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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
JHONNATAN BRINEZ URDANETA, et al.;
Petitioners,
v.
CHUCK KEETON, et al.;

Case No.: CV-20-00654-PHX-SPL
Agency Case Nos.: 201-910-906;
203-699-999; 205-914-447; 203-710976; 213-351-367; 213-348-505; 203702-428; 213-361-650

Respondents.
__________________________________________________
DECLARATION OF OFFICER IN CHARGE JASON CILIBERTI
I, Jason Ciliberti, Officer in Charge (OIC), make the following statements under oath and subject
to the penalty of perjury:
1. I am employed by U.S. Department of Homeland Security (DHS), Immigration and
Customs Enforcement (ICE), and currently serve as the OIC for the La Palma
Correctional Center (LPCC). I was previously the Assistant Field Office Director for the
LPCC starting in 2018 until I was promoted to the position of OIC in 2020.
2. I provide this declaration based on my personal knowledge, belief, reasonable inquiry,
and information obtained from various records, systems, databases, other DHS
employees, employees of DHS contract facilities and information portals maintained and
relied upon by DHS in the regular course of business.
3. In my current position, I work closely with the Field Medical Coordinator (FMC), who
reports to the Medical Case Management Unit. The FMCs serve as medical consultants to
the ICE field offices and oversee clinical services at Inter-Governmental Service
Agreement (IGSA) facilities that house ICE detainees, including the LPCC.
4. ICE Health Service Corps (IHSC) provides direct medical, dental, and mental health
patient care to approximately 15,300 detainees housed at 20 IHSC-staffed facilities
throughout the nation.
5. IHSC’s FMCs ensure that the provision of medical care by contractors to the ICE
detainees within the IGSA facilities meets detention standards, as required by the IGSA
contract. The FMCs do not provide hands-on care or direct the care within the IGSA
facilities but monitor the medical care and services provided by the contract facilities.
Medical staff at the contract facilities are directly responsible for medical care at the
facility.
6. IHSC comprises a multidisciplinary workforce that consists of U.S. Public Health Service
Commissioned Corps (USPHS) officers, federal civil servants, and contract health
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professionals. The LPCC, as an IGSA facility, employs a multidisciplinary medical
workforce that consists of Registered Nurses, Physician assistants, Physicians, medical
assistants, Dental Hygienists, Dentists, Psychologists, Psychiatrists, and Nurse
Practitioners.
7. Since the onset of reports of Coronavirus Disease 2019 (COVID-19), ICE
epidemiologists have been tracking the outbreak, regularly updating infection prevention
and control protocols, and issuing guidance to field staff on screening and management of
potential exposure among detainees.
8. In testing for COVID-19, medical staff at the LPCC is also following guidance issued by
the Centers for Disease Control (CDC) to safeguard those in its custody and care.
9. Each detainee is screened for disabilities upon admission by a Registered Nurse.
Identified disabilities are further evaluated and reasonable accommodations are provided
as medically appropriate.
10. For both EDC and LPCC medical staff are screening all detainee intakes when they enter
the facilities including travel histories, medical histories and checking body temperatures
and have procedures to continue monitoring the populations’ health. Detainees are
assessed for fever and respiratory illness, are asked to confirm if they have had close
contact with a person with laboratory-confirmed COVID-19 in the past 14 days, and
whether they have traveled from or through area(s) with sustained community
transmission in the past two weeks. All new arrival detainees are then placed in isolation
from the general population and closely observed for 14 days, regardless of their travel or
health history.
11. For both EDC and LPCC, those detainees who present symptoms compatible with
COVID-19 will be placed in isolation, where they will be tested. If testing is positive,
they will remain isolated and treated. In case of any clinical deterioration, they will be
referred to a local hospital.
12. In cases of known exposure to a person with confirmed COVID-19, asymptomatic
detainees are placed in cohorts with restricted movement for the duration of the most
recent incubation period (14 days after most recent exposure to an ill detainee) and are
monitored daily for fever and symptoms of respiratory illness. Cohorting is an infectionprevention strategy which involves housing detainees together who were exposed to a
person with an infectious organism but are asymptomatic. This practice lasts for the
duration of the incubation period of 14 days, because individuals with these and other
communicable diseases can be contagious before they develop symptoms and can serve
as undetected source patients. Those that show onset of fever and/or respiratory illness
are referred to a medical provider for evaluation. Cohorting is discontinued when the 14day incubation period completes with no new cases. Per ICE policy, detainees diagnosed
with any communicable disease who require isolation are placed in an appropriate setting
in accordance with CDC or state and local health department guidelines.
13. The LPCC has the following medical capabilities: A clinic staff which manages male
detainees and provides daily access to sick calls in a clinical setting, as well as mental
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health services and the ability to admit patients at the local hospital for medical and
mental health care.
14. As of 8:00 AM on April 13, 2020, LPCC medical staff provided the following
information:
a. There are presently no laboratory confirmed cases of COVID-19 in LPCC.
b. Two ICE detainees with prior laboratory confirmed cases of COVID-19 in the
LPCC, no longer test positive. There are 98 detainees who are currently
cohorted and under daily observation due to exposure to the first confirmed
case of COVID-19.
c. There was previously one confirmed case of COVID-19 in the LPCC, who
was a new intake. He was quarantined at intake and separated from the
general population. He was subsequently hospitalized for an unrelated
injury/illness and then released from ICE custody.
d. The entire LPCC facility is cohorted until at least April 14, 2020. All
detainees are cohorted in their respective housing units with meals being
provided in the housing units and no inter-housing unit contact between
detainees.
e. The LPCC is not accepting further detainee intakes into the facility until at
least April 14, 2020.
15. The LPCC has a population within its approved capacity and is not overcrowded.
16. The LPCC has increased sanitation frequency and provides sanitation supplies as
follows:
o LPCC provides disinfectant spray, and soap in every housing unit at the detention
center. The administration is encouraging both staff and the detention center
general population to use these tools often and liberally.
o LPCC provides disinfectants to staff and cleaning crews and CDC recommended
cleaning and disinfection above and beyond normal activity have been
implemented.
o LPCC cleans and disinfects each housing unit between shifts and entire cell
blocks on a rotational schedule.
o LPCC provides every housing unit in the detention center with disinfectant spray,
soap, and hot water. LPCC staff and the general population are directed to use
these cleaning tools often and liberally.

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17. The Department of Homeland Security has limited professional visits to noncontact
visits and suspended in person social visitation and facility tours. The Department has
required that all visitors wear personal protective equipment (PPE) to include mask,
gloves and eye protection. No visitors are permitted to enter without the PPE.
18. The LPCC is utilizing security staff medically trained to conduct temperature screening
and health history questionnaires of all staff and vendors when they enter the facilities
including body temperatures.
19. The LPCC medical staff are screening all detainee intakes when they enter the facilities
including travel histories, medical histories and checking body temperatures and have
procedures to continue monitoring the populations’ health. LPCC stopped detainee
intakes on March 31, 2020 and is currently not intaking any new detainees until at least
April 14, 2020.
20. The LPCC medical staff provide education on COVID-19 to staff and detainees to
include the importance of hand washing and hand hygiene, covering coughs with the
elbow instead of with hands, and requesting to seek medical care if they feel ill. The
facilities provide detainees daily access to sick call.
21. The LPCC medical staff has identified housing units for the quarantine of patients who
are suspected of or test positive for COVID-19 infection to be addressed as set forth in
paragraphs 9, 10 and 11, supra.
22. ICE has reviewed its detained “at risk population” as identified by the CDC guidelines
to determine if detention remains appropriate, considering the detainee’s health, public
safety and mandatory detention requirements, and adjusted custody conditions, when
appropriate, to protect health, safety and well-being of its detainees.
I declare, under penalty of perjury under 28 U.S.C. § 1746, that the foregoing is true and
correct to the best of my knowledge and based on information obtained from other individuals
Digitally signed by JASON A
employed by ICE.
JASON A
DATED: April 13, 2020

CILIBERTI
Date: 2020.04.13 08:24:33
-07'00'
_____________________________________

CILIBERTI

Jason Ciliberti, Officer in Charge
La Palma Correctional Center
Enforcement and Removal Operations
U.S. Immigration and Customs Enforcement

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