Declaration from Jennifer Smith

We were unable to speak directly to detainees who had not requested to speak with us and/or whose names we did not have already because ICE did not want us "soliciting" clients. We explained that we were volunteers and that we were not charging for our services, but we were still not allowed to speak to anyone not on our list. We provided a list of names to ICE, but we were unable to see a majority of the women on the list either because ICE was unable to locate them or because they were in a consular, asylum, or court interview without counsel.

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