Plaintiffs’ Response to Order to Show Cause in Flores Litigation

On August 14, 2015, the plaintiffs filed their response in the Flores litigation to the Order to Show Cause, stating “When this Court issued its Order it was fully apprised of the parties’ arguments and submissions. Defendants continue in breach to this day. They offer no rational reason why they cannot comply with the detention and release provisions of the Order starting immediately and within 90 days provide the Court with proposed standards--and procedures for monitoring compliance with such standards--for detaining class members in facilities that are safe and sanitary, consistent with concern for the particular vulnerability of minors, and consistent with Paragraph 12 of the Agreement.”

• Plaintiffs' Response to the July 24, 2015, Order to Show Cause

• Table of Contents for Exhibits Submitted with Plaintiffs' Response to Order to Show Cause

• Reports, Letters, Press Releases, and Articles on Family Detention (Exhibits 69-86)

• Declarations from Doe v. Johnson Lawsuit -- on CBP Conditions, Part 1

• Declarations from Doe v. Johnson Lawsuit -- on CBP Conditions, Part 2

• Declarations Andrew Free, Aseem Mehta, Carol Anne Donohoe, Chris Christiansen, and David Thompson Describing Conditions at Berks, Karnes, and Dilley

• Declarations from Denise Gilman, Alan Shapiro, MD, Elizabeth Sweet, Elora Mukherjee, and Johana De Leon, Describing Conditions at Berks, Karnes, and Dilley

• Declarations from Karen Lucas (AILA) and Lindsay Harris (the American Immigration Council), Regarding Complaints Filed with DHS CRCL and OIG on Deplorable Medical Conditions and the Psychological Impact of Detention, along with Declarations from Attorneys Kim Hunter, Laura Lichter, and Katherine Park

• Evidence Regarding Medical Conditions in Family Detention, Declaration from Luis Zayas on the Mental Health of Detained Families, Declaration from Manoj Govindaiah and Miranda Guerrero Regarding Conditions at Karnes

• Declarations from the R.I.L.R. Lawsuit, Declarations from Robyn Barnard, Scott Coomes, Stephen Manning (on data from the CARA Project), and Susannah Volpe, on Conditions at Karnes and Dilley

• Declarations from Doe v. Johnson Lawsuit -- on CBP Conditions, Part 3

Cite as AILA Doc. No. 15082320.