Declaration from Christina Brown

[M]any women reported to me that they had very limited access to telephones. They had to wait in long lines to make calls, and their calls were limited to three minutes. They reported they were forced to clean in order to “earn” their phone calls. Some women told me that they were denied calls when the ICE officers were upset with them. The women’s inability to make phone calls limited the capacity of attorneys to properly prepare clients and precluded clients from calling their attorneys to give them updated case information.