Declaration from Phillip Smith

Each and every applicant that I met with or represented during an official proceeding with an Immigration Judge or asylum officer had a child or children with them at the time, often in their laps. Many of the children were sick, and the mothers were often required to recount gruesome acts of violence, sometimes rape, while holding or trying to care for their children. There was no one to care for the children or any place that they could be left while these proceedings were taking place.