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 PATTERSON
Senior Assistant Attorney General
MICHAEL NEWMAN
SATOSHI Y ANAI
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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THE UNITED STATES OF AMERICA,

Case No. 2:18-cv-00490-JAM-KJN

Plaintiff,
SUPPLEMENTAL DECLARATION OF
TOM K. WONG IN SUPPORT OF
DEFENDANTS’ OPPOSITION TO
THE STATE OF CALIFORNIA; EDMUND PLAINTIFF’S MOTION FOR
PRELIMINARY INJUNCTION
GERALD BROWN JR., Governor of
California, in his official capacity; and
XAVIER BECERRA, Attorney General of
Judge: Honorable John A. Mendez
California, in his official capacity,
Action Filed: March 6, 2018
Defendants.
v.

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Supp. Decl. of Tom K. Wong in Supp. of Defs.’ Opp’n to Pl.’s Mot. for Prelim. Inj.
(18-cv-00490-JAM-KJN)

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I, Tom K. Wong declare as follows:

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1.

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I have personal knowledge of the facts set forth in this declaration. If called as a

witness, I could and would testify competently to the matters set forth below.

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2.

I was deposed on May 30, 2018.

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3.

During the deposition, I discovered two errors in need of correcting. Both of these

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are in paragraph 11. First, in paragraph 11, line 14, I inadvertently included the word “not” in the

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sentence stating, “six [California counties] are characterized as not willing to accept detainer

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requests.” This part of the sentence simply summarizes the ICE dataset that I used in my analysis,

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which is described in paragraphs 9 through 24, and thus does not change the substance of my

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conclusions. The second error that needs correcting is in paragraph 11, line 17. The FOIA data

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were current as of December 2016, not December 2015.

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I declare under penalty of perjury under the laws of the United States that the foregoing is

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true and correct and that this declaration was executed on June 4, 2018 in San Diego, California.

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______________________________
TOM K. WONG

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Supp. Decl. of Tom K. Wong in Supp. of Defs.’ Opp’n to Pl.’s Mot. for Prelim. Inj.
(18-cv-00490-JAM-KJN)