United States of America v. State of California et al

Filing 75

DECLARATION of Joe Dominic in opposition to 2 Motion for Preliminary Injunction. (Attachments: # 1 Declaration of Chris Caligiuri, # 2 Declaration of Arif Alikhan, # 3 Declaration of Jim Hart, # 4 Declaration of Jeffrey Rosen, # 5 Declaration of Diana Carbajal, # 6 Declaration of Holly Cooper, # 7 Declaration of Tom Wong)(Sherman, Lee)

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Anornc, General of Californi a

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Sen ilH Assistant /\tlomc, ( icncral
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Supen ising 01.;put) Attorneys (i1.;11cral

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Cl I rn m. 1.i: Dtvl t\'l 1 I I () N
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Lu: I. S 11rn.,1A~
Deput) Attorneys General
State Bar No. 27227 1
300 S. Spring Street
Los An~eles. CA 90013
Telcph~ne: (2 13) 269-6404
Fax: [phone]
E-mai l: Lee,Sherman@doj .ca.gov
Attor1111ys fur Defendants

II

IN T HE UNITED STATES DI STRI CT CO URT

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FOR THE EASTERN DI STRICT OF CA LI FORN IA

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THE UN ITED STATES OF AMERICA,

Case No. 2: 18-cv-00490-JAM-K.I N

Plaintiff.

DECLARATION OF HOLLY S.
COOPER IN SUPPORT OF
DEFENDANTS' OPPOSITION TO
PLAINTIFF'S MOTION FOR
THE STATE OF CALIFORNIA; EDMU ND PRELIMINARY INJUNCTION
GERALD BROWN JR., Governor of
California, in his official capacity; and
XAVIER BECERRA, Attorney General of
Judge: Honorable John A. Mendel'.
California, in his official capacity,
Action Filed: March 6. 2018
v.

Defendants.

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_ .)

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Deel. of Holly S. C0oper in Supp. of f'. kt\ .' Opp' n 10 Pl. 's l\.'101. lnr Preli m. lnj.
( I 8-cv-00-190-JA M-KJN)

I. Holly S. Cooper. dec lare as l'ollows:
I.

l am a resiuent or thl' State or Ca Ii f'nrn ia I ha ,-c personal know ledge of the fo ct~

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~ct forth i11 this tkclar.:11
ion. lt'callcd as a v,itnc~s. l cou ld and ,voufd rcst,fy competen tly 10 the

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mal!crs set rorth be low.

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I have knowledge o I' the cone! itions in many imrn igration detcnt ion cen ters v. 1thin

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the State or California. I have been a lawyer for almost 20 years aml for the ma_iority or my

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can:cr. I ha\'e pro\'ided free legal representation and consultations to individuals in im migration

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detention centers. Over the course of my career. I have interviewed thousands of men and

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women in the custody of Immigration and Customs Enforcement (I CE ) and unaccompanied

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children in the custody of the Offi ce of Refugee Resettlement. I have also been permitted special

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access to certain detention centers to inspect detention centers in my capacity as the Co-director

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of the Uni,ersity of Cali fornia. Davis Schoo l ot'La,,· s Immigration Lav.· Clini c. counsel for the

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Flon:s v. Reno Settlement Agreement (Case No. CV85 4544 (C.D.Cal. 1996). and in my capacity

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as a former member and advisor of the American Bar Association·s Immigration Commission.

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I regularly visit v, ith clients in the Yuba County Jail. the Rio Cosumnes

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Correctional Center (''RCCC") in Elk Grove. and the Contra Costa County Jail- sometimes as

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frequently as twice a week. For the 12 years that I have been visiting imm igration detainees in

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Yuba County Jail and the Sacramento County Jail (both fo rmerly at the d0\\11t0\\1
1jail and

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currently at the RCCC jail), immigration detainees· information has been publicly available.

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Yuba County has maintained a webpage that makes available personal infomrntion of detainees

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such as names. booking date. ages. \\ eight. gender. height. and whether the person is in count\'

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custody or immigration custody (or as Yuba County refers to it as " IN s·· custod) ). St'e Exhibit

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A, a true and correct redacted copy of a screenshot ot' the Yuba Count) \\ cbsitc ,, here detainee

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information is made available.

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4.

Sacramento County also lists \\'hcthi.:r the person is in C
l1unt) or immigration

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custody on its roster that is kept at the jail. The roster is publicly aYailabk on a desk in front 01'

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the jail' s reception area. Anyone from the public can access thi s roster. I frequently use the

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public ly a\'ai lable lists to get an accounting of hov. many pcrsons are in immigrati0n custody at
1

D.:cl. of!.-loll) S Cooper

Supp. n f Dc l\.' Opp ' n to Pl. \ M ol. l~>r Prel im ln_i .
( 18-ev-OOHO-JAI\ I-KJN )

111

l'ach foci lit) . h) help t'arni li es lind loved (int:s. and to determine lengths ol' detention fur my

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clients.
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Department or Homeland Security (" OH S") also runs a program called Victim\

or

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Immigrant Crime Engagement (.. VOICE"). VOICE releases detainees· information to . (1) a

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victim of crime(s); (2) a witness of crime(s): (3) an individual v.ith a legal responsibility to act on

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behalf of a victim or witness (e.g.. attorneys. parents, legal guardians. etc.): or (4) indi\'iJual s

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acting at the request ot' a victim or witness.
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One needs the ''A'' number (located in many public records like Ninth Circuit orders), and the
person's country of birth: or one can search wi th the individual' s name and country of binh.
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OHS also maintains a publicly available online locator for e\'cry ICE detainee.

For almost 18 years. I ha\'e documented. witnessed. and listened to detainees

recount their experiences enduring systemic. sub-human conditions in immigration custody in
public and pri vate California immigration detention centers. I ,·isit immigration detention centers

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in Cali fornia almost every week and inter\'iew at least 30 indi\'iduals in immigration custody

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every month. The fol lowing are my obserYations and experiences from my visits and

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im·estigations of detention centers throughout my career:

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feces smeared on their seg,rcg,ated cell:

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19

Spoken to detainees on the telephone \\ho are contemplating suicide whik the:, are describing

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Inspected rape phone hotlines only to realize the phone \\'as note, en connected to :.i phone
line:

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Witnessed almost uni versal ly inadequate law libraries:

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Witnessed retaliation against clients for demanding humane nll:Jica l treatment:

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\Vitnessed many detention centers " ith attorney-client, isit rooms that :m: not sound proof.
\\ here c: Iients are afraid to speak for kar of hcing o,·crheard:

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25

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1leard detainees recount li fe threatening medical issues that arc not hcing treated:

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Some detainees have \old me \hey have been raped while in detention ( one e, en"" recent as

last month) :

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Some detainees hm·e witnessed guard~ performing oral sex on other guards.
-,
Deel. of l·h1lly S. Co0pa in Surp. of Def.,· Opp'n to Pl ·s Mot t,,r l'rt'tirn 1113
( I 8-cv-00~90-JA r-.l -KJ~ )

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centers:

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\\"itnc~:.ed cltc1 {both adult s and childn:11 ) '-LIiler l'ru111 inadc4 uatc lood <;ourcc<.. 111 dc tcnuon
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Client::, ::md detainees ha\l.: complained about being tran:.purted in shack le~

v. hich can bc

e,traordinaril) pai nful fo r elderl: detainees and detainees ,,i th dir.;abilit1
cs:

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Children ha, e also been shack led during asylum inten·icws and suf'Jercd injuncs from
shackles being t00 tight around the v. rists: and

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Women detainees had inferior recreational facilities at Mesa Verde Detenti on Center.

8 II The issues are systemic. pen asive, and have not abated throughout the 18 years I have been
9 I working '"ith adults and children in immi gration detention centers.
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Unsani tary and unsafe conditions continue to exist in detention facilities in

11 ~ Cali fo rnia. For instance. dming a visit to RCCC in January 2014. I observed that the fac ility ,.,_ as
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~ old. loud. and dirty. As ,,·e walked down the halls. the concrete was wet and di rty- like a thin

13 II sludge on the ground. Men v. ere detained with other county inmates who ,, ere in criminal

14 1 custody. Some pods were open with bunks out in the open. and other pods were double-tiered
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with locked down cells. Last year around March 20 17. detainees at RCCC were evacuated due to

16 II high levels of lead and copper in the drinki ng water

\\ US disco,

ered by local goYemment

17 II inspection officials.
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lnac!_cguatc Mental Health Care
9.

Suicidal ideation is a major issue for persons and children in prolonged detention.

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Chi ldren have called me from detention duri ng the Christmas holidays crying in total despair that

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they j ust want to be with their mothers. Most detained children arc hundreds or mil es from family

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and olien are on ly able to speak with parents less than an hour per week. Mothers and f,llhers \\ ho

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are detained have particularly profound trauma at being separated from their children. Detainees

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are not pt!rmitted to touch their children throughout thei r detention, and \\ alking through the

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fa mi ly visitation rooms I often see children and parents crying, plac ing their hands o, er the

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plexiglass di viders trJ ing to touch. Om:, ery unique a<;pcct of immigra tion detention i" that man~

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ind ividuals are app lying fo r imm igration defenses that rcquin: them to prO\ ilk detailed narrati, L'S

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about their past traumas. Many

US)

lum seeker::.. abused children, and crime victims nH1,1 prn\'idc

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Deel. of I lol ly~- Coopt:r in Supp. lll L
kf.\.' Opp' n to Pl ·, t',foJ t'or J> r,·11111. 1111.
( I 8-C\ -00-1 90-JA 1\1-KJ f'..)

S\\ Orn

tcst1111
nn) rl·g.ar<ling their past rapes. past tortun:. past chi ld ahuse. an<l pa~l lrauma::.

Dctniling past traumatic c:-:periL·nccs in a public court takes a tremendous psycholog ical toll on

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immigration dctai ni.: cs. This trauma is compounded b) the !~ that most clo not have their
tcl

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traditional suprort networks to sustain them because they arc detained . For example. a v.oman

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may be requirt:d to provide specilic, graphic detail o!" all past rapes for her asylum hearing, and

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then must return alone to her cell at the <le tent ion cen ter. Detainees hm·e shom, me v. here they

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self-mutilate due to the despair of prolonged detention and tel l me of their suicidal thoughts. It 1~

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not uncommon to have to counsel indi viduals who are having suicidal ideat ion::.. One detainee

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told me how he witni.::ssed one detainee cut hi s wri sts and watched the bl ood spill out from the

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bathroom stall. He cried to me as he recounted ho,v people were in complete despair and not

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getting adequate psychological care.
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I have also represented clients with se,·ere psychological issues \\ho face extreme

13 II medical neglect. In one case. ,, e obtained the client's rrior psychiatric histoI") evinc ing seYerc
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psychiatric history that was being treated with psychotropic medications. After receiYing notice

15 II of the client's prior medical treatment. the advice nurse at the detention center prescribed T) leno l
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II and more outdoor time. and ignored tht! clien1·s prior treatment plan. \Vhen he \\ as released from

17 I detention months later. neither hi s famil y nor l mis notified. He was released in do\\11tO\\TI San
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Francisco in a patient gown made from paper. It took hours for me and hi s family to tind him.

19 II After he was found , he told us he had to beg for money so he could take thi.:: Ba) Area Rapid

20 II Transi t system home to Oakland.
tna<!_cgua te Mcdi~al Care

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Medical indifference to immigration detainees is perYasi vc ,md unabazed.

23 II Detainees with medical or psycho logica l issues rarely receive adequate medical care. Throughout
24 II my 18 years visi ting immigration detention centers I ha,·c obscr'I ed that detention centers: ( I ) fail

25 II to meet health care nei.: ds of indivi duals in a time!~ manner: (2) otlen fa il to rd"cr indi, iduals

to

26 n higher-level medical care pro\' iders \\hen necessary (anJ in some c~ses \his l'ailure has resulted

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27 II Jeath); (3) fo il to provide adequate stnff nnd medical r ersonnel: (~) fail to communicate crnic,ilh

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Deel.

or I toll)<;. Coop~r in Sur p. of Dl' k

. Opp·n to Pl ·\ ;\lot for Prl'l1 m ln1
( 18-cv-OO-t90-J:\M-KIN)

important informatio n about i11dividuab' medical conditions bd wcen 'itall and especially during
, II

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trans~~rs: anJ (5) fai l l l ) adequately screen individuab for illnesses.
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Almost every time / visil an immigration Jcte11lion center. dclainees com plain of

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medical neglect. On a recent visit a man told rnc that he had severe pain in his mouth and

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believed his tooth \\'as infected. l·k told me was going tu pull out the tooth himself bccauc;;c he

6 II was not receiving medical allcntion and feared the infection would spread.
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13.

On or around May 11 . 2015, 1 inspected the Mesa Verde Detention Facility in

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Bakersfield . California. because it had recently opened and a delegation of ci\ ii rights lavvyers

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\\',mted to inspect the facility. I inspected the facility in my capacity as Co-di rector of the UC

lo II Davis Immigration Lav.: Clinic. A prison official and ICE officers lead the .. tour"' of the facility
11 I and answered questions. I was concerned to learn that medical staffing included only 20 hours a
12 II week of a contract physician rather than havi ng a doctor at the faci lity at all times. The planned
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20 hours per week of psychiatric care on-site was also a concern given that approximately 400

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detainees were in custody there. After our tour. we learned that there 'vvas a waiting list fo r

I 5 II appointments with the psychiatrist.
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On or around May 22, 20 15, l inspected the Otay tvlesa Detention fac ility near

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San Diego, California with a delegation from the American Bar Association. On this inspection.

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we were not permitted to speak with the ICE detainees. but we were permitted to ask questions to

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the detention center spokesperson and medical staff. Therefore. we had no access to the

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detainees· perspective on this visit. One issue of concern \\ as the Jack of confidcntialitv of

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medical records. We were told by the detenti on center spokesperson that ICE onicers as \\ell as

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the Office of Chief Counsel could access and inspect a detai ncc·s medical ti le. This raised

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concerns that information that was given to medi cal sta ff for treatment purposes could be used to

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a person's detriment in deportation proceedi ngs.

,.,_)
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L;!_nguagc Burri~r_s
15.

The overwhelming majority of immigration detainees dLl not speak. write. or read

27 II English. Spanish is the predominant language of most detainees. Other languages spoken by
28 II detai nees are Tagalog. Vietnamese. Mandari n. Punjabi. f rench. \\'olo[ Somali. l laitian Cn.:olc.
5
Dee l. of I lo lly ::-.. Cooper in ~upp. of Defs.· Opp' n to Pl ·s \1ot. for Prd 11n. lnj
( 18-c\·-00-190-JAM- K.JN)

Hindi . Urdu. Farsi. and indigenous languages !'rorn Guatemala and Mexico . Language barrier~
, I create c..>normous obstacles for non- Engli sh speakers. Although detainees have simultaneous
3 II translations during their remova l hearings. they are not afforded a translator to prepare the legal

4 II forms required by the court. Immigration detainees also do not have the right to appointed
5 II counsel unless they have a serious mental disorder pursuant to Franco-Gonzolez v. Holder. No .
6 II CV I 0-1022 11 DG (C.D. Cal). The vast majority of immigration detainees (most of whom do not
7 II speak. read. or write English) represent themsel ves without the assistance of a lawyer. l n some

8 II California detention centers, only around 15% of the detainees have the assistance of a lawyer.
16.

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Jo II

Most defenses in immigration court are enormously complicated and require

submitting lengthy legal forms to the court. The immigration legal forms are akin to Internal

J 1 II Revenue Service tax forms- they are lengthy and incomprehensible to most persons. For
J 2 II example, if an immigration detainee asked an immigration judge for the opportunity to apply for
J3

II political asylum. she would be given the Form 1-589. a I0-page fo1m in English that asks

14 ~ complex questions regarding persecution in her home country. The Form 1-589 is required of
15 II anyone wishing to seek political asylum . If, for example. the detainee was a monolingual
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II Mandarin speaker from China, she would need to complete the Form 1-589 in English. lf the

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I person cannot read or write in English, they cannot complete the fo rm. Most detainees who

l 8 I( cannot afford a lav.ryer have no choice but to ask other detainees to assist them with the forms.

19 II This forces immigration detaint:t:s to disclose very personal detai ls about their persecution. snual

20 I orientation, or rape histories to other detainees. Detainees helping non-English speakers usually
21 I have no legal training- and even though well-intended-often miss critical detai ls or facts that

22 II can have a serious prejudicial effect on the person·s asyl um application. EYen as a trained

23 II la\\/)'er, r can spend a minimum of 15 hours completing a Form 1-589 \,·ith my clients-if I need
24 11 to use a trans lator that time fram e can easily be doubled. Moreover. ir a pro se detainee who
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cannot read or 'v\Titc in English must author a legal brief to the court of appeals. the legal process

26

becomes a farce. To properly \V1'ite a legal appel\a\e brief, \be detainee nn.,st he able \o read

27 I lengthy transcri pts in English. research case law in English. read relevant court cases in Cn~l i~:.11.
28 II and "vrite legal bri efs in English analyzing the transcripts and case lav.: npplicahk

6

tl)

Deel. of Holly S. Cooper in Supp. of Defs .' Or p' n 10 Pl. 's Mot. for l'rt'\ 1 . ln1 .
111
( t 8-cv -00400 -JAi'vl -K JN)

the ir cas.:

lm111i gratill11 detainees 1> lk 11 stare a l rn e in rnnfus1 a~ I describe the appellate procc~s 111 the
on.
,

II

Board or l111111 igration Appeals and Ninth Circuit and what \,\,ill be required in their legal brief\

3

ff

can co11tidcntl~ say that a perso n "vho dues not read or \.\ rite 1:ng!ish cannot represent thcmsel,cs

4 II in a court of appeals without assistance. Many immigration detainees gi ve up valid claims for
5 II relief because th~ language barriers make it extremely difficul t to represent thcm~elve~ in pro se.
6

17.

Language barriers also stymie access to medical treatment. as most detai nees must

7

fill out "kites.. or medical request fo rms in English to receive medical treatment. If an

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immigration detainee cannot speak English, again they must rely on the benevolence of

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immigration detainees who can write the medical requests in English for them. They must

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disclose very personal information to complete strangers to request medical treatment.
Lack of Access to Telephones

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18.

Telephone access has hi storically been an enormous issue for detainees and

13 I lawyers who are trying to reach their clients. One near-common characteristic of immigration

14 II detention is its remoteness from Cali fornia's urban centers or distance from free legal service
15 II providers. Over the years, IC E has contracted with detention centers located in El Centro.

16 II Marysville, Elk Grove. California City, Bakersfield. and Adelanto. among other cities. Most of
17 I these are distant from free legal services and maj or cities. Thus. phone access is critical to an
18

individual' s legal case as many lav.,yers and nonprofit lawyers cannot afford the time and e\.pense

19

to travel to remote detenti on centers. A part of thi s issue has been remediated through a class

20 II action settlement called Lyon, et al. v. United States Immigration Customs £1~/brcement. No. 1321

cv-5878. that covers Northern California detention centers: howe\'er. ma11) detention centers in

22

Southern California are not covered by the settlement. Persistent issues for Southern California

23 II faci lities arc: (1) inability to call numbers with automated attendants; (2) inability to call kg.al
24 II counsel on a confidential phone line: (3) inabil ity of lawyers to reach clients on conlidential

25

phone lines: (4) inabil ity to leave messages (most detention center phones disconnect the detainee

26

call if no ··)ive" person is there to receive the call ); and (5) the high cost of phone cal\s. The bck

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of inadequate phone access impedes a pcrson·s abi lity to gather evidence in suprort of their

28 II claim, impacts a law)'cr's ability to effectively represe nt their client. and impacts Califo1111a

7
- - - -- - - -- -- - - - - - - - -- - - -- - - - - - - - -- - · - - - Dee l. of llolly S. Cooper in Supp. of Dcfs." Opp' n to Pl."s Mot. fl,r Prcl1m lni
( t 8-cv-004 90-JAI\I - K JN)

r~sid~ nts ,, hn tnu~I pa) 1hc high co~I~ o l' lhl' colk l' I lcll'phonl' call,; from the ir family in friends in

2 II detention.

3 II

L~ldeguatc
_Accc:". i"i lo Le_gal Resou rces anti Coun,.cl
.
19.

4

lmmig.ralion law is extraordina ril y compkx yt.:t law libra ries in imm igration

5 II detention centers are universal!) inade4uatc. Rarely arc relevant f<.,rms available in imm igration
6 II detention centers' law li braries. Immigrants in removal proceed ings often apply for relief from
7

II removal. Typical forms used to apply lor relief' arc: ( J) applications fo r poli tical asyl um: (2 )

8 II applications for U visas: (3) applications fo r cancellation of removal: (4) fee wai vers: and (5)

9 ~ applications for adj ustment of status. It is common fo r law libraries not to have any of these
1O II fo rms.

20.

11

Immigrants also bear the burden of proof in appl icati ons fo r relief. For example.

12 II for political asylum. an applicant must show an objectively reasonable fear of persecution in her
13

home country. This is typically demonstrated through human rights reports. newspaper articles.

J4

and State Department reports submitted by the applicant. I lowever. law libraries in detention

15 II centers rarely contain relevant human rights materials and applicants cannot meet their burden
16
17

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without assistance outside of' the detention center.
21.

Legal materials are generally out-of-date and inadequate. Typically. the situation

l8

is so dire. that I donate my old legal treatises and compilations or current human rights reports to

19

detention centers. I have even asked publishers to send me defective books (i.e. books with tom

20

pages or spines) so that I can donate them to the detainees.

21

•

22 .

During my visit to Mesa Verde Detention Center in 2015. I noted that the law

22 II li brary was inadequate. During the inspection. l had the opport unity to log in and run a search on

23

the legal database available to detainees. and had three concerns about the s:- stem. First. giYen

24

that I - a trained at1orney 1,,vi th considerable ex perience using different legal search engines

25

could not fi gure out how to cond uct a search "'" ithout significant gu idance from the lihrnrian. I

26

doubted that most detainees could Lio the sarnc. \ queried the system on a basic deportation

27

question and the system told me it could not finJ any cases that met a basic criteria. Dctainet'~

28

ofte n do not have access to recent. critical information pertaining lo their cases. lmm igratt un l.i\\ '
8
Deel. of Holly S. Conpl'r in Supp of L>ch.· Opp·n to Pl ·, l\fot for Prl'i1 lnj
111
( 18-c\ -00490-JA M -KJ N )

can change
there

")

1

\\Cl\ .'

fr\1 111

\\ Cd,-tt1-\\cc~ a1 IHI\ 111g up-lo-date kg,tl 1nfonnt1t1on 1 cn11c,il \J on.:11\cr
1d
s

111, i111m1
grJtiu11 li..1n11, ur n:k,an l l111
111a1111gh1.., n.:porh a,ailabk 111 thi.: la,\ l1
brn0

I large nu111 b1.·r u(1mm1gra11011 Jcta1ncl'" appl)
.

to r

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/um . \\l lhho lding o( ri.:111<1,al nnd rd1cl

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rn
4 ~ under th1.· Clll\CntH ,\ gui nsl lortu n.:. all ur \, l11 ch u~uall) requ ire 1mm1granh to hear the burden
5 II

\) r

rrn1 :rnJ present e, idcncc ahout conJi11 om, in their home coun tne'.'>. Without c.1cces.., lo current
)f

6 II human rights repons. immigr:.1111s cannot prc)Cllt '.'> uch c\'idencc and meet their hurdens f unhcr
7

~

,,. c ,,ere told if a detainee \\'anted to print any doL: urncnls. they had to be mailed to the lav.

8

I

librarian and she would print them. This raised concerns ahout the pri\'aC) of the data ac:; man)

9 II detainees are recounting private informatio n about torture and persecution that \\ Ould ha\C lo be

Jo ~

emailed to a third party for printing.

23.

II

Around January 2014. I v.as given a "tour'" of RCCC in Elk Gro,·e The lav.

12

library ,, as in a large cage in the middle o f a larger room. The library had no rcle, ant

13

information fo r ICE detainees. The library appeared catered to persons in criminal custody.

24.

14
J5 ~

The ability to confer 'vVith counsel in immigration detention centers is al so lim ited.

For instance. Mesa Verde Detention Faci lity did not have sound-proof rooms for attorneys The

16 II attorney-client visitation rooms at RCCC were of vary ing sizes and ,Yere ··first-come-tirst-~en·e ··

17 II The smaller visitation rooms could not reasonably accommodate more than one person. thus. if

18 II the lawyer needed a translator. he or she would have to wait fo r the larger room. At the Ot..t)
19

~

Mesa Detention Facility. I also had concerns of the adequac~ of the la\\ librnr) due to lad. of

20 II relevant fo rm s and legal resources. and concerns over phone access.
21
22
23
24

I declare under penalty of perjury under the laws nf the United Stutes that the forei;l1 ing ,._
true and correct and that thi s declaration

\\ US

executed on

. 20 IS in

Vrbod lo..N1. Californi a.

25

-

26

HOLL \' S~BHQR

27

28

~ ":) Q

........ ...__

___

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--------------------------- --------- -------- --- ---------- - --Dee l. cir I loll:-, \ . C00p..:r 111 Supp. 0t l kt~ · Upp n w l' I. \ i\fot lor P rl·l 11ll 1111
-

( I 8-cv-00 190-.11\r\ 1
-K.IN )

I

EXHIBIT A