Declaration from Arlene Rivera

The attorney desks were located about 10-15 feet away from the ICE officers and so could easily be overheard by them. ICE officers approached us every hour, even during client meetings, to conduct head counts. In addition to the ICE officers, other detainees and their children (who were with their mothers at all times) could overhear attorney-client conversations, which were supposed to be confidential.

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