Court filing

Declaration — East Bay Sanctuary v. Trump

Record facts

Court	U.S. District Court for the Northern District of California
Filed	2018-12-04

U.S. District Court for the Northern District of California · No. 4:18-cv-06810-JST · Doc. 71-7 · 2018-12-04 · Docket on CourtListener

Full text

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DECLARATION OF MICHELLE BRANE OF
THE WOMEN’S REFUGEE COMMISSION

I, Michelle Brané, hereby declare as follows:
1.
I am the Director of the Migrant Rights and Justice (MRJ) Program of
the Women’s Refugee Commission (WRC), where I have worked on research and
policy advocacy since August of 2006. Prior to joining the WRC, I was the
Director of the Access to Justice Program at Lutheran Immigrant and Refugee
Services, a Human Rights Officer and Election Monitor seconded by the U.S.
Department of State to the OSCE (Organization for Security and Cooperation in
Europe), and an Attorney Advisor at the U.S. Department of Justice, Board of
Immigration Appeals. I am admitted to practice law in New York. I make this
declaration based on my personal knowledge except where I have indicated
otherwise. If called as a witness, I could and would testify competently and
truthfully to these matters.
2.
I submit this declaration to document the widespread and systematic
denial by the U.S. government of the rights of asylum seekers and danger to which
this exposes asylum seekers and especially unaccompanied children, who present
themselves at the port of entry in Tijuana/San Isidro.
The Women’s Refugee Commission and the
Migrant Rights and Justice Program
3.
The WRC is a non-profit organization that advocates for the rights of
women, children, and youth fleeing violence and persecution. The WRC is based
in New York, New York; the MRJ Program is based in Washington, D.C.
4.
The WRC was founded in 1989, originally as a program within the
International Rescue Committee, after having identified a dearth of programming
to protect women and girls displaced by humanitarian crises around the world. It
subsequently evolved into an independent entity. WRC’s mission is to improve the
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lives and protect the rights of women, children and youth displaced by conflict and
crisis.
5.
The WRC is a leading expert on the needs of refugee women and
children, and the policies and programs that can protect and empower them. The
WRC regularly consults displaced women, children, and youth, and works with the
community-based organizations that are usually the first responders in any
humanitarian crisis. It then raises those needs with policy makers and
implementers, including local and national governments, the United Nations, and
other international non-governmental organizations that drive humanitarian policy
and practice.
6.
The MRJ program focuses on the right to seek asylum in the United
States. It strives to ensure that refugees, including women and children, are
provided with humane reception in transit and in the United States, given access to
legal protection, and protected from exposure to gender discrimination or gender-
based violence. The MRJ program regularly consults with diverse stakeholders,
including affected migrants and refugees; community-based, national, and
international organizations; policymakers, including Members of Congress and
their staff; and federal government officials from several departments and agencies
that work on immigration-related issues and conduct oversight.
7.
Since 1996, the MRJ team has made numerous visits to the southwest
border region, including along Mexico’s northern border, as well as to immigration
detention centers for adult women and families and to shelters housing
unaccompanied children throughout the country. Based on the information that we
collect on these visits and our legal and policy analysis of the issues, we advocate
for improvements through various methods, including meetings with government
officials and service providers, and by documenting our findings through fact
sheets, reports, backgrounders, and other materials. We make recommendations to
address identified or observed gaps or ways in which we believe the corresponding
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department or agency could improve its compliance with the relevant standards.
We use these materials in our advocacy work to inform the perspectives and
decisions of policymakers. Although the WRC has not litigated cases directly, the
MRJ program has filed amicus briefs and declarations in pending litigation on
issues such as the conditions and standards for the custody of unaccompanied
children.
Recent Experiences of Asylum Seekers in
Encounters with U.S. Authorities
8.
Since December 2016, members of my staff in the MRJ program and I
have conducted several visits to the U.S.–Mexico border, after receiving reports
from local advocates that asylum seekers were being systematically turned away
from U.S. land Ports of Entry. Most recently we visited Tijuana, Mexico and San
Isidro and San Diego, California on November 26 – 30, 2018. My focus today is
on observations and findings from this visit.
9.
The structure of our visit consisted of crossing the border from the
United States to Mexico by foot. Once in Tijuana, Mexico, we met with NGOs
Government officials, International Organizations, and migrants, over the course of
several days. We observed events and attempts to enter through the port of Entry at
“Garita El Chaparal” – or Pedestrain Access West. We spoke with migrants and
asylum seekers about their experiences crossing the border, trying to cross the
border, or before attempting to cross the border from Mexico into the United
States. All of the asylum seekers we encountered were seeking safe haven in the
United States after fleeing targeted violence or other serious harm in their home
countries.
10.
I also met with CBP representatives on the U.S. side of the border, to
learn more about what they were observing on these same issues and to share our
findings.

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Manner in Which Asylum Seekers Are Denied Processing
11.
All asylum seekers, including those from Mexico, are told by U.S.
border officials that prior to processing or entry they have to coordinate with
Mexican immigration authorities. In practice, what we observed – confirmed by
asylum seekers, Mexican and U.S. government officials, and NGOs working in
Tijuana – is that asylum seekers must register themselves on a list that is
maintained by migrants themselves and the Mexican agency known as “Grupo
Beta.”
12.
Asylum seekers maintaining “the list” are self-appointed through an
ad hoc nomination system. I observed that asylum seekers managing “the list” are
stationed at a table outside of the Port of Entry. Migrants who approach them are
asked for their identity documents, their name is put on the list, and they are given
a piece of paper with a number on it. Every evening, this list is given to the
Mexican agency, “Grupo Beta” for “safekeeping” overnight.
13.
Asylum seekers, NGO personnel, and Grupo Beta themselves
informed us that Grupo Beta maintains the lists of asylum seekers waiting to
present at a specific Port of Entry every night, and in the morning, after being
informed by U.S. authorities how many will be accepted, they escort the
individuals whose turn it is to the U.S. officials at the Port of Entry. We were told
that if an asylum seeker approaches the Port without being on ‘the list”, he or she
would be turned away by U.S. authorities, refused processing, and be told that they
need to get on “the list”.
14.
On this visit, we spoke to asylum seekers from Mexico, Honduras,
and Venezuela. All of the asylum seekers with whom I spoke were confused and
concerned about the process.
15.
Unaccompanied children are unable to access the port of entry
through the “metering” system implemented by the United States. Unaccompanied
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children are unable to get on the list – or present themselves at the border based on
the list. They are also unable to approach the port of entry without being on the
list.
16.
Any children who present themselves to Mexican authorities (as
required by U.S. officials) to be escorted to the Port of Entry are referred to
Desarrollo Integral de La Familia (DIF) – the Mexican agency charged with the
protection of children. Once referred to DIF, children risk detention and
deportation. As a result, children are unable to get on “the list” and access the port
of entry.
17.
DIF is charged with the care and custody of all unaccompanied
children in Mexico. Children and adults to whom we spoke reported that being
sent to DIF meant deportation. While DIF is responsible for screening children for
protection, the reality is that this often does not happen and children in custody are
often unable to access protection.1
18.
In addition to not being able to sign onto the list and access the port of
entry, children who are unaccompanied informed us that they are afraid to identify
themselves. Their status as unaccompanied children puts them at increased risk
(see examples below).
19.
We also met with Al Otro Lado (AOL), DIF officials, and leaders of
the Casa Inca YMCA shelter for unaccompanied children in Tijuana. Where
possible (when they are identified and when there is space available and where a
child is willing), unaccompanied children identified by NGOs or DIF are sent to
Casa Inca. When they become aware of unaccompanied children who are
interested in applying for asylum in the Unites States, AOL attorneys and
volunteers provide them with a legal orientation, do a screening, and in appropriate

1 Georgetown Law Human Rights Institute Fact Finding Project, The Cost of
Stemming the Tide, April 2015, https://www.law.georgetown.edu/human-rights-
institute/our-work/fact-finding-project/the-cost-of-stemming-the-tide/.
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cases will accompany a child to the Port of Entry.

Threatening Conditions along Mexico’s Northern Border
20.
During my visit to Tijuana, I saw and spoke with many asylum
seekers, who reported that CBP had refused to process them. These individuals,
who were waiting in shelters in northern Mexico while figuring out what to do next
were in a very vulnerable situation. A small number have found accommodations
either in rental space or with Mexican families. The majority are unable to afford
private accommodations. These asylum seekers were dependent on the Mexican
authorities or non-governmental entities to provide them with lodging and food.
21.
On the day I spoke to migrants whose number was expected to be
called who were waiting for entrance, I encountered Mexican, Venezuelan, and
Honduran families. They were fleeing violence and persecution and had been
waiting at the port for several weeks.
22.
Asylum seekers stranded along Mexico’s northern border are
particularly susceptible to opportunistic or predatory behavior.
23.
One of the shelters we visited – a sports complex known as Benito
Juarez– was located in the red light district of Tijuana. We were told to leave the
area before dark because it was extremely dangerous and that the neighborhood
was the home base for traffickers. We were told that it was “not safe” to walk or
spend time outside around the shelter. We were also told that there is an unofficial
5:00 p.m. curfew in place for the area, since violent crime picks up after dark.
24.
Sanitary conditions are extremely concerning at Benito Juarez. Toilet
facilities consisted of a small building with indoor toilets that were overflowing
and had a line of about a hundred people pushing to get in. In addition, there was a
line of about 25-30 port-a-potties. Many had doors completely broken off or
falling off the hinges. They were not segregated by gender. There were only two
showers, outdoor with no privacy barriers or proper drainage. The area around the
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toilets was flooded with standing water.
25.
Garbage receptacles were inadequate and overflowing.
26.
We saw no security within the shelter – which was housing over 4000
migrants, except for two civilian clothed municipal employees restricting access to
an indoor facility that housed a limited number of women and children, and single
men with children. Many women, children, and families remained outside the
enclosed area.
27.
The only public health presence we witnessed was public health
personnel handing out face masks as protection for respiratory illness.

28.
On November 30 the shelter was transferred to a new location known
as El Barretal. The new location is better equipped for sheltering in the winter
months because it has a roof and concrete floors. However, the new shelter is also
in a very dangerous neighborhood and is very remote from the city and ports of
entry. Getting access to the port of entry to request asylum, sign up on “the list”,
or report when your number is called, is difficult.
29.
We interviewed many asylum seekers at the shelter and in other
shelters in Tijuana. The majority were from Honduras and told us they were
fleeing violence ranging from extreme domestic violence, to gang and cartel
violence, and violence from governmental entities based on political opinion.
Information about asylum rights is extremely lacking in the shelters. The majority
of the people to whom we spoke expressed fear of returning home but were
unfamiliar with asylum or the criteria. We encountered many unaccompanied
children in the shelter who had no information about their rights to protection in
Mexico or the United States.
30.
Most of the unaccompanied children to whom we spoke did not know
how to ask for asylum in the U.S. They were either unaware of the list or knew
about the list and told us that they were unable to get on the list as unaccompanied
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children. Several told us they “need an adult” to help them cross.
31.
Unaccompanied children were very hesitant to tell us they were
unaccompanied. They explained that if they encountered authorities they would be
taken, detained, and deported. Most of the children we spoke to expressed great
fear of being returned to their home countries.
32.
In several cases their understanding gave us serious concern that they
were at risk of trafficking or of getting themselves into risky smuggling situations.
Where we identified unaccompanied children, we referred them to attorneys and
the children’s shelter but the children were often mistrustful and not sure what to
do, and both space at the shelter and attorneys are limited.
33.
We encountered one 16-year-old boy who was traveling with his 8-
year-old half-brother. The boy was afraid to stay at the Benito Juarez shelter or go
to the new shelter because conditions were so bad and dangerous. He was also
afraid to go to the border or to try to get on the list because he was unaccompanied
and feared he would be detained and deported. He wanted to go to his family in
the U.S. but had no idea how. We told him about the children’s shelter and he said
he would try to find his brother and bring him, but by the time he went to look for
his brother, he had left.
34.
We encountered a 13-year-old girl from Honduras who was looking
for safety. She was alone and knew that she would not be able to register at the job
fair offered by Mexican authorities because she was too young. She was also
aware of the risk of deportation if she presented herself to the Mexican authorities
for registration. She did not know how to get to the port of entry because she knew
she needed an adult to do so. While we were speaking to her we were approached
by a woman who said she was looking out for her. The girl looked uncomfortable.
The woman asked her why she was speaking to us and the girl said she was trying
to get information about seeking protection. The woman said “Why would you
need protection? You have me.” The girl had made an arrangement to care for the
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Lisa Mitchell-Bennett, MA, MPH
225 Hibiscus Ct. Brownsville, TX 78520
(956) 466-5657
lisa.mitchell-bennett@uth.tmc.edu

Education:

Master of Public Health, MPH
University of Texas, School of Public Health (2010)

Master of Arts, International Development Administration, MA
School for International Training, Brattleboro, VT (1994)

Bachelor of Arts, Political Science/International Relations, BA
University of California, Riverside, CA (1989)
Dean’s List; Departmental Honors

Certificate, Estudios Hispanicos (1987)
University of Granada, Spain

Experience:

Project Manager
University of Texas, School of Public Health
Brownsville, TX 2011 – present
Manage a large team of multi-project initiatives with numerous institutional
partners throughout the region. Projects include a diabetes chronic care
management program with community health workers, local hospitals, clinics and
behavioral health providers (Salud y Vida); an evidence-based youth obesity
intervention in the schools and community (MEND); a navigation program for a
mobile clinic serving uninsured, rural population; a community-wide campaign
with media, policy and environmental change working in 9 towns and cities (Tu
Salud ¡Si Cuenta!); and supervising numerous graduate and undergraduate
student for research internships.

Quality Assurance Coordinator
University of Texas, School of Public Health
Brownsville, TX 2011 - 2013
Coordinated monitoring and quality assurance for a multi-disciplinary team;
developed and evaluated interventions to address obesity and diabetes through
a community-wide campaign including media, policy and environmental change
to support healthy choices. Managed relationships with community partner
institutions, provided training and supervision to community health workers,
created and evaluated content for media campaign, involved in grant writing and
reporting. Responsible for monitoring, training and implementing coordinated
efforts with a clinical research unit, local community partners and research
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investigators. Developed and provided training for organizations and community-
health workers across the state.

Senior Research Associate
University of Texas, School of Public Health
Brownsville, TX 2003-2011
Coordinated intervention research and community outreach efforts for multiple
projects. Facilitated research center’s community advisory board; oversaw mini-
grant funding for community-based organizations, schools and clinics; provided
support and resources to community groups to engage in design, evaluation and
dissemination of culturally appropriate programs. Coordinated community health
worker training and a media campaign “Tu Salud, Si Cuenta” with U.S. and
Mexican media partners. Provided research coordination on numerous
community based participatory research studies addressing health disparities
including diabetes, teen pregnancy, obesity, cancer (HPV) and emergency
preparedness as well as Hispanic science education (manage multi-university
summer science high school internship program). Co-facilitated a course on
Conducting and Analyzing Focus Group Data and guest lecturer in Evaluation
and Health Promotion courses.

Project Director/Health Education Coordinator
Brownsville Community Health Center
Brownsville, TX 1997 - 2003
Managed Campus Care Centers, school-based health center with 3 full-service
clinics in a large school district serving uninsured and indigent students and their
families; supervised multi-disciplinary team including medical and mental health
care providers, social workers, medical assistants and office personnel. Also
served as coordinator of health education, prevention and outreach efforts for the
community health center (FQHC) in the satellite clinics and schools; coordinated
community-based health education on violence prevention and sex education for
the school district. Responsible for grant writing, reporting, staff supervision,
design and implementation of curriculum for award-winning health promotion
efforts in the schools and community.

Division Director, Adult Education and Job Training
Congreso de Latinos Unidos, Philadelphia, PA 1995 - 1997
Directed multi-facet job training and adult education programs for a large inner-
city agency in North Philadelphia. Provided contract and grant management;
supervision of a large staff including teachers, trainers, social workers and
project coordinators; worked closely with city-wide domestic violence programs to
recruit and retrain women looking to reenter the workforce; collaborated with the
Private Industry Council, the Community College of Philadelphia and the
American Street Empowerment Zone; participation on an Executive Management
Team for the larger agency.

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Project Director
Mano a Mano/One Border Foundation
Brownsville, TX—Matamoros, Mexico 1993-1995
Directed and co-founded a bi-national community health worker organization
“Mano a Mano” in U.S.-Mexico border communities of Matamoros, Mexico and
Brownsville, Texas. Designed and implemented recruitment, training, grant-
writing and facilitated project’s advisory board. Fostered cross-border, cross
institution relationships and supervised community health workers. Accompanied
health worker on home visits and addressed barriers.

Legal Advocate/Unaccompanied Minors Program Coordinator
Casa del Proyecto Libertad, Harlingen, TX 1991-1993
Coordinated advocacy and legal services to Central American unaccompanied
minors and refugees. Involved in local and national advocacy efforts; provided
legal services to detained adult political asylum applicants; represented in
Immigration Court as Accredited Representative, researched human rights policy
and provided legal rights presentations in immigration detention facilities and
shelters.

Associate Editor, Latin America Press
Lima, Peru 1990-1991:
Researched, edited and translated for a scholarly bilingual publication covering a
broad range of political and economic issues in Latin America and the Caribbean.
Publication based in Lima, Peru.

Trainer, Centro Cultural Costaricense-Norteamericano
San Jose, Costa Rica 1990:
Designed and implemented cross-cultural curriculum for rural Central American
youth preparing for high school exchange program and university agricultural
programs in the U.S. Worked with U.S. AID funded agricultural grant. Based in
San Jose, Costa Rica.

Organizer, Farm Labor Organizing Committee
Toledo, OH 1987
Recruited farmworkers to become members of a labor union through human
rights presentations; provided social services and outreach to labor camps
across northern Ohio. Organized FLOC annual convention which hosted Cesar
Chavez and United Farm Worker Delegates from across the county.

Publications/Presentations:

o Fernandez ME, McCurdy S, Arvey S, Morales-Campos D, Tyson, S,
Useche, B, Mitchell-Bennett, L, Sanderson, M. HPV Knowledge,
Attitudes, and Cultural Beliefs among Hispanic Men and Women in South
Texas. Ethnicity and Health. December 2009.
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o Heredia, N, Lee, M, Mitchell-Bennett, L, Reininger, B.M. Tu Salud¡ Sí
Cuenta! Your Health Matters! A Community-wide Campaign in a Hispanic
Border Community in Texas. Journal of Nutrition Education and Behavior,
2017.

o Heredia, N, Lee, M, Mitchell-Bennett, L, Reininger, B.M. Tu Salud, Si
Cuenta! Your Health Matters! A quasi-experimental design to assess the
contribution of a communitywide campaign to eating behaviors and
anthropometric outcomes in a Hispanic border community in Texas.
Journal of Nutrition Education and Behavior. In Press.

o Montoya, J. A., Salinas, J. J., Barroso, C. S., Mitchell-Bennett, L., &
Reininger, B. (2011). Nativity and nutritional behaviors in the Mexican
origin population living in the US–Mexico border region. Journal of
Immigrant and Minority Health, 13(1), 94–100. PMCID: PMC3034163

o Reininger, B. M., Mitchell-Bennett, L., Lee, M., Gowen, R. Z., Barroso, C.
S., Gay, J. L., & Saldana, M. V. (2015). Tu Salud,¡ Si Cuenta!: Exposure
to a community-wide campaign and its associations with physical activity
and fruit and vegetable consumption among individuals of Mexican
descent. Social Science & Medicine, 143, 98-106. PMCID: PMC4642277

o Reininger, B. M., Barroso, C. S., Mitchell-Bennett, L., Chavez, M.,
Fernandez, M. E., Cantu, E., Smith, K. L., & Fisher-Hoch, S. P. (2014).
Socio-ecological influences on healthcare access and navigation among
persons of Mexican descent living on the U.S./Mexico border. Journal of
Immigrant and Minority Health, 2014 Apr;16(2):218-28 PMCID:
PMC4377819

o Reininger, B. M., Barroso, C. S., Mitchell-Bennett, L., Cantu, E.,
Fernandez, M. E., Gonzalez, D. A., Chavez, M., Freeberg, D., & McAlister,
A. (2010). Process evaluation and participatory methods in an obesity-
prevention media campaign for Mexican Americans. Health Promotion
Practice, 11(3), 347–357. PMCID: PMC2877153

o Mitchell-Bennett, L., "Social cognitive theory and factors associated with
Mexican-American parents' beliefs, attitudes and practices regarding
communication with their adolescent children about sex" (2010). Texas
Medical Center Dissertations (via ProQuest). AAI1470749.
http://digitalcommons.library.tmc.edu/dissertations/AAI1470749

o American Public Health Association (APHA) Paper presented
(Washington D.C.,2007) “Latina mothers' communication with their
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adolescent children about sexuality, sexually transmitted diseases and the
reproductive system”
o American Public Health Association (APHA) Paper/Poster presentations
(Philadelphia, 2005); “Assessing Cultural Beliefs and Practices Regarding
Healthcare Utilization Among Hispanics in the Lower Rio Grande Valley
(LRGV)” & “Assessing Attitudes and Science Career Choices Among
Hispanic Youth in LRGV”
o Research Symposium, University of Texas, Brownsville. “Hispanic
Adolescent Attitudes and Preferences Regarding Employment During
High School” (2007)
o Healthy Communities Annual Meeting, “Assessing Cultural Beliefs,
Attitudes and Practices of Lower Rio Grande Valley Hispanic Parents’
Communicating With Their Adolescent Children About Sex” (2006)
o Rio Grande Valley Science Association Annual Conference, San Juan,
TX, “Assessing Attitudes and Science Career Choices Among Hispanic
Youth in the Lower Rio Grande Valley, Texas” (2005)
o U.S.-Mexico Border Health Conference, El Paso, TX “Campus Care
Centers: Comprehensive School Based Health Centers” (1997)
o University of Texas Health Science Center, Border Health Conference,
Presenter / Expert Panel Member San Antonio, TX, “Mano a Mano; A
Promotora de Salud Model” (1995)

Certifications:

o Department of State Health Services Community Health Worker Instructor
certification (2012- present)
o Accredited Representative, Accredited by the Board of Immigration to
represent political asylum cases in Federal Immigration Court (1995)

Community Service:

o Board of Directors, Brownsville Wellness Coalition (2017-Present)
o Guardian Ad Litem, Young Center for Immigrant Children’s Rights
(2015-2017)
o Friends of the West Rail Trail Organizing Committee (2015- Present)
o Board of Directors, Episcopal Day School (2012-2014)
o Board of Directors, Casa del Proyecto Libertad (1999-2005)
o United Brownsville Health Committee (2010-2013)
o Volunteer, La Posada Soup Kitchen, Brownsville, Texas (2010-2013)
o Institutional Animal Care Research Committee, University of Texas,
Brownsville (2010)
o Vestry, Church of the Advent Episcopal (2007-2008)
o Rio Grande Valley Science Association, Board Member (2004-2008)
o Steering Committee Member, REACH Coalition/Walk El Valle (2002-2003)
o Advisory Board Member, Mano A Mano Promotoras (1998-2000)
o Health Trendbenders, Healthy Communities of Brownsville (2002-2008)
o Member, National Assembly on School Based Health Care (1997-2000)
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o Steering Committee, American Lung Association (1997-1998)
o Executive Committee, Save Our Children Brownsville (1997)
o Board Member, American Street Empowerment Zone (1995-1997)
o Member, Philadelphia Job Developer’s Network (1995-1997)
o Member, Singing City Philadelphia Inner City Choral Music (1995-1997)
o Volunteer Director, Cameron Park Community Center (1993-94)
o Executive Committee, March of Dimes Rio Grande Valley (1993-1995)
o Delegate, Citizen’s Observer Mission to El Salvador (1994)
o Volunteer, General Board of Global Ministries UMC (1991-1993)
o Volunteer, Pamplona Alta Soup Kitchen, Lima, Peru (1990-91)

Awards and Honors:
Domonic Napoli Humanitarian Scholarship (1985); United Methodist Church
College Scholarship (1985); University of California Alumni Award for Community
Service (1989); University of California, Dept. of Political Science Honors (1989);
Ford Foundation Immigration Advocates Training Scholarship (1991); Rio
Grande Valley Human Rights Award (Holy Spirit Parish-1995); Congress of
United Latinos’ Service Award (1997); Award for Excellence in Texas School
Health (2000); University of Texas, Houston Health Science Center, American
Public Health Association Annual Conference Scholarship (2006); Finalist,
Fulbright U.S. Student Program Scholarship.

Other Experience:

o Teacher (English as a Second Language and Spanish),
o “The Language Connection”, Phoenix, Arizona, Phoenix Public Schools,
o Arizona, and Euroidiomas Language Institute, Lima, Peru.
o Intern, International Affairs Council, Riverside, CA
o Teacher Trainer, Brownsville Independent School District Developed and
implemented puberty and sexuality education training for district teachers,
counselors and nurses, Brownsville, TX

Languages:
English (Fluent); Spanish (Fluent); French (Proficient).
I have lived and/or worked in Mexico, Colombia, Indonesia, Switzerland,
Spain, Costa Rica, Peru and the U.S.

References available upon request.
Case 4:18-cv-06810-JST Document 71-7 Filed 12/04/18 Page 15 of 15

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