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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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: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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THE UNITED STATES OF AMERICA,

Plaintiff, DEFENDANTS’ NOTICE OF FILING OF
CORRECTED DECLARATION

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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.

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Defendants’ Notice of Filing of Corrected Declaration

(2:18-cv-00490-JAM-KJN)

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Defendants respectfully submit this Notice of Filing of Corrected Declaration in order to

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correct the record for the Court with respect to two facts set forth in the Declaration of Tom K.

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Wong (Wong Declaration), filed May 4, 2018, in support of Defendants’ Opposition to Plaintiff’s

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Motion for Preliminary Injunction in the above-captioned case and docketed on the Court’s

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electronic case filing system (ECF) as Document 75-7. The attached Supplemental Declaration

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of Tom K. Wong explains that during his May 30, 2018 deposition, he found two errors in

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paragraph 11 of his declaration. First, Dr. Wong inadvertently included the word “not” in a

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sentence stating in relevant part that “six [California counties] are characterized as not willing to

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accept detainer requests,” in paragraph 11, line 14. This part of the sentence simply summarizes

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the underlying ICE data that forms the basis of Dr. Wong’s analysis described in paragraphs 9

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through 24 and does not change the substance of his conclusions in the declaration. In addition,

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in line 17 of paragraph 11, the date of which the FOIA data were current is December 2016, not

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December 2015. Those corrections have been made in paragraph 11 of the attached Amended

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Declaration. The date of signing has also been changed. No other changes to the Wong

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Declaration have been made nor have any changes been made to the exhibit attached to that

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declaration.

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Dated: June 6, 2018

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Respectfully Submitted,
XAVIER BECERRA
Attorney General of California

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/s/Christine Chuang
Christine Chuang
Deputy Attorney General
Attorneys for Defendants

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Defendants’ Notice of Filing of Corrected Declaration

(2:18-cv-00490-JAM-KJN)