Declaration of Erez Reuveni — East Bay Sanctuary Covenant v. Barr, Case 4:19-cv-04073-JST (Document 68-1)

Summary

A declaration of Erez Reuveni, Assistant Director in the Office of Immigration Litigation, District Court Section, of the U.S. Department of Justice, filed September 3, 2019 as Document 68-1 in East Bay Sanctuary Covenant v. Barr, Case No. 4:19-cv-4073-JST, in the U.S. District Court for the Northern District of California. The plaintiffs challenge the interim final rule Asylum Eligibility and Procedural Modifications, 84 Fed. Reg. 33,829 (July 16, 2019). Reuveni states that two agency guidance documents the defendants filed with their opposition to a renewed motion for a nationwide injunction, from EOIR and ICE (ECF Nos. 65-1 and 65-3), contain privileged attorney-client communications, work product and third-party personal information, and that plaintiffs' counsel Lee Gelernt takes no position on filing them partially under seal.

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DECLARATION OF EREZ REUVENI
East Bay Sanctuary Covenant v. Barr,

Case No. 4:19-cv-4073-JST
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JOSEPH H. HUNT
Assistant Attorney General
WILLIAM C. PEACHEY
Director
EREZ REUVENI
Assistant Director
U.S. Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Tel: (202) 307-4293
Erez.R.Reuveni@usdoj.gov
PATRICK GLEN
Senior Litigation Counsel

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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East Bay Sanctuary Covenant, et al.,
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Plaintiffs,

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v.
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Civil Action No. 4:19-cv-4073-JST

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DECLARATION OF

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EREZ REUVENI

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William Barr, et al.,
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Defendants.

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Case 4:19-cv-04073-JST   Document 68-1   Filed 09/03/19   Page 1 of 2

DECLARATION OF EREZ REUVENI
East Bay Sanctuary Covenant v. Barr,

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Case No. 4:19-cv-4073-JST

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I, Erez Reuveni, declare:
1.
I am an Assistant Director at the Office of Immigration Litigation, District Court
Section, of the United States Department of Justice, and represent Defendants in this action.  The
facts set forth in this declaration are within my personal knowledge or based on documents and
information I have received in the course of this litigation in this case.
2.
Plaintiffs in this lawsuit are challenging the Interim Final Rule titled “Asylum
Eligibility and Procedural Modifications,” 84 Fed. Reg. 33,829 (July 16, 2019) (“Rule”).  See ECF
Nos. 1, 3.
3.
As part of their opposition to Plaintiffs’ renewed motion for a nationwide injunction
(ECF No. 63), Defendants attached ass exhibits guidance documents issued by the Executive
Office of Immigration Review (“EOIR”), United States Immigration and Citizenship Service
(“USCIS”) and Immigration and Customs Enforcement (“ICE”), illustrating how each agency is
implementing this Court’s injunction, as modified by the Ninth Circuit.
4.
Two of the guidance documents, issued by EOIR and ICE, respectively, contain
privileged attorney-client communications that occurred in connection with this case. Those
documents presently appear on the docket at ECF Nos. 65-1 (EOIR) and 65-3 (ICE).
5.
Those same two documents also contain privileged work-product information and
personal identifying information, as  these documents were explicitly prepared in connection with
the pending litigation and in response to the preliminary injunction issued by this Court, as
modified by the Ninth Circuit.
6.
In addition, the guidance documents contain third party personal identifying
information, including third party attorney names.
7.
On September 3, 2019, I contacted Counsel for Plaintiffs, Lee Gelernt, via email to
ascertain Plaintiffs’ position on this motion.  Plaintiffs’ Counsel indicates they take no position as
to whether the aforementioned guidance documents should be filed partially under seal.
I declare under penalty of perjury that the following declaration is true and correct.
Executed at Washington, D.C. on September 3, 2019.

/s/ Erez Reuveni

EREZ REUVENI
Case 4:19-cv-04073-JST   Document 68-1   Filed 09/03/19   Page 2 of 2

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