United States of America v. State of California et al

Filing 165

AMENDED DECLARATIONS by State of California re 75 . (Attachments: # 1 Supplemental Declaration of Wong, # 2 Amended Declaration of Wong) (Chuang, Christine) Modified on 6/6/2018 (York, M).

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1 2 3 4 5 6 7 8 9 10 XAVIER BECERRA Attorney General of California THOMAS S. PATTERSON Senior Assistant Attorney General MICHAEL NEWMAN SATOSHI YANAI ANTHONY HAKL Supervising Deputy Attorneys General CHRISTINE CHUANG CHEROKEE DM MELTON LEE I. SHERMAN Deputy Attorneys General State Bar No. 272271 300 S. Spring Street Los Angeles, CA 90013 Telephone: (213) 269-6404 Fax: (213) 897-7605 E-mail: Lee.Sherman@doj.ca.gov Attorneys for Defendants 11 IN THE UNITED STATES DISTRICT COURT 12 FOR THE EASTERN DISTRICT OF CALIFORNIA 13 SACRAMENTO DIVISION 14 15 16 THE UNITED STATES OF AMERICA, Plaintiff, DEFENDANTS’ NOTICE OF FILING OF CORRECTED DECLARATION 17 18 19 20 21 22 Case No. 2:18-cv-00490-JAM-KJN v. THE STATE OF CALIFORNIA; EDMUND Judge: Honorable John A. Mendez Action Filed: March 6, 2018 GERALD BROWN JR., Governor of California, in his official capacity; and XAVIER BECERRA, Attorney General of California, in his official capacity, Defendants. 23 24 25 26 27 28 Defendants’ Notice of Filing of Corrected Declaration (2:18-cv-00490-JAM-KJN) 1 Defendants respectfully submit this Notice of Filing of Corrected Declaration in order to 2 correct the record for the Court with respect to two facts set forth in the Declaration of Tom K. 3 Wong (Wong Declaration), filed May 4, 2018, in support of Defendants’ Opposition to Plaintiff’s 4 Motion for Preliminary Injunction in the above-captioned case and docketed on the Court’s 5 electronic case filing system (ECF) as Document 75-7. The attached Supplemental Declaration 6 of Tom K. Wong explains that during his May 30, 2018 deposition, he found two errors in 7 paragraph 11 of his declaration. First, Dr. Wong inadvertently included the word “not” in a 8 sentence stating in relevant part that “six [California counties] are characterized as not willing to 9 accept detainer requests,” in paragraph 11, line 14. This part of the sentence simply summarizes 10 the underlying ICE data that forms the basis of Dr. Wong’s analysis described in paragraphs 9 11 through 24 and does not change the substance of his conclusions in the declaration. In addition, 12 in line 17 of paragraph 11, the date of which the FOIA data were current is December 2016, not 13 December 2015. Those corrections have been made in paragraph 11 of the attached Amended 14 Declaration. The date of signing has also been changed. No other changes to the Wong 15 Declaration have been made nor have any changes been made to the exhibit attached to that 16 declaration. 17 18 Dated: June 6, 2018 19 Respectfully Submitted, XAVIER BECERRA Attorney General of California 20 21 22 /s/Christine Chuang Christine Chuang Deputy Attorney General Attorneys for Defendants 23 24 25 26 27 28 Defendants’ Notice of Filing of Corrected Declaration (2:18-cv-00490-JAM-KJN)

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