Declaration from Bryan Johnson

I have been able to speak with [my client] only sporadically because the ICE officers at the Artesia facility do not permit her to use a phone at any set times, and when she is given access, permit her to remain on the phone only for short periods of time. During my first phone call with [my client] . . . I was able to speak with her for only 9 minutes and 39 seconds when she called me after hours at 6:56 pm EST. After that, an ICE agent forced her to end the call. The approximately ten additional conversations I had with Jane were similar. I had great difficulty preparing her case given the erratic and insufficient time that ICE agents allowed her to use the phone. I received a call from Jane, who told me that ICE was trying to force her to agree to deportation and saying that she could go to jail for ten years and be separated from her son if she did not sign for travel documents.