119 San Diego, California. Case Document 35-1 Filed 09/09/19 PageID.320 Page4of7 EXHIBIT Summaly Case Document 35-1 Filed 09/09/19 PageID.321 PM CTTP Card Status: Activated First Name: KAJI ROSA SPELLMAN Last Name: DOUSA ?Birth Date: Gender: Citizenship: Program: GLOBAL ENTRY Expiration Date: 22 AUG 2022 Document Application ID: Number: Issue RFID: Issue Date: 14 DEC 2016 Tag ID: Version: C01 Street: Suite: City: State/Province: CA Country: US Postal Code: 919421701 Case Document 35-1 Filed 09/09/19 PageID.322 Page60f7 EXHIBIT SC Document 35-1 Filed 09/09/19 PagelD.323 Page7of7 AILW Dum- quuv: 0001A. 00-- Ivan-?D?- 0? - (-V th- - Int-d ?Hug-.4 mm AA: {7 Dunc-"u unu- m? Ill- W4 - mm you(II- D-.213 n- NMQA AMI OWIO AUINID .E NIH-A. ?I'll I I I 5199 2) 23 um: 5 LE ?mw 'mm can. LAAh-on--(a-uyalnm 0 out". gunk-ah Vti-A m- Lot to moo-l? nan - cl ~90: mun 1:50!) 4 on: m- or: an ?gaunt-c nan vu-D no. my may: rune?unu- sum Dau- nun-nu n? buy?- 1p. up: ban? has. 7-1 1? m. no- u- x?n? m. ban-n Iy? ml Dan L..- rm: - :mwxu :o a: ma IA: Remarks: 0N JANUARY 2, 2019 AT APPROXIMATELY 1847 KAJI DOUSA (DOB FOR ENTRY INTO THE US MEXICO VIA THE SAN YSIDRO PORT OF ENTRY PEDESTRIAN WEST DOUSA PRESENTED HER VALID GLOBAL ENTRY CARD BEARING l99m27698 HER NAME AND PICTURE FOR ENTRY INTO THE UNITED STATE DEROGATORY WAS FOUND DURING INTERVIEW DOUSA WAS RELEASED AT APPROXIMATELY 1930 HOURSnoo mun MID h-(Yy? c-n- v1.1. u?v? Wm Wm hung?n..- Hyman-a) on. no: an anal.? um n. pun-.1 s?a Dol.?? In no. L. Ion; no root m: I omymn 2019 momnm m7 Nouns, m: DOUSA DOB: NO DEROGATORY INFORMATION WAS FOUND DURING INTERVIEW DDUSA WAS RELEASED AT APPROXIMATELY 1930 HOURS. 1.4 nu.- (M ma?a-o Ann?dunn- minimal) Mun?Mn..- h?n you n'u mo.- WM :1 Au: matron - u: m??mMMa -) ?bum-ulna; a a? was nun-.? mun-? buy-unu? tun?awn. DO. Au: no.9 (u urwxu warm?