Deportation Research Clinic,Source Materials
Deporation Research Clinic, Buffett Institute for Global Affairs, Northwestern University, Media Inquiries

ONE DOLLAR PER DAY: THE SLAVING WAGES OF IMMIGRATION JAIL WORK PROGRAMS

A History and Legal Analysis, 1943 - present

source materials and updates from ongoing litigation over work conditions and information

Ruderman, et al. v. McHenry County, case no: 3:22-cv-50115 

Complaint, 4/15/2022, 21 pages, Doc. 1

Awombang v. CoreCivic, Inc., case no: 19-2207 

Appeal to Fourth Circuit (Including Original Complaint), 12/10/2019, 186 pages, Doc. 18

Brief of Appellants, 12/10/2019, 41 pages, Doc. 19

Brief of Appellee, 01/09/2020, 46 pages, Doc. 22

Order Removing Case from Calendar, 01/13/2021, 1 pages, Doc. 44

Yeend v. Akima Global Services, Inc., case no: 1:20-cv-01281-TJM-CFH 

Plaintiff's State Complaint, 09/03/2020, 21 pages, Doc. 2

Summons Served to Defendants, 09/03/2020, 21 pages, Doc. 1-3

Service of Process, 09/18/2020, 18 pages, Doc. 1-2

Civil Cover Sheet, 10/16/2020, 2 pages, Doc. 1-5

Exhibit 1 Declaration of Laura Mitchell, 10/16/2020, 4 pages, Doc. 1-1

Notice of Removal to Federal Court Filed with Northern District of New York, 10/16/2020, 18 pages, Doc. 1

Notice of Removal to Federal Court Given to State Court, 10/16/2020, 2 pages, Doc. 1-4

Notice of Admission Requirement to Plaintiffs Attorney Maureen Hussain, 10/19/2020, 1 pages, Doc. 5

Notice of Admission Requirement to Plaintiffs Attorney Robert McCreanor, 10/19/2020, 1 pages, Doc. 4

Rule 26 Filing Order, 10/19/2020, 15 pages, Doc. 3

Answer to Complaint in District Court, 10/23/2020, 24 pages, Doc. 6

Defendant Corporate Disclosure Statement, 10/23/2020, 2 pages, Doc. 7

Memorandum of Law in Support of Plaintffs' Motion to Strike Defendant's Affirmative Defenses , 11/14/2020, 16 pages, Doc. 15-1

Notice of Motion to Strike Defendant's Affrimative Responses, 11/14/2020, 2 pages, Doc. 15

Notice of Motion to Remand, 12/01/2020, 41 pages, Doc. 18

Gonzalez v. CORECIVIC, Inc., case no: 1:18-cv-00169 

  LAREDO, Texas facility

Complaint and Class Action, 2/22/2018, 37 pages, Doc. 1

Motion to Dismiss Plaintiff's Complaint, 6/08/2018, 19 pages, Doc. 18

Response in Opposition to Motion, 7/24/2018, 17 pages, Doc. 23

Defendant Corecivic's Reply in Support of Motion to Dismiss, 8/30/2018, 10 pages, Doc. 27

Order Denying Motion to Dismiss, 03/01/2019, 5 Pages, LEXIS 114595

Order Setting Initial Pretrial Conference, 3/27/2019, 1 Page, Doc. 36

Motion to Stay Case by CoreCivic, Inc., 4/02/2019, 10 pages, Doc. 37

Order Granting Defendant's Motion to Certify for Interlocutory Appeal, 6/10/2019, 3 pages, Doc. 42

5th Circuit Decision on Interlocutory Appeal, 02/18/2021, 24 pages

Barrientos, et al. v. CORECIVC, Inc., case no: 4:18-cv-00070-CDL

  LUMPKIN, Georgia facility

Complaint for Declaratory/Injunctive Relief, Damages, 4/17/2018, 32 pages, Doc. 1

Response in Opposition to Motion to Dismiss, 7/12/2018, 23 pages, Doc. 34

Reply in Support of Defendants' MOtion to Dismiss, 8/02/2018, 12 pages, Doc. 37

Order on Motion to Dismiss for Failure to State a Claim, 8/17/18, 17 pages, Doc. 38

Notice of Appeal, 12/12/2018, 89 pages, Doc. 40

Eleventh Circuit Court Decision Upholding District Court Order, 2/28/2020, 25 pages, Doc. 42

Raul Novoa, et al. v. The GEO Group, Inc., case no: 5:17-cv-02514

ADELANTO, California facility

Complaint for Declaratory/Injunctive Relief, Damages, 12/19/2017, 18 pages, Doc. 1

Complaint, 12/20/2017, 18 pages, Doc. 1

Defendant Memorandum of Points and Authorities In Support of Motion to Dismiss, 2/16/2018, 32 pages, Doc. 20-1

Order Granting in part and Denying in part Motion to Dismiss, 6/21/2018, 18 pages, Doc. 44

Defendant Answer to Plaintiff's Original Complaint, 07/03/2018, 27 pages, Doc. 45

Plaintiff's Answer and Affirmative Defenses to GEO's Counterclaims, 07/24/2018, Doc. 50

Order Denying 2d Motion to Dismiss,
8/22/2018, 11 pages

Defendant First Amended Answer and Counterclaim to Plaintiff First Amended Complaint, 12/19/2018, 23 pages, Doc. 106

Order Granting Stipulation to Modify the Scheduling Order, 02/25/19, 2 pages, Doc. 124

(Proposed) Order on Request For Approval of Substituion or Withdrawal of Attorney, 03/12/19, 1 page, Doc. 125-1

Order on Requst for Approval of Substitution or Withdrawal of Attorney, 03/13/19, 1 page, Doc. 126

Order on Application of Non-Resident Attorney to Appear in a Specific Case, 04/22/19, 1 page, Doc. 150

(Proposed) Order on Application of Non-Resident Attorney to Appear, 06/06/19, 1 page, Doc. 158-1

Order on Application of Non-Resident Attorney to Appear in a Specific Case, 06/06/19, 1 page, Doc. 159

Notice of Motion to Amend Scheduling Order and Amend Pleadings, 8/16/2019, 15 pages, Doc. 167

Order by Judge Jesus G. Bernal Granting Stipulation to Modify the Scheduling Order, 08/30/19, 2 pages, Doc. 180

Plaintiff Reply in Support of Motion to Amend, 09/03/2019, 14 pages, Doc. 181

Third Amended Complaint for Declaratory and Injunctive Relief and Damages, 09/16/2019, 59 pages, Doc. 184

Plaintiffs' Memorandum of Points and Authorities in Support of Motion for Class Certification, 09/27/2019, 45 pages, Doc.192-1

Declaration of Raul Novoa, 09/27/2019, 4 pages, Doc. 192-3

Defendant Counterclaim to Plaintiff Third Amended Complaint, 10/15/2019, 38 pages, Doc. 200

Plaintiff Answer to Defendant Counterclaim, 10/28/2019, 7 pages, Doc. 204

Defendant Opposition to Plaintiff Motion for Class Certification, 10/28/2019, 40 pages, Doc. 205

Plaintiff Reply in Support of Class Certification, 11/04/2019, 31 pages, Doc. 209

Declaration of Lydia Wright in Support of Plaintiffs' Reply, 11/04/2019, 3 pages, Doc. 210-1

    Exhibits, 55 pages, Doc. 210-2

Defendants Motion to Exclude Declarations, 11/04/2019, 11 pages, Doc. 211

Plaintiffs Response in Opposition to Motion to Exclude Declarations, 11/08/2019, 10 pages, Doc. 213

Defendants Reply In Support of Its Motion to Exclude Declarations, 11/12/2019, 9 pages, Doc. 216

Transcript of Oral Proceedings, 11/18/2019, 31 pages, Doc. 224

Order Granting Motion for Class Certification and Denying Defendants Motion to Exclude, 11/26/2019, 28 pages, Doc. 223

Order Regarding Plaintiff's Motion to Compel, 12/06/2019, 7 pages, Doc. 227

Order on Plaintiffs Motion for Class Certification, 12/06/2019, 3 pages, Doc. 229

Declaration in Support of Defendants Motion for a Protective Order, 12/10/2019, 3 pages, Doc. 231

Defendants Motion for a Protective Order, 12/10/2019, 18 pages, Doc. 230

Exhibits (including Zoley declaration and email), 12/10/2019, 36 pages, Doc. 231-1

Exhibits, 12/16/2019, 46 pages, Doc. 233-1

Plaintiffs' Opposition to Defendant's Motion for a Protective Order, 12/16/2019, 13 pages, Doc. 233

Declaration of Colin Barnacle in Support of Defendant's Motion for a Protective Order, 12/20/2019, 2 pages, Doc. 235-1

Defendant's Reply in Support of Motion for a Protective Order, 12/20/2019, 11 pages, Doc. 235

Exhibits, 12/20/2019, 15 pages, Doc. 235-2

Order Granting Defendant's Motion for Protective Order, 01/02/2020, 6 pages, Doc. 242

Defendant's Supplement to Motion to Compel Production, 01/07/2020, 6 pages, Doc. 245

Plaintiff's Supplement to Motion to Compel Production, 01/09/2020, 8 pages, Doc. 246

Supplemental Declaration of Theodore Maya, 01/09/2020, 11 pages, Doc. 246-1

Declaration of Daniel Charest in Support of Plaintiffs' Ex Parte Application, 04/06/2020, 23 pages, Doc. 253

Memorandum in Support of Platintiff's Ex Parte Application for a TRO, 04/06/2020, 32 pages, Doc. 252-1

Plaintiff's Proposed Orders, 04/06/2020, 7 pages, Doc. 252-2

Plaintiffs' Ex Parte Application for a Temporary Restraining Order, 04/06/2020, 6 pages, Doc. 252

Declaration of David Pelt in Support of Defendant's Motion, 04/08/2020, 207 pages, Doc. 256

Defendant's Opposition to Ex Parte Application for a Temporary Restraining Order, 04/08/2020, 66 pages, Doc. 254

Defendant's Opposition to Motion for Expedited Discovery, 04/10/2020, 4 pages, Doc. 258

Supplemental Declaration in Support of Defendant's Motion, 04/13/2020, 63 pages, Doc. 262-1

Defendant's Supplement Opposing Ex Parte Application for TRO, 04/17/2020, 75 pages, Doc. 265

Plaintiff's Supplement to Ex Parte Application for TRO, 04/17/2020, 63 pages, Doc. 264

Judge's Order Denying Plaintiff's Application for TRO and Denying Plaintiff's Expedited Discovery Request, 04/22/2020, 13 pages, Doc. 268

Transcript of Proceeding, 05/20/2020, 78 pages, Doc. 276

Plaintiffs' Motion to Approve Class Notice Plan, 08/04/2020, 20 pages, Doc. 284

Defendant's Ex Parte Application to Extend Discovery Cut-Off Date to 10-30-2020, 08/21/2020, 89 pages, Doc. 300

Plaintiffs' Opposition to Ex Parte Application to Extend Discovery, 08/23/2020, 28 pages, Doc. 301

Defendant's Objection in Opposition to Plaintiff's Motion to Approve Class Notice Plan, 08/24/2020, 42 pages, Doc. 303

08- 21 Attachment 6 Proposed Order, 08/ /2020, 1 pages, Doc. 301-6

Plaintiffs' Motion to Approve Class Notice Plan, 08/04/2020, 20 pages, Doc. 284

Attachment 1 Declaration, 08/21/2020, 2 pages, Doc. 301-1

Attachment 2 Exhibit, 08/21/2020, 3 pages, Doc. 301-2

Attachment 3 Exhibit, 08/21/2020, 3 pages, Doc. 301-3

Attachment 4 Exhibit, 08/21/2020, 6 pages, Doc. 301-4

Attachment 5 Exhibit, 08/21/2020, 3 pages, Doc. 301-5

Attachment 1, Declaration, 08/23/2020, 5 pages, Doc. 300-1

Attachment 2 Exhibit, 08/23/2020, 26 pages, Doc. 300-2

Attachment 3 Exhibit, 08/23/2020, 27 pages, Doc. 300-3

Attachment 4 Exhibit, 08/23/2020, 3 pages, Doc. 300-4

Attachment 5 Proposed Order, 08/23/2020, 5 pages, Doc. 300-5

Attachment 6 Exhibit, 08/23/2020, 4 pages, Doc. 300-6

Attachment 6 Proposed Order, 08/23/2020, 2 pages, Doc. 300-7

Motion to Extend Discovery Cut-Off Date, 08/23/2020, 17 pages, Doc. 300

Attachment 1 Declaration, 08/24/2020, 3 pages, Doc. 303-1

Attachment 2 Exhibit, 08/24/2020, 3 pages, Doc. 303-2

Attachment 3 Exhibit, 08/24/2020, 16 pages, Doc. 303-3

Attachment 4 Exhibit, 08/24/2020, 2 pages, Doc. 303-4

Opposition to Plaintiff's Motion to Aprove Class Notice Plan, 08/24/2020, 18 pages, Doc. 303

Attachment 1 Declaration, 08/31/2020, 2 pages, Doc. 310-1

Plaintiff Reply in Support of Motion to Approve Class Notice Plan, 08/31/2020, 14 pages, Doc. 310

Defendant The GEO Group, Inc's Reply to Plaintiff's Opposition to Geo's Motion to ContinueTrial and Pretrial Dates and Reopen Discovery, 09/21/2020, 10 pages, Doc. 327

MOTION to Compel Responses_Information filed by Plaintiffs Jaime Campos Fuentes, Abdiaziz Karim, Ramon Mancia, Raul Novoa, 09/30/2020, 5 pages, Doc. 331

MOTION to Compel Production of Documents and Further Responses filed by Defendant The GEO Group, Inc, 09/30/2020, 9 pages, Doc. 332

MOTION to Exclude the Testimony of Dr, 10/01/2020, 4 pages, Doc. 333

Opposition to Plaintiffs Motion Regarding Discovery Dispute, 10/01/2020, 10 pages, Doc. 337

Response in Oppositon to Motion Compel Production of Documents and Further Responses 332 filed by Plaintiffs Jaime Campos Fuentes, Abdiaziz Karim, Ramon Mancia, Raul Novoa, 10/01/2020, 10 pages, Doc. 335

Motion to Strike GEO's Third Supplement to Initial Disclosures filed by Plaintiffs Jaime Campos Fuentes, Abdiaziz Karim, Ramon Mancia, Raul Novoa, 10/07/2020, 5 pages, Doc. 344

Motion to Exclude the Testimony of Serena Morones filed by Plaintiffs Jaime Campos Fuentes, Abdiaziz Karim, Ramon Mancia, Raul Novoa, 10/16/2020, 5 pages, Doc. 355

Opposition To Plaintiffs' Motion To Strike GEO's Third Supplement To Initial Disclosures, 10/19/2020, 20 pages, Doc. 357

Reply in Support Notice of Motion and Motion to exclude the Testimony of Dr, 10/19/2020, 12 pages, Doc. 356

Opposition to Plaintiffs' Ex Parte Application to Exceed Deposition Limit, 10/26/2020, 6 pages, Doc. 367

Opposition to Plaintiffs' Motion to Exclude Testimony of Serena Morones, 10/26/2020, 21 pages, Doc. 368

REPLY in Support Notice of Motion and Motion to Strike GEO's Third Supplement to Initial Disclosures, 10/26/2020, 10 pages, Doc. 366

Declaration in Response to Plaintiffs' Application to File Two Exhibits to Plaintiffs' Motion, 10/30/2020, 4 pages, Doc. 375

Reply in Support of Plaintiffs’ Motion to Exclude Testimony of Selena Morones, 11/02/2020, 13 pages, Doc. 376

Order Granting and Denying Plaintiffs’ Motion to Strike GEO’s Third Supplement to Initial Disclosures, 11/12/2020, 5 pages, Doc. 388

Response in Opposition to Motion, 8/21 /2020, 10 pages, Doc. 301

Plaintiffs' Memorandum in Opposition to GEO's Motion for Summary Judgement, 01/12/2021, 47 pages, Doc. 432

Plaintiffs' Opposition to Defendant's Motion to Decertify the Class, 01/12/2021, 23 pages, Doc. 433

Defendant Reply in Support of it's Motion to Decertify the Class, 01/16/2021, 24 pages, Doc. 437

Defendant's Reply in Support of Motion for Summary Judgement, 01/16/2021, 29 pages, Doc. 436

Plaintiffs' Reply Memorandum in Support of Motion for Partial Summary Judgement, 01/18/2021, 16 pages, Doc. 438

Judge's Order on Partial Summary Judgement, 01/25/2022, 36 pages, Doc. 542

Ugochukwu Goodluck Nwauzor v. The GEO Group, Inc., case no. 3:17-cv-05769,
(formerly Chao Chen v. GEO)

TACOMA, Washington facility.

Complaint, 09/26/2017, 6 pages, Doc. 1

Demand for Jury Trial, 10/12/2017, 3 pages, Doc. 14

Minute Order Regarding Discovery and Desposition, 09/28/17, 3 pages, Doc. 3

Order DENYING GEO's Motion to Dismiss,
12/06/2017, 19 pages, Doc. 28

Order On Motion to Seal, 12/11/17, 3 pages, Doc. 30

GEO's Corporate Disclosure Statement, 12/19/2017, 2 pages, Doc. 32

GEO's Reply, 12/20/2017, 15 pages, Doc. 33

Plaintiff's Motion to Dismiss or Strike Counterclaims, 01/10/2018, 17 pages, Doc. 37

Opposition to Chen's Motion to Dismiss Counterclaim, 01/29/2018, 33 pages, Doc. 38

Order on Motion to Dismiss for Failure to State a Claim, 02/28/18, 16 pages, Doc. 40

Facility List, 03/23/18, 5 pages, Doc. 45-2

Performance-Based National Detention Standards 2011, 03/23/18, 22 pages, Doc. 45-3

GEO Group's Response to Plaintiff's First Interogatories, 03/23/18, 34 pages, Doc. 45-4

ICE Volunteer Detainee Wage Payments, 03/23/18, 2 pages, Doc. 45-5

Initial Disclosures, 03/23/18, 5 pages, Doc. 45-6

Declaration on Devin Theriot-Orr, 03/23/18, 5 pages, Doc. 46

Declaration of Andrew Free, 03/23/18, 8 pages, Doc. 47

Declaration of Chao Chen, 03/23/18, 5 pages, Doc. 49

GEO Detention Handbook, 03/23/18, 39 pages, Doc. 49-1

Order on GEO Group's Motion From Deadline, 04/13/18, 4 pages, Doc. 60

Order on Motion to Dismiss, 04/26/2018, 10 pages, Doc. 67

Order on GEO Group's Motion for Order of Dismissal, 04/26/18, 10 pages, Doc. 68

Order on Plaintiff's Motion for Relief from Deadlines and for Status Conference, 05/15/18, 4 pages, Doc. 77

Order on Plaintiff's Motion for Leave to Amend Class Action Complaint, 06/13/18, 5 pages, Doc. 83

GEO's Motion to Dismiss, 06/27/2018, 32 pages, Doc. 91

Opposition to Defendant's Motion to Dismiss, 07/16/2018, 19 pages, Doc. 101

Exhibit A, 07/16/2018, 4 pages, Doc. 101-1

Exhibit B, 07/16/2018, 8 pages, Doc. 101-2

Exhibit C, 07/16/2018, 2 pages, Doc. 101-3

Exhibit D, 07/16/2018, 52 pages, Doc. 101-4

Declaration of Tracey Valerio, 07/20/2018, 6 pages, Doc. 105

Reply in Support of GEO's Motion to Dismiss, 07/20/2018, 18 pages, Doc. 104

Order on Stipulated Motion, 07/30/2018, 2 pages, Doc. 109

Plaintiff's Notice of Supplemental Authority, 08/01/2018, 4 pages, Doc. 110

Order on Motion to Dismiss for Failure to State a Claim, 08/06/18, 3 pages, Doc. 113

Order on Motion for Miscellaneous Relief, 08/06/18, 4 pages, Doc. 114

Order of USCA, 11/08/18, 1 page, Doc. 135

Order on Motion for Miscellaneous Relief, 03/20/19, 3 pages, Doc. 160

Order on Motion for Protective Order, 03/20/19, 5 pages, Doc. 161

Order on Joint Status Report, 04/08/19, 3 pages, Doc. 166

Order for Supplement to Oral Ruling, 05/28/19, 2 pages,   Doc. 175

Plaintiff's Notice Regarding Proposed Order in State of Washington v. GEO Group, 10/04/2019, 6 pages, Doc.189

Declaration of Andrew Free RE Notice, 10/04/2019, 3 pages, Doc.190

Order on State's Motion for Protective Order Quashing Subpoenas for Deposition, 11/14/2019, 11 pages, Doc. 206

Stipulated Motion for Relief from Discovery, 11/22/2019, 8 pages, Doc. 207

Order Granting Stipulated Motion for Relief of Discovery, 11/25/2019, 2 pages, Doc. 208

Declaration of Jamal, 12/12/2019, 7 pages, Doc. 210

Plaintiff's Proposed Order on Motion to Amend, 12/12/2019, 3 pages, Doc. 211

Response by Defendant on Motion to Amend Order, 12/23/2019, 12 pages, Doc. 213

Reply filed by Plaintiffs on Motion to Amend Order, 12/27/2019, 8 pages, Doc. 214

Second Declaration of Jamal N, 12/27/2019, 47 pages, Doc. 215

Order Regarding Plaintiff's Motion to Amend, 12/31/2019, 3 pages, Doc. 216

Declaration of Jamal N, 01/02/2020, 241 pages, Doc. 223

Declaration of Bruce Scott filed by Defendant, 01/02/2020, 2 pages, Doc. 228

Declaration of Colin Barnacle filed by Defendant, 01/02/2020, 405 pages, Doc. 229

Declaration of Colin L, 01/02/2020, 80 pages, Doc. 218

Defendant's Motion for Summary Judgment Requesting Oral Argument , 01/02/2020, 27 pages, Doc. 227

Motion to Exclude Expert Testimony of Christopher Strawn, filed by Defendant, 01/02/2020, 9 pages, Doc. 219

Motion to Exclude Expert Testimony of Jeffrey Munson, filed by Defendant, 01/02/2020, 11 pages, Doc. 217

Order Granting Defendant's Motion to Exclude Expert Testimony of Christopher Strawn, 01/02/2020, 2 pages, Doc. 226

Order Granting Defendant's Motion to Exclude Expert Testimony of Jeffrey Munson, 01/02/2020, 2 pages, Doc. 225

Plaintiffs' Motion for Summary Judgment Requesting Oral Argument, 01/02/2020, 25 pages, Doc. 221

Stipulated Motion to Seal, filed by Plaintiff , 01/02/2020, 10 pages, Doc. 222

Order Granting Stipulated Motion to Seal Documents, 01/06/2020, 9 pages, Doc. 231

Plaintiff's Redacted Motion for Summary Judgment, 01/07/2020, 25 pages, Doc. 233

Declaration of Jamal N, 01/13/2020, 29 pages, Doc. 238

Minute Order Granting Plaintiff's Motion to Amend Notice Plan, 01/13/2020, 4 pages, Doc. 235

Plaintiffs' Opposition to Defendant's Motion to Exclude Expert Testimony of Christopher Strawn, 01/13/2020, 7 pages, Doc. 236

Plaintiffs' Opposition to Defendant's Motion to Exclude Expert Testimony of Dr, 01/13/2020, 10 pages, Doc. 237

Declaration of Colin L, 01/15/2020, 10 pages, Doc. 240

Defendant's Objections To Plaintiff's Proposed Amended Notice Plan, 01/15/2020, 12 pages, Doc. 239

Motion of Immigration Reform Law Institute Brief in Support of Defendant's Motion for Summary Judgment and in Opposition to Plaintiffs' Motion for Summary Judgment , 01/15/2020, 21 pages, Doc. 243

Official Transcript of Preliminary Pretrial Conference held on 1_10_2020, 01/15/2020, 57 pages, Doc. 242

Order on Plaintiff's Motion to Amend Notice Plan and Renoting Motions for Summary Judgment, 01/15/2020, 3 pages, Doc.

Defendant's Reply in Support of Motion to Exclude Expert Testimony of Christopher Strawn, 01/17/2020, 7 pages, Doc. 247

Defendant's Reply in Support of Motion to Exclude Expert Testimony of Jeffrey Munson, 01/17/2020, 9 pages, Doc. 246

Order Denying Motion of Immigration Reform Law Institute Brief in Support of Defendant's Motion for Summary Judgment and in Opposition to Plaintiffs' Motion for Summary Judgment , 01/17/2020, 2 pages, Doc. 245

Order Granting in Part and Denying in Part State's Motion to Strike Defendant's Jury Demand and Procedural Order, 01/21/2020, 6 pages, Doc. 250

Order Denying Defendant's Motion to Exclude Expert Testimony of Jeffrey Munson , 01/24/2020, 2 pages, Doc. 251

Order Denying Without Prejudice Defendant's Motion to Exclude Expert Testimony of Christopher Strawn, 01/24/2020, 2 pages, Doc. 252

Stipulated Notice and Proposed Order Regarding Amended Notice Plan and Class Notices, 01/27/2020, 18 pages, Doc. 253

Stipulation and Order Regarding Amended Notice Plan and Class Notices, 01/30/2020, 6 pages, Doc. 254

Declaration of Colin L, 03/12/2020, 34 pages, Doc. 257

Declaration of Jamal N, 03/12/2020, 10 pages, Doc. 260

Defendant's Motion in Limine , 03/12/2020, 16 pages, Doc. 256

Plaintiffs' Motions in Limine , 03/12/2020, 6 pages, Doc. 258

Plaintiffs' Motions in Limine Requesting Oral Argument , 03/12/2020, 24 pages, Doc. 259

Notice of Withdrawal of Counsel filed by Defendant, 03/13/2020, 3 pages, Doc. 261

Stipulated Motion and Order Granting Plaintiffs’ Motions in Limine , 03/17/2020, 5 pages, Doc. 262

Declaration of Colin L, 03/23/2020, 28 pages, Doc. 267

Defendant's Opposition to Plaintiffs' Motion in Limine, 03/23/2020, 20 pages, Doc. 266

Declaration of Jamal N, 03/23/2020, 31 pages, Doc. 265

Plaintiffs' Opposition to Defendant's Motion in Limine, 03/23/2020, 12 pages, Doc. 264

Declaration of Jamal N, 03/27/2020, 284 pages, Doc. 275

Declaration of Jamal N, 03/27/2020, 70 pages, Doc. 273

Defendant's Opposition to Plaintiffs’ Motion for Summary Judgment, 03/27/2020, 27 pages, Doc. 274

Plaintiffs' Opposition to Defendant's Motion for Summary Judgment , 03/27/2020, 32 pages, Doc. 272

Defendant's Reply in Support of Summary Judgment (2020-01-02), 04/03/2020, 15 pages, Doc. 278

Plaintiffs' Reply in Support of Summary Judgment (2020-01-02), 04/03/2020, 15 pages, Doc. 279

Minute Oder Regarding Cross Motions for Plantiffs’ Summary Judgment, 04/07/2020, 1 pages, Doc. 281

Notice Regarding Opt Outs Filed by Plantiff, 04/07/2020, 6 pages, Doc. 282

Order on Cross Motions for Plantiffs’ Summary Judgment [Denying 221, 227, 233], 04/07/2020, 20 pages, Doc. 280

General Order on Motions in Limine, 04/10/2020, 2 pages, Doc. 284

Defendant filed Motion for Reconsideration of Order on Cross Motions for Summary Judgment , 04/21/2020, 12 pages, Doc. 288

Order Denying Motion for Reconsideration of Order on Cross-Motions for Summary Judgment, 04/23/2020, 7 pages, Doc. 289

Defendant Proposed Voir Dire, 04/24/2020, 7 pages, Doc. 290

Plaintiff filed Designation of Deposition Transcript of Bruce Scott Jr, 04/24/2020, 85 pages, Doc. 295

Plaintiff filed Designation of Deposition Transcript of Bruce Scott Jr, 04/24/2020, 123 pages, Doc. 294

Plaintiff filed Designation of Deposition Transcript of David M, 04/24/2020, 117 pages, Doc. 296

Plaintiff filed Designation of Deposition Transcript of Erwin Delacruz, 04/24/2020, 148 pages, Doc. 291

Plaintiff filed Designation of Deposition Transcript of Marc A, 04/24/2020, 92 pages, Doc. 293

Plaintiff filed Designation of Deposition Transcript of Michael Heye, 04/24/2020, 129 pages, Doc. 292

Defendant's Trial Brief, 04/29/2020, 25 pages, Doc. 302

Plaintiff's Trial Brief, 04/29/2020, 22 pages, Doc. 301

Letter from Judge regarding plaintiffs' deposition objections, 05/08/2020, 1 pages, Doc. 305

Court’s Rulings on Deposition Objections, 05/20/2020, 47 pages, Doc. 306

Notice of Withdrawl for Counsel filed by Defendant, 05/28/2020, 3 pages, Doc. 308

Stipulation Regarding Deposition By Remote Video Means, 06/10/2020, 7 pages, Doc. 309

Letter from Judge, 07/20/2020, 2 pages, Doc. 310

Court's Case Introduction to Jurors, 05/18/2021, 7 pages, Doc. 348

Judge Decides GEO Should Pay for Increased Wages, Not Taxpayer, 08/19/2021, 9 pages, Doc. 419

Federal Judge Cashes Out to Defend Private Prison, 08/30/2021, 3 pages, Doc. 425

State of Washington v. The GEO Group, Inc., case no. 3:17-cv-05806

Complaint, 09/20/2017, 6 pages

Order Setting Hearing On Motion, 11/07/17, 2 pages, Doc. 14

Order Denying GEO's Motion to Dismiss, 12/06/2017, 19 pages, Doc. 29

Order on Motion to Seal, 12/11/17, 3 pages, Doc. 30

Order on Motion to Remand, 12/13/17, 5 pages, Doc. 32

Order Regarding Discovery and Dispositions, 12/29/17,3 pages, Doc. 36

Order on State's Motion to Dismiss, 02/28/18, 15 pages,Doc. 44

Order on Motion for Miscellaneous Relief, 03/14/18, 2 pages, Doc. 49

Order on Motion to Dismiss, 04/26/18, 12 pages, Doc. 58

Order on Stipulated Motion, 06/29/18, 2 pages, Doc. 76

Order to Re-Note, 08/13/18, 4 pages, Doc. 96

Order on Motion for Protective Order, 08/27/18, 4 pages, Doc. 110

Order on Motion for Relief, 10/02/18, 11 pages, Doc. 133

Order on Motion for Reconsideration, 10/17/18, 2 pages, Doc. 143

Order on Motion for Miscellaneous Relief, 11/27/18, 5 pages, Doc. 157

Order on Motion for Summary Judgement, 12/10/18, 9 pages, Doc. 162

Order on Motion to Exclude, 12/13/18, 4 pages, Doc. 163

Order on Motion for Reconsideration, 12/27/18, 3 pages, Doc. 165

Order of USCA, 03/19/19, 2 pages, Doc. 178

Order on Motion for Miscellaneous Relief, 04/08/19, 3 pages, Doc. 181

Order on Motion for Partial Summary Judgement, 05/13/19, 11 pages, Doc. 202

Order on Motion for Protective Order, 05/13/19, 2 pages, Doc. 204

Order on Motion for Reconsideration, 05/23/19, 4 pages, Doc. 211

Order Regarding the Inspection of The Defendant's Facility, 06/20/19, 3 pages, Doc. 235

Order on Motion to Compel, 06/01/19, 7 pages, Doc. 243

Declaration of Amber Martin, 07/02/2019, 12 pages, Doc. 246

Attachment 2, 07/02/2019, 190 pages, Doc. 246-2

Attachment 3, 07/02/2019, 203 pages, Doc. 246-3

Order on Motion for Leave to File, 07/29/19, 3 pages, Doc. 278

Order on Motion for Summary Judgement, 08/06/19, 15 pages, Doc. 288

Statement of Interest of USA, 08/20/2019, 18 pages, Doc. 290

Order to Re-Note Motion, 08/22/19, 2 pages, Doc. 292

Memorandum of 9th Circuit Dismissing Defendant's Mandamus Petition, 09/03/2019, 3 pages, Doc. 296

Plaintiff's Response to Defendant's Motion for Reconsideration of Summary Judgement, 09/06/2019, 31 pages, Doc. 297

Defendant's Reply Supporting Reconsideration of Summary Judgement Order, 09/10/2019, 15 pages, Doc. 299

Defendant's Reply to State of Washington's Response RE Interest of the United States, 09/10/2019, 8 pages, Doc.

Declaration of James Kelly Supporting DOJ Statement of Interest, 09/12/2019, 48 pages, Doc. 303

Declaration of Joan K, 09/13/2019, 42 pages, Doc. 305

Declaration of Julie Williams Supporting DOJ Statement of Interest, 09/13/2019, 84 pages, Doc. 304

Judge's Proposed Order Granting Summary Judgement of Dismissal, 09/24/2019, 9 pages, Doc. 306-1

Declarations in Support of Plaintiff's Response - Byron Eagle, Sean Murphy, Theodore Lewis, Debra Eisen, Lezlie A, 10/04/2019, 119 pages, Doc. 313

Defendant's Response to Proposed Order, 10/04/2019, 3 pages, Doc. 320

Plaintiff's Response to Judge's Proposed Order, 10/04/2019, 29 pages, Doc. 308

Judge's Order Not Issuing Proposed Order, 10/09/2019, 3 pages, Doc. 322

Defendant's Motion for Reconsideration of Order, 10/23/2019, 9 pages, Doc. 324

Judge's Order Denying Defendant's Motion for Reconsideration, 10/28/2019, 2 pages, Doc. 326

Stipulated Motion and Order Establishing Deadline for Defendant's Document Production, 11/12/2019, 4 pages, Doc. 336

Plaintiff's Motion To Strike Defendant's Jury Demand, 12/05/2019, 17 pages, Doc. 342

Defendant's Opposition to Plaintiff's Motion to Strike Jury Demand, 12/16/2019, 15 pages, Doc. 344

Plaintiff's Reply in Support of Motion to Strike GEO's Jury Demand, 12/20/2019, 9 pages, Doc. 345

Judge's Order Partially Denying Plaintiff's Motion to Strike Jury Demand, 01/21/2020, 6 pages, Doc. 353

Declaration of Colin Barnacle RE Defendant's Motions in Limine, 03/12/2020, 34 pages, Doc. 356

Defendant's Motions In Limine, 03/12/2020, 13 pages, Doc. 355

Plaintiff's Motions in Limine, 03/12/2020, 21 pages, Doc. 357

Judge's Order on Motions in Limine, 03/17/2020, 5 pages, Doc. 359

Plaintiff's Response to Motions in Limine, 03/20/2020, 16 pages, Doc. 361

Defendant's Response to Motions in Limine, 03/23/2020, 118 pages, Doc. 365

Defendant's Trial Brief, 04/29/2020, 25 pages, Doc. 386

Plaintiff's Trial Brief, 04/29/2020, 38 pages, Doc. 385

Judge's Final Pretrial Order, 05/06/2020, 34 pages, Doc. 388

Judge's Order Regarding Deposition Objections, 05/08/2020, 1 pages, Doc. 389

Court's Ruling on Deposition Objections, 05/20/2020, 47 pages, Doc. 390

Exhibits, 08/20/2020, 59 pages, Doc. 397

Plaintiff's Motion to Compel, 08/20/2020, 13 pages, Doc. 396

Sealed Brenneke Declaration, 08/20/2020, 19 pages, Doc. 399

Reply in Support of Plaintiff's Motion to Compel, 09/01/2020, 3 pages, Doc. 400

Defendant's Opposition to Plaintiff's Motion to Compel, 09/02/2020, 29 pages, Doc. 401

Defendant's Motion for In Camera Review, 09/04/2020, 72 pages, Doc. 403

Plaintiff's Reply in Support of Motion to Compel, 09/04/2020, 9 pages, Doc. 405

Order Granting Plaintiff's Motion to Compel, 09/14/2020, 3 pages, Doc. 409

Washington's Response to GEO's Motion , 09/22/2020, 15 pages, Doc.

Washington's Response to Geo's Motion for Reconsideration of Order, 10/16/2020, 13 pages, Doc. at

GEO Group's Notice of Supplemental Authority on Hearing Transcript, 10/20/2020, 8 pages, Doc. 422

Geo's reply to Motion granting Washington's Motion, 10/22/2020, 13 pages, Doc. 424

Washington's Notive of Supplement Authority and Exhibit of Hearing Transcript, 10/23/2020, 59 pages, Doc. 425

Geo's Motion For Reconsideration of Order Granting Washington's Motion is Denied, 10/26/2020, 2 pages, Doc. 426

GEO Group's Motion for Judgement on a Matter of Law, 07/15/2021, 31 pages, Doc. 503

Plaintiff's Renewed Motion for Judgement, 07/30/2021, 17 pages, Doc. 498

GEO's Response to Motion for Judgement, 08/02/2021, 24 pages, Doc. 509

Plaintiff's Response to Motion for Judgement, 08/02/2021, 32 pages, Doc. 507

GEO's Response to Plaintiff's Reply to Motion for Judgement, 08/06/2021, 17 pages, Doc. 513

Reply in Support of Plaintiff's Motion for Judgement, 08/06/2021, 15 pages, Doc. 512

Alejandro Menocal et al. v. GEO Group, Inc., case no: 1:14-cv-02887, U.S. District Court, Colorado. 

Original Complaint- Menocal et al. v. GEO Group, Inc., 10/21/2014 (Doc. 1, 21 pages)

Order on Motion for Leave, 01/27/15, 1 page, Doc. 20

Order Denying Motion to Dismiss, 7/6/2015(Doc. 23, 14 pages)

Def. Motion for Reconsideration of Order Denying GEO's Motion to Dismiss,08/04/2015 (Doc. 29, 32 pages)

Pl. Motion to Strike Motion to Reconsider, 08/24/2015 (Doc. 31, 4 pages)

Order Denying Motion to Reconsider Denial of Motion to Dismiss, 8/26/2015, (Doc. 33, 3 pages)

Def. Motion to Stay Pending Interlocutory Appeal, 09/22/2015 (26 pages).

Stipulated Protective Order  Concerning Confidential Information, 02/08/16, 7 pages, Doc. 45

Order denying GEO Motion for Interlocutory Appeal,3/17/2016 (Doc. 48, 4 pages)

Motion for Class Certification and Appointment of Class Counsel, 05/06/2016 (Doc. 49, 27 pages), plus attachments below.

Attachment 1: Register of wage determinations under the Service Contract Act in Colorado, list of occupations and corresponding hourly wage (Doc. 48-2, 10 pages).
Attachment 2: Declaration of Alejandro Menocal Lepe (Doc. 49-2, 2 pages).
Attachment 3: Declaration of Grisel Xahuentitla-Flores (Doc. 49-3, 2 pages).
Attachment 4: Declaration of Lourdes Argueta (Doc. 49-4, 2 pages).
Attachment 5: Declaration of Jesus Gaytan (Doc. 49-5, 2 pages).
Attachment 6: Declaration of Demtrio A. Valerga (Doc. 49-6, 2 pages).
Attachment 7: Declaration of Carlos Eliezer Ortiz Mu&ntildeoz (Doc. 49-7, 2 pages).
Attachment 8: Declaration of Alejandro Hernandez Torres (Doc. 49-8, 2 pages).
Attachment 9: Declaration of Adriana Mendoza Castellanos (Doc. 49-9, 2 pages)
Attachment 10: Declaration of Brandt P. Milstein (Doc. 49-10, 2 pages)

Deposition of GEO Asst. Warden Dawn Ceja: conducted 03/29/2016,(Doc. 50-1, 74 pages)

Deposition of Melody Jean Furst: taken on behalf of the GEO Group, conducted 03/29/2016, filed 05/06/2016 (Doc. 50-5, 24 pages)

Aurora Sanitary Procedures Manual: Policy and procedure manual for the Aurora/ICE Processing Center by the GEO Group, filed 05/06/2016 (Doc. 50-2, 12 pages)

Aurora Detainee Work Plan Manual: Policy and procedure manual for the Aurora/ICE Processing Center by the GEO Group, filed 05/06/2016 (Doc. 50-4, 24 pages)

Detainee Grievance Forms: complaints from Alejandro Menocal Lepe and Marcos Brambila concerning pricing and detainee pay, filed 05/06/2016 (Doc. 50-7, 4 pages)

Detainee Handbook Local Supplement: supplement for the Aurora Processing Center with regulations for detainees, published by the GEO Group, filed 05/06/2016 (Doc. 50-3, 27 pages)

Man Days Billing Report Status Detail: billing status information for detainees between 11/1/2012 and 11/30/2012 for the Aurora Detention Center, filed 05/06/2016 (Doc. 50-6, 18 pages) ---------------------------------------

Judge Kane's Order Certifying Class, 2/27/2017. (Doc. 57, 21 pages).

GEO Petitioner, Appellate Court Documents, Case no. 17-701

GEO Petition to Appeal Judge Kane Order Certifying Class, 3/13/2017 (#01019778492, 34 pages)

Order on Proposed  Scheduling and Discovery Order, 04/05/17, 2 pages, Doc. 62

Grant of Petitioner's Appeal, 4/11/2017 (#01019793218, 1 page)

Order on Motion for Protective Order, 06/06/17, 9 pages, Doc. 84

Oder on Motion for Extension of Time to File, 12/18/17, 1 page, Doc. 113

Tenth Circuit Order Terminating GEO Appeal, 2/9/2018 (#01019793218, 39 pages)

Order on Motion to Withdraw as Attorney, 02/16/18, 1 page, Doc. 120

Order on Motion for Leave, 03/16/18, 1 page, Doc. 127

The GEO Group, Inc. v. Menocal et. al. Petition for Writ of Certiorari, 6/4/2018, 139 pages

Order Denying Defendant's 143 Request to Depose Abset Class Members, 09/18/18, 2 pages, Doc. 147

Order on Motion to Compel, 04/03/19, 2 pages, Doc. 175

Plaintiff's Motion to Compel Deposition, 05/30/2019, 244 pages, Doc. 181

Defendant's Brief in Opposition to Motion to Compel, 06/20/2019, 81 pages, Doc. 187

Plaintiff's Reply to Defendant's Response to Motion to Compel, 07/03/2019, 46 pages, Doc. 192

Supplemental Brief in Support of Motion to Compel, 09/10/2019, 18 pages, Doc. 206

Plaintiff's Third Motion to Compel, 09/24/2019, 11 pages, Doc. 207

Defendant's Response to Plaintiff's Motion to Compel, 10/01/2019, 8 pages, Doc. 211

Plaintiff's Reply in Support of Motion to Compel, 10/02/2019, 9 pages, Doc. 212

Courtroom Minutes for Discovery Conference, 10/18/2019, 2 pages, Doc. 227

Courtroom Minutes for Discovery Conference, 01/21/2020, 2 pages, Doc. 236

Transcript of Proceedings, 02/18/2020, 23 pages, Doc. 278

Courtroom Minutes for Discovery Conference, 04/08/2020, 1 pages, Doc. 258

Plaintiff's Motion for Summary Judgement, 04/29/2020, 45 pages, Doc. 260

Restricted Documents in Support of Plaintiff's Motion, 04/29/2020, 337 pages, Doc. 1

Unrestricted Exhibits in Support of Plaintiff's Motion, 04/29/2020, 492 pages, Doc. 261

Defendant's Response to Motion for Summary Judgement, 06/05/2020, 40 pages, Doc. 270

Defendant's Cross Motion for Summary Judgement, 06/25/2020, 29 pages, Doc. 284

Exhibits in Support of Plaintiff's Reply, 06/26/2020, 230 pages, Doc. 287

Plaintiff's Reply in Support of Motion for Summary Judgement, 06/26/2020, 116 pages, Doc. 286

Plaintiff's Response Opposing Cross Motion for Summary Judgement, 07/31/2020, 53 pages, Doc. 298

Defendant's Motion For Summary Judgement, 08/17/2020, 39 pages, Doc. 305

Defendant's Motion to Dismiss for Failure to Join Party, 08/17/2020, 41 pages, Doc. 307

Defendant's Motion to Decertify Class, 08/19/2020, 62 pages, Doc. 312

Defendant's Reply to Response to Cross Motion, 08/21/2020, 21 pages, Doc. 316

Exhibits A-K and Scheffey's Declaration of support for Geo's reply (in support of cross-motion for summary judgement) , 08/21/2020, 131 pages, Doc. 317

Geo's Response to Menocal's Motion for Jury View, 08/28/2020, 38 pages, Doc. 323

Order granting Geo's Motion to Restrict Exhibits, 08/28/2020, 2 pages, Doc. 320

(Menocal's) Reply to Motion for Jury View and Deposition transcript, 09/11/2020, 63 pages, Doc. 326

Menocal's Reply in support of Jury View, 09/11/2020, 13 pages, Doc. 325

Court Grants Geo's Motion to Restrict, 10/19/2020, 2 pages, Doc. and

Court Grants motion to restrict documents filed at ECF No, 10/28/2020, 10 pages, Doc. 341

Anthony Whyte v. Suffolk County Sheriff, Superior Court Civil Case no. 15-00444-E 

Anthony Whyte Affidavit of Indigency, 02/11/2015, 2 pages

Whyte Complaint, 02/18/2015, 9 pages

Motion to Vacate Hearing on Indigency and Fee Waiver, 2/19/2015, 8 pages

Suffolk County Motion to Dismiss, 5/4/2015, 19 pages

Order and Memorandum Granting Motion to Dismiss, 1/8/2016, 7 pages

    Massachusetts Appellate Court 2016-P-0751

Appellant Brief (Whyte), 07/25/2016, 32 pages

Appellee Brief (Suffolk County), 09/28/2016, 34 pages

Appellant Reply Brief (Whyte), 10/12/2016, 19 pages

State Appellate Panel Order, aff. lower court order, unpublished, 05/16/2017, 4 pages

Sylvester Owino and Jonathan Gomez et al. v. CoreCivic, case no. 3:17-cv-01112-jls-nls

Complaint, 05/31/2017, 36 pages, Doc. 1

Order Staying Case and Deferring Rule on 18 Motion to Dismiss, 02/16/18, 3 pages, Doc. 33

Order Granting in Part and Denying Motion to Dismiss, 05/14/18, 51 pages, Doc. 38

Order Granting Joint Motion for Entry of Protective Order, 08/13/18, 8 pages, Doc. 60

Order on Joint Motion for Determination of Discovery Dispute, 10/26/18, 9 pages, Doc. 69

Order on Motion for Reconsideration, 03/26/19, 7 pages, Doc. 82

Order on Motion for Discovery, 07/03/2019, 6 pages, Doc. 112

Order Setting Brief Schedule, 07/15/19, 1 page, Doc. 121

Order Granting in part and Denying in part 119 Defendant's Motion for Leave to File Documents Under Seal, 07/16/2019, 3 pages, Doc.

Reply to Response to 84 Motion to Certify Class (Gomez and Owino), 08/01/2019, 67 pages, Doc. 127

Order Continuing Hearing and Setting Briefing Schedule, 08/07/2019, 2 pages, Doc. 129

Order Granting 130 Joint Motion to Extend Discovery Motion Deadline , 08/19/2019, 3 pages, Doc. 131

Response in Opposition to 128 Motion to Exclude Evidence From Class Certification (CoreCivic), 09/05/2019, 21 pages, Doc. 132-1

Response in Opposition 97 Motion for Partial Summary Judgment (CoreCivic), 09/12/2019, 27 pages, Doc. 133

Order Granting 135 Defendant's Motion , 09/23/2019, 2 pages, Doc. 138

Reply to Response to 128 Motion to Exclude Evidence From Class Certification (Gomez and Owino), 09/26/2019, 8 pages, Doc. 139

Reply to Response to 117 Motion for Judgment on the Pleadings (CoreCivic), 09/26/2019, 24 pages, Doc. 140

Reply to Response to 97 Motion for Partial Summary Judgment (Gomez and Owin), 09/26/2019, 17 pages, Doc. 141

Order for Continuing Hearing, 11/07/2019, 3 pages, Doc. 143

Supplemental Briefing (Gomez Owino), 11/15/2019, 30 pages, Doc. 144

Supplemental Briefing (CoreCivic), 11/22/2019, 33 pages, Doc. 145

Notice of Filing Additional Declaration to Plaintiffs' Supplemental Briefings(CoreCivic), 11/26/2019, 9 pages, Doc. 147

Supplemental Briefing (Gomez and Owino), 12/02/2019, 43 pages, Doc. 148

Order Granting in part and Denying in part Plaintiffs' 149 Motion for Leave to File Documents Under Seal, 12/16/2019, 4 pages, Doc.

Motion to Seal a Previously Filed Document Under Seal(CoreCivic), 12/23/2019, 21 pages, Doc. Under

Response in Opposition 155 MOTION to Seal a Previously Filed Document (Gomez and Owino), 12/30/2019, 9 pages, Doc. 156

Reply to Response to 155 MOTION to Seal a Previously Filed Document (CoreCivic) , 01/06/2020, 19 pages, Doc. Under

Order Denying 155 Defendant's renewed Motion for Leave to File Documents Under Seal, 01/09/2020, 7 pages, Doc. Under

Transcript of Motion Hearing , 01/10/2020, 73 pages, Doc. 159

Supplemental Briefing(Gomez and Owin), 01/17/2020, 8 pages, Doc. 160

Supplemental Briefing (CoreCivic), 01/31/2020, 11 pages, Doc. 164

Notice Regarding Exhibit 41 and 42 Attachment (Gomez and Owino), 02/05/2020, 41 pages, Doc. 166

NOTICE Regarding Exhibit B, C, DAttachment (Gomez and Owino), 02/05/2020, 23 pages, Doc. 167

Notice Regarding Exhibit 11 Attachment (Gomez and Owino), 02/05/2020, 160 pages, Doc. 165

Order Requesting Supplemental Reply Brief from Plaintiff, 02/28/2020, 2 pages, Doc. 168

Supplemental Briefing (Gomez and Owino) , 03/09/2020, 12 pages, Doc. 169

Notice of Supplemental Authority; Motion for Judgment on the Pleadings (CoreCivic), 03/11/2020, 22 pages, Doc. 171

Notice of Supplemental Authority and Request for Supplemental Briefing (CoreCivic), 03/19/2020, 18 pages, Doc. 172

Notice of Supplemental Authority (Gomez and Owino), 03/20/2020, 12 pages, Doc. 174

Response re 172 Notice of Supplemental Authority and Opposition to Request for Supplemental Briefing (Gomeza and Owino), 03/20/2020, 5 pages, Doc. 173

REPLY to 173 Response, 172 Notice, in Support of Request for Supplemental Briefing (CoreCivic), 03/23/2020, 10 pages, Doc. 175

Reply to 174 Notice, 117 Motion for Judgment on the Pleadings, and to Plaintiffs' Response to Notice of Supplemental Authority (CoreCivic), 03/24/2020, 7 pages, Doc. 176

Response 174 Notice to Plaintiffs' Notice of Supplemental Authority (CoreCivic), 03/24/2020, 19 pages, Doc. 177

Reply to Plaintiffs Notice Of Supplemental Authority and to 174 Motion For Judgment On The Pleadings (Owino), 03/26/2020, 8 pages, Doc. 178

Order Denying Plaintiffs' motion for Partial Summary Judgement and Granting_denying in Plantiff's Motion for Class Certitification, 04/01/2020, 59 pages, Doc. 179

Status Report (Gomez and Owino), 04/15/2020, 10 pages, Doc. 180

Declaration of Nicholas D, 04/15/2020, 161 pages, Doc. 182

Joint Motion for Discovery Discovery Dispute No, 06/01/2020, 50 pages, Doc. 184

Order Following Case Management Conference, 06/03/2020, 2 pages, Doc. 186

Opposition to Corecivic's Motion for Reconsideration (Gomez and Owino), 06/04/2020, 34 pages, Doc. 188

Reply in Support of Motion for Reconsideration (CoreCivic), 06/11/2020, 31 pages, Doc. 190

Order Regarding Class NOtice and Settting Further Status Conference, 07/20/2020, 2 pages, Doc. 193

Order Regarding Joint Motion For Determination of Discovery No, 07/20/2020, 6 pages, Doc. 192

Noitce of Filing Objections to Plaintiffs Proposed Class Notices and Class Plan(CoreCivic) , 09/10/2020, 26 pages, Doc. 199

Notice of Filing Order Approving Plaintiffs' Class Notice Program (Gomez and Owino), 09/10/2020, 31 pages, Doc. 198

Order on Proposed Class Notices , 09/15/2020, 19 pages, Doc. 200

Owino's Propsed Content for Class Notices and Exhibits 1-9, 10/06/2020, 47 pages, Doc. 201

CoreCivic's Objections to Owino's Proposed Class Notices, 10/13/2020, 12 pages, Doc. 202

Court Order on Proposed Class Notice Plan, 10/28/2020, 6 pages, Doc. 203

Order on Proposed Class Notice Plan, 12/18/2020, 7 pages, Doc. 206

Plaintiffs' Response to Defendant's Notice of Non-Compliance, 01/08/2021, 4 pages, Doc. 209

Order Denying Defendant's Motion for Reconsideration, 01/13/2021, 19 pages, Doc. 210

Order Regarding Class Notice Plan, 01/13/2021, 2 pages, Doc. 211

 
CONTRACTS AND COMPLIANCE REVIEWS

Many of the contracts and Requests for Proposals (RFPs) are publicly available but practically obscure.
 
The payments for specific sites were released to me following FOIA requests.
Older ones were collected from the FOIA Reading Room.

Fed Biz Opps provides detailed information to contractors so they may prepare their bids; the packages here range from a single pdf of a few pages for a renewal to over a dozen of documents, some several hundred pages. Fed Biz Opps only maintains these packages for 365 days. Documents no longer available on that site have been uploaded to this website.

There are three categories of contracts:  
1) Between ICE and the private prison or security firms, e.g., ICE contracts with GEO to run the Tacoma facility.  
These are the most likely to include explicit reference to "Detainee Work" and pay at $1 per day.    Codes for this refer either to federal occupation categories of "guard service" or "food service."
Some of the contracts have the dollar amounts for either the rate or total budgeted redacted.  

2) Between ICE and cities or counties, called Intergovernmentmental Service Agreements and abbreviated by the government usually as IGSAs and sometimes as ISAs.  

2a.  If the contract contemplates a private subcontractor then it may include reference to "Detainee Work" and pay at $1 per day.  Codes for this refer either to federal occupation categories of "guard service" or "food service."  An example of this is the contract between ICE and the City of Adelanto.  I am presently litigating the redaction of the specific information on the detainee pay from these agreements and also the failure of ICE to provide the contract between the City of Adelanto and the subcontractor, GEO.  In these arrangements, the cities or counties receive what is effectively a kickback.  In exchange for greasing the wheels with the federal government, the local governments receive a three to five percent per diem cut of the payments from the federal government to the firm.

2b.  If the contract is with a city or county and the guard duties are performed exclusively by unionized city or county guards in facilities also housing criminal inmates, i.e., jails or prisons, then ICE tends to omit reference to the Detainee Work program altogether.  This appears to be in keeping with the federal government policy for contracting space for federal criminal inmates, as ICE contracts lift language from the Convict Work regulations, even though ICE has custody only over civil detainees.  There is also regional variation.

The contracts usually go out for several years.   The 2013 Request for Proposals for the contract at the Krome facility in Miami, Florida, for instance, goes out to 2024.
 
Some are indefinite and are simply renewed with addenda for increases in the per diem compensation, per the terms of the initial contract.  A contract signed in, say, 2008, therefore, may be still largely in effect today.


Adelanto, California, IGSA Group, subcontractor   

Contract for 2011-2016 EROIGSA-11-0003 (2011)(235 pages)

Contract with Schedules and Compliance Standards EROIGSA-11-003 (2011) (409 pages)

FOIA Appeal, remanded, now in litigation.ICE FOIA response includes unlawful redaction of amounts and unlawful withholding of contract between Adelanto and GEO.  Work program referenced but not amounts of payments.

p. 6  Total amount of award: almost $175 million

p. 32  References Voluntary Work Program, boilerplate description. 

Almance County, North Carolina

Almance County, North Carolina, 2007
Highlights
p. 1 $61/day payments per detainee
p. 6  Explicitly prohibits "employment of unauthorized aliens" and indicates only work performed by detainees should be cleaning of their personal area, but also references addenda that are not included.
p. 8  Indicates ICE payment policy since 1999 that was not followed for payments from 2000 to 2009 for resident work program at El Centro.  "The Service Provider shall provide ICE with the
information needed to make payments by electronic funds transfer (EFT). Since January 1, 1999, ICE makes all payments only by EFT [Electronic Fund Transfer]."  However, the FOIA release from El Centro indicates the program was balanced by INS and then ICE through "Imprest Reports."  Imprest funds are petty cash.  The Paper discusses the Department of Treasury's (DOT) prohibition of using these funds for programs such as detainee pay.  The use of imprest funds in violation of ICE and DOT policy calls into question the accuracy of ICE data on its payments for this program.

This language appears in several other but not all ICE contracts and is quoted here to underscore the irregularity of the imprest fund payments when and if they occur.

-No reference to a Detainee Work Program, highlighting program's use to defray costs for private providers and not to further official policy appearing in the Performance Based National Detention Standards.

Aurora, Colorado, GEO Group

Amendments to Contract (2005) (46 pages)

p.7 "Manage a Detainee Work Program"

p. 8 Model Quality Assurance Plan.

Contract 2006 (326 pages)

Broward, Pompano Beach, Florida

Contract 2009 (7 pages)

Sections A and B only. p.2 and 3:Detainee Volunteer Work Program.

Cobb County, Georgia, 2008  
Contract, 2008
Highlights
p. 2  $42.58/day payments per detainee
p. 8  Explicitly prohibits "employment of unauthorized aliens" and indicates only work performed by detainees should be cleaning of their personal area, but also references addenda that are not included.
-No reference to a Detainee Work Program as referenced in the Performance Based National Detention Standards, highlighting program's use to defray costs for private providers and not to further the stated policy.
 
Denver, CO, Solicitation for New Contractor Owned and Operated Detention Facility, 2011 (through 2017)

Statement of Objectives (SOO) (4 pages)
p. 1.  Points out that the language in the RFP will be part of the contract: "In response to the Government’s solicitation and SOO, offerors shall propose a Performance Work Statement (PWS) that both complies with ICE operational and legal requirements and specifically correlates with the offeror’s proposed solution. Accordingly, the final PWS will become a part of the resultant contract."

p. 2.  525 bed facility (497 male, 28 female)--

p. 3  ICE data on length of stay:  "During FY2010, 90% of the ICE detainee population was housed for two months or less; 51% of that population were housed for two weeks or less, and 25% were housed for one to three days."  
About half held for more than two weeks.  This is the population that would be most likely to participate in the work program, although even those held for just a few days have reported their participation.  
(Also, ICE data on this are misleading--those in ICE custody are frequently moved.  For purposes of the data above, ICE starts the clock over.  

An NGO recently received a FOIA release on time in detention for a specific day among all those held and the average is significantly higher.  Source: Director of NGO, findings have not yet released, May, 2014.)

Amendment 1 (4 pages)
Q and A about information, inlcluding pricing, staffing, and management  

Amendment 2 (4 pages)
Q and A about information.  
p. 2  "The average daily population is 417."

Statement on Deliverables   (3 pages)
p. 3  Requires information on "Detainee Work Clearances" -- indicating expecation of Detainee Work for private contractor

Quality Assurance (27 pages)
p. 9  5% weighting of "Justice," which covers how the contractor handles grievances, including those about work:  
"A Contract Discrepancy Report that cites violations of PBNDS [Performance Based National Detention Standards]
 and PWS [Performance Work Scope] sections that treat detainees fairly and respect their legal rights, permits the Contract Officer to withhold or deduct up to 5% of a monthly invoice until the Contract Officer determines there is full compliance with the standard or section."   In other words, if a facility does not respect the rights of those in its custody,  including responding to grievances about forced work, the worst that happens is that it loses 5% of its contract for a limited period, though this funding could be only withheld.

p. 20  Food Service:  "Detainees receive safety and appropriate equipment training prior to beginning work in department."

p. 24  Evaluation Sheet, includes requirements for maintaining data on "Voluntary Work Program" participation and pay 

Solicitation--includes language for extensions through 2017 (127 pages)
p. 4, Reference to "Detainee Work":
"Stipend for Detainee Work Program - Reimbursement 76650 DA
for this line item will be at actual cost of
$1.00 per day per detainee. The contractor shall
not exceed the quantity shown without prior
approval by the Contracting Officer.
Product/Service Code: S206
Product/Service Description: GUARD SERVICES"

The parallel column as well states that the total days of employment available for $1 per day pay is 76650 and the "unit" is "DA."

At 100% use of reimbursed stipend = 76650 days of work at 58/day =  $4,445,700 for work performed at $7.25 hr/8 hour day.  Savings to private firm =  $4,369,050
At 90% use of reimbursed stipend =   68985 days of work at 58/day =  $4,001,130 for work performed at $7.25 hr/8 hour day.  Savings to private firm = $3,932,145

Estimates for Number of People Working
Maximum monthly wage for each ICE resident = $20 (5 days at $1 per day)--rules do not permit more than 40 hours work/week and each shift counts as up to 8 hours.  

Total monthly stipend spent at 100% = $6388
Number of people potentially employed in one month is between 319  (6388/$20) and 6,388 (if people cycled through at fastest rate possible and everyone worked for one day at $1)
For one day average minimum number also is 319.  

Total monthly stipend spent at 90% = $5749  (if firm does not use entire budget)  (El Centro used 92% of budget)
Total number of people potentially employed in one month is between 287 (5749/20) and 5749 (if people cycled through at fastest rate possible and everyone worked for one day at $1).  

For one day at 90% of amount budgeted for "Detainee Work," the average number working would be 191, or 44 percent of those in ICE custody at this facility on any given day.

E-QIP procedures for applicants (28 pages), instructions for applicant to complete E-QIP procedures for hiring purposes

Past Performance Information Form (1 page), worksheet to identify contract performances

EL CENTRO, California (CLOSED)

Ahtna Technical Services (2001-2009), 462 pages

Solicitation 2009 93 pages 

Contract 2009 (166 pages)

Missing Sections A and B.

Table of El Centro Actual Disbursements November 2009 to October 2010

El Paso, Texas, PSC

Performance Work Statement (90 pages)

Elizabeth City, New Jersey, CCA

2005 to 2023, including option periods  (139 pages)

p. 27
"The detainee work plan must be voluntary, and may include work or program assignments for industrial, maintenance,
custodial, service or other jobs. The detainee work program shall not conflict with any other requirements of the contract and must comply with all applicable laws and regulations. (Technical Exhibit 7 - ICE Voluntary Work Program
p. 83
Exhibit 7 Form indicating pay at $1/day.  No maximum amount in contract.

Annual Compliance Review (2012)

Orders and Amendments to 2005 Contract (128 pages)

Eloy, Arizona CCA

(2006-09) 

Contract omits reference to Detainee Work program, but facility does have this program.

Gastonia, North Carolina (Gaston County)

Gaston County Jail 2007 (19 pages)
No reference to detainee work program


Florence, (SPC) Arizona

Scope of Work Questions and Responses, 2009 (56 pages)

p. 32
"140. Assuming detainee cleaning crews (in addition to detainees in residence) clean
housing units, there does not appear to be a post associated with “housekeeping”.
Does the contractor provide any janitorial labor/or a detainee labor supervisor?
A: Housing Officers supervise housing unit cleaning, escorts/compound
supervise outside details.

143. Section C, Subsection 6 (page 38): Can detainees be used to provide laundry
services as part of their paid work?
A: Yes.

144. Subsection 6 Detainee work details: Can ICE provide a range or estimate of
how many hours or days of detainee work details there are? Can these work details
generally be monitored by positions listed in Attachment 1 or are extra people
needed for this task? What tasks do detainees regularly perform?
A: The RFP will be revised to reflect an estimated quantity of 80,000 hours
annually for CLIN 0003. Reimbursement for this line item will be at actual cost.
The offeror is responsible for providing a solution to the requirements. Some of
the duties detainees perform include laundry, food service and janitorial."

Solicitation, 2009, Amended (122 pages)

p. 2
"Question 144 The response is changed to read
“The RFP will be revised to reflect an estimated
quantity of 54,531 detainee work days per year
for CLIN 0003. Offerors should propose $1.00 per
detainee work day for 54,531 days."

ADP for 2009  = 383  

54531 days of work at 58/day =  $3,162,798 for work performed at $7.25 hr/8 hour day.  Savings to private firm =  $3,108,267
At 90% use of reimbursed stipend =   68985 days of work at 58/day =  $4,001,130 for work performed at $7.25 hr/8 hour day.  Savings to private firm = $3,932,145

Estimates for Number of People Working
Maximum monthly wage for each ICE resident = $20 (5 days at $1 per day)--rules do not permit more than 40 hours work/week and each shift counts as up to 8 hours.  

Total monthly stipend spent at 100% = $6388
Number of people potentially employed in one month is between 319  (6388/$20) and 6,388 (if people cycled through at fastest rate possible and everyone worked for one day at $1)
For one day average minimum number also is 319.  

Total monthly stipend spent at 90% = $5749  (if firm does not use entire budget)  (El Centro used 92% of budget)
Total number of people potentially employed in one month is between 287 (5749/20) and 5749 (if people cycled through at fastest rate possible and everyone worked for one day at $1).  

For one day at 90% of amount budgeted for "Detainee Work," the average number working would be 191, or 44 percent of those in ICE custody at this facility on any given day.


Henderson, UT

Annual Compliance Review (2012)


Houston, Texas (CCA)

Contract 2003-09  (246 pages)
p. 3 References "detainee wages" at $1 per day, no maximum amount indicated for any of the periods, as opposed to all other contract line items

p. 8
Indefinite contract

p. 51
Contractor shall prepare meals on site

p. 53
Canteen proceeds to go to detainee recreation/welfare fund
p. 212
CCA letter to ICE requesting increased compensation because of increased wages, states CCA has held 317,042 detainees in 12 months of 2006-07.

p. 242  Adult Detainee Wages listed at annual $95265  (all other years this amount is redacted, appearance here appears to be accidental compliance with the FOIA law)  (2007)

Houston ADP 2007 = 864

At 100% use of reimbursed stipend = 95265 days of work at 58/day =  $5,525,370 for work performed at $7.25 hr/8 hour day.  Savings to private firm =  $5,430,105
At 90% use of reimbursed stipend =   days of work at 58/day =  $4,972,833 for work performed at $7.25 hr/8 hour day.
  Savings to private firm = $4,887,094

Estimates for Number of People Working
Maximum monthly wage for each ICE resident = $20 (5 days at $1 per day)--rules do not permit more than 40 hours work/week and each shift counts as up to 8 hours.  

Total monthly stipend spent at 100% = $7939
Number of people potentially employed in one month is between 397  (7939/$20) and 7939 (if people cycled through at fastest rate possible and everyone worked for one day at $1)
Average Daily Employment  = 265 (7939/30 days), or 30% (265/864).  

Total monthly stipend spent at 90% = $7145 (if firm does not use entire budget)  (El Centro used 92% of budget)
Total number of people potentially employed in one month is between 357 (7145/20) and 7145 (if people cycled through at fastest rate possible and everyone worked for one day at $1).  

For one day at 90% of amount budgeted for "Detainee Work," the Average Daily Employment would be 238, or 28%.


Houston CCA, 2009-10 (7 pages)

p. 3  Funding in support of Detainee Volunteer Wages 20000

Performance Work Statement (156 pages)

Justification and Authority, 2014 (to renew CCA contract without open bidding) (5 pages)

p. 1  "The contract expires on March 31, 2014.  The current value of HSCEDM-09-D-00007 is $182,749,821.76.  This extension would raise the value ... to $222,000,854.71."

p. 2  "The re-competition of this requirement has undergone significant delays due to unexpected budgetary constraints.  A new contract cannot be awarded before the current contract expires on March 31, 2014."

p. 3  Indicates that it posted a Request for Information in 2012 and of the 5 potential bidders -- CCA, The GEO Group, Community Education Centers, In, Jaguar Security, Inc., and Management and Training Corporation, and that only CCA was qualified.

p. 4  Detainee Volunteer Wages Qty 21,000 Unit Price $1.00/day.  
ICE is referring to these payments as "wages."

NOTE:  Reports from individuals held by ICE in Houston, CCA reveal off-the-book compensation in food and desirable shifts, as well as coercion. Therefore, the lower range of actual payments demonstrably does not reflect work performed. Please see the accounts of Frank Serna and Robinson Martinez.  

Joe Curley Detention Facility, Montgomery, Texas

Karnes County, Texas (GEO)

IGSA 2010 (154 pages)

p. 4  $58/ to $68/per diem

p. 83 Detainee Work Program
"The detainee work plan must be voluntary, and may include work or program
assignments for industrial, maintenance, custodial, service, or other jobs."

p. 87  
Restrictions on commissary profits, must benefit detainees.

p. 131
"9. DETAINEE OR MEMBER OF THE PUBLIC COMPLAINTS
The detainee and the public are the ultimate recipients of the services identified in this
Agreement. Any complaints made known to the COTR will be logged and forwarded to the
Service Provider for remedy. Upon notification, the Service Provider shall be given a prespecified
number of hours after verbal notification from the COTR to address the issue."

p. 135
"Justice" section of Performance Requirements at 5%.

p. 139, and p. 149
Detainee Work Assignments to be reported monthly

p. 145
Detainees part of food service plan

KENOSHA COUNTY, WI

Annual Compliance Review (2011)   

Krome Detention Facility, Miami, FL (AKAL Security)

Contract (2015) (662 pages)

Food Service (2012) (2 pages)
Table on 14/30 ratio of Detainee Workers/Legally Paid Workers

30 x 365 =  

Payments by category through 2024
p. 2  Detainee Wages, refers to "Evaluation Program" for portion used for Food Services, (even though this is standard operating procedure already.  Uses same language of "evaluation only" through 2024.

"Expenses for this CLIN shall not exceed $3,000 per month. Contractor shall be reimbursed on the award document for expenses as incurred. Detainees earn $1.00 per day.
$30,000 will be used for the purposes of evaluation only.

Product/Service Code: S203
Product/Service Description: Food Services
Period of Performance: 02/01/2014 to 11/30/2014"


Solicitation Contract Sections A and B (2012) (31 pages)
p. 4  Detainee Wages for 6/2013 to 8/2014 listed at $9150, at $10,950 for 12 months in subsequent years.

Note:
30 food workers/day x 365 = 10950

Krome ADP 2013 = 568

At 100% use of reimbursed stipend = 30000 days of work at 58/day =  $1,740,000 for work performed at $7.25 hr/8 hour day.  Savings to private firm =  $1,710,000  

Estimates for Number of People Working
Maximum monthly wage for each ICE resident = $20 (5 days at $1 per day)--rules do not permit more than 40 hours work/week and each shift counts as up to 8 hours.  

Total monthly stipend spent at 100% = $2500 
Number of people potentially employed in one month is between 125  (2500/$20) and 2,500 (if people cycled through at fastest rate possible and everyone worked for one day at $1)
Average number is 83, or 15%  
NOTE:  Not clear if 30,000 includes Food Service Detainee Wages.
This would mean an additional 30 workers/day for a total of 113, or Average Daily Employment of 20%.  Also, language in Scope of Work requirement for new manual and odd budgeting as "evaluation" indicates possible current payments outside work program budget.
 

Solicitation Section C (PWS) (2012) 61 pages

Statement of Objectives (2012)

pp. 21-3  Detainee Work Program, standard language on this.  
"Submit a food service staffing plan and shall maintain this staffing in accordance with the Staffing Plan. Detainee work detail staff may be included in the Staffing Plan, only with ICE approval."

Language states workers not to be used in food preparation.  Other contracts state this as well.
Detainees report preparing food at direction of food service legally paid employees.

p. 35  "The contractor shall develop a site-specific Voluntary Work Program operations manual for the management of this program."  This has been unlawfully withheld from release under FOIA.

RFP Q and A
p. 7  Juveniles held at nearby hotel.

1998-03 (99 pages)

pp. 46-47  No mention of detainee work program, including typical place requiring documentation of participation (and see pp. 83-4)

Mira Loma, Los Angeles County (IGSA)- CLOSED 2012

1997-2007 (107 pages)
No reference to work program.
Lawyer committee review 2004 notes program exised, detainees were paid with superior living quarters (e.g., cable television) and food. Mira Loma contract ended in 2012, detainees transferred to new Adelanto facility, under contract with GEO through ICE IGSA with City of Adelanta.  Shift because of wage requirements of Los Angeles County Sheriff union when contract up for renewal, much higher than GEO wages. Source: government employee at Mira Loma, 2012.

Annual Review. American Bar Association, Commission on Immigration. Latham and Watkins Delegation, no. 502130-0018.  2006


Orange County, IGSA 
2010-2015  (5 pages, update on separate agreement, signed 2013)



Otay Mesa, San Diego, California, CCA

Contract 1999 (3 pages, Sections A and B only)

Contract (2005) Amendments and Orders (393 pages)

Pinal County Adult Detention IGSA

2006-08 IGSA (35 pages)

p. 9  Unusual classification of performance requirements, lumps several services and access to legal materials into one category (15%) and grievances into another (5%).

p. 28  $59.64/per diem

p. 32  Indicates just 11 grievances received, none resolved in favor of detainee

p. 33  Checklist Evaluation Worksheet, "Detainee Work Program" checked Not Applicable [Paid work performed by jail inmates, ICE detainees forced to work, or incentivized by food.]

pp. 34-5  Two suicides in period of review.  
Narratives provided.  
Facility receives excellent marks.

Perry County, Alabama  (Perry County)

IGSA (2007-2012)  (52 pages)
No reference to detainee work program

Polk County, Texas (Community Education Centers)

2012, Local contract between County and CEC  (15 pages)
Note:  Says it is the sole operating agreement, no reference to terms of inmate work

IGSA between ICE and Polk County (70 pages)
 

p. 3  
Contract for "prisoner day[s]"

Note:
No Contract Line for Detainee Work Program


Annual Compliance Review, by Creative Corrections, 2009 (10 pages).


Port Isabel, Texas, Ahtna Technical Services, Inc.

2014 Solicitation (221 pages)

p. 5  Detainee Voluntary Worker Wages @ $1.00/Day 120000 DA
Minimum Days: 0 Days
Maximum Days: 120,000 Days
(Option Line Item)
Product/Service Code: S206
Product/Service Description: HOUSEKEEPING- GUARD
Period of Performance: 06/01/2015 to 05/31/2016

At 100% use of Detainee Wages = 120,000 days of work at 58/day =  
$6,960,000 for work performed at $7.25 hr/8 hour day.  
Savings to private firm =  $6,840,000

At 90% use of Detainee Wages =  
$6,264,000 for work performed at $7.25 hr/8 hour day.  
Savings to private firm = $6,144,000

Estimates for Number of People Working
Maximum monthly wage for each ICE resident = $20 (5 days at $1 per day)--rules do not permit more than 40 hours work/week and each shift counts as up to 8 hours.  

Total monthly detainee wages at 90% = $9,000

Average Daily Population for 2013 = 1115
  
Total number of people potentially employed in one month is between 450 (9000/20) and 9000 (if people cycled through at fastest rate possible and everyone worked for one day at $1).

Average daily employment (9000/30 days)   
300
Average Percent Employed/Day (1115/300)
27%

p. 39 "Detainee work detail volunteers may assist food service staff, but shall not be
depended upon to fulfill basic SOW [Scope of Work] requirements."  
Indicates that ICE is aware of illegal character of actual reliance by ICE contractors on detainee work and attempts to cover up reliance by private firms on detainee work, of which ICE is well aware, e.g., circulation of
 Food Service staffing showing ratio of 30 detainee workers/14 SCA-covered workers.

p. 60  "10.8 Laundry Facility
The Contractor shall supervise and manage the PIDC detainee laundry facility. The
Detainee Voluntary Work Program will be provided as a Government-furnished service
for Contractor use (see Section C.9.19) in the laundry facility."

Government inserting in its own contract provisions for the use of detainee labor to meet requirement of laundry service, contradicting statement that contractor is not to rely on detainee work for meeting Scope of Work requirements.

p. 61  Under instructions for managing laundry detainee work detail, contractor is instructed to
"Avoid disciplining any detainee or violating any detainee rights during work time."

Highlights understanding by ICE that there is a legal difference between objectives for "work time" and those of custody.
Makes evident the violations of the Fair Labor Standards Act, which applies to work absent certain exemptions, none of which include the use of aliens held under immigration laws to clean laundry.

p. 141
"[T]ransportation services with no defined minimum quantities, stationary guard or escort services, transportation mileage or other Minor Charges such as sack lunches and detainee wages): shall be fully supported with documentation substantiating the costs and/or reflecting the established price in the contract and submitted in .pdf format."
This information is responsive to my previous requests and have been withheld in violation of the Freedom of Information Act.
 

p. 196  Table on how contractors are to allocate costs,
"DETAINEE WORKER WAGES" are under heading
"COSTS WHICH SHOULD NOT BE INCLUDED IN THE RESPECTIVE CLIN(s)"[Contract Line Item Number]
Instructing contractors not to use per diem bed cost payments [CLIN 1] to cover detainee wages.

p. 197
For Detaine Wage CLIN column on Costs Note To Be Included:
"PROFIT ON DETAINEE WAGES"  
A program that is the key component of the prison firms profits must use the dollars budgeted for this only for paying the detainee wages of $1 day, not profits to the firm.  
(It would appear the sole purpose of this line is to amuse those who have read Franz Kafka.)

Department of Labor Wage Determination (11 pages)
Texas Counties of Brooks, Cameron, Dimmit, Duval, Frio, Hidalgo, Jim
Hogg, Kenedy, La Salle, Maverick, Starr, Webb, Willacy, Zapata, Zavala.
p. 4.  Laundry, Machine Washer = $8.31
p. 11  "ALL OCCUPATIONS LISTED ABOVE RECEIVE THE FOLLOWING BENEFITS:
HEALTH & WELFARE: $3.81 per hour or $152.40 per week or $660.40 per month."

Cost and Pricing Summary Template (5 pages)
p. 5
"The Voluntary Work Program is a fixed price funded by the Government, and paid to the detainee by the Contractor. For cost estimating purposes, utilize the provided $100,000.00."

Note:  There is a clear discrepancy between budgeting policy stated in contract --  "fixed price" of $1 per day -- and the budgeting policy in the PBNDS --"at least $1 per day."  Contractors actually do pay more than $1 per day in some facilities for occupations that are core to their operations and do not have needed workers.  This discrepancy implications for program's legality, insofar as it reveals discrepancy between stated policy, its rationale, and the de facto practices.

Questions And ICE Responses (March 28, 2014) (150 pages)
pp. 130-131  
Description of detainee work duties (barber, food service, plate detail, etc.) and indicates they are authorized to work outside the secure perimeter "as needed," but does not indicate those positions.

Performance Requirements Summary (10 pages)

pp. 8-9
"Justice" (incl. law libraries, access to rights presentations, and grievances) weighted at 10%.
"Detainee Discrimination" weighted at 10%

Total for Justice and Detainee Discrimination =
20% 

NOTE
These weightings are significantly higher than those in other contracts.  


Past Performance Questionnaire: For Detention Management, Transportation and Food Services

Port Isabel Detention Center Site Visit: ICE Responses to Site Visit Questions Received in Accordance with Solicitation Instructions

Bidding Spreadsheet Template 


Port Isabel Facility Map


Contract 2008 - 2013

No reference to amount allocated for resident wages.

p. 72  Requires list of "Authorized Detainee Workers."

p. 80  Weights the adequate protection of "detainee rights" at 5% of performance goals. These include access to legal materials, group presentations of legal rights, and use of punitive segregated cell assignments.If facility fails on all of these they are at most penalized 5% of their contract.

p. 83  First infraction of Detainee Rights, penalty at 1.25%, escalating to 4th infraction at 5%.

p. 101 Performance Review Checklist, "Volunteer Detainee Work Program," "Facility has a Volunteer Work Program," column O indicated, and not "Daily, Weekly, Monthly."  "O" not defined but only a handful of other programs use this column.  The PBNDS have references to "Optimal" standards, a euphemism for optional, e.g., "**Facilities operating at the optimal level shall offer detainees at least two hours of recreation or exercise opportunities per day, seven days a week." p. 348, PBNDS.
 

Non-competitive Renewal, 2014

"The re-competition of this requirement will not be awarded in time to allow for continuity of the mission critical services, or the proper transitioning of Contractors. Any lapse in services would jeopardize the safety of detainees and ICE personnel working at the facility."


Pearsall Facility, GEO

2004-2010 ICE contract with GEO, incl. transportation for other Texas facilities (368 pages).

p. 8 References "Adult Detainee Volunteer Wages, Amt Per Day."  All amounts unlawfully redacted.

p. 53  Reference to Detainee Work Program

Questions and Responses, RFP, 2011 (18 pages)

Performance Requirements Summary, 2011 (4 pages)
p. 4 "Justice," including grievance procedures, weighted at 5%
Mentions Detainee Volunteer Work Program

Facility Design Standards (435 pages)
How to Build Your Own Detention Facility, includes descriptions of segregated management units

Southwest Texas Detention Facility (2008-2010), GEO  (40 pages)

References "Detainee Volunteer Work Program" and code for charges to S206 Guard Services, amounts unlawfully redacted

San Diego, California, ICE ERO Janitorial Contract (for purposes of cost and wage comparisons)

Solicitation, 2010  (55 pages)


Puerto Rico, MVM 
Three facilities and transportation (2008-2013)  (179 pages)

No details on detention facilities
MVM also does not list the facilities it manages



San Antonio, TX
Request for Proposal, offered 2011, for 2011 to 2016 (60 pages)
p. 3
Detainee Work Program has a Contract Line Number but no days or amounts listed.  Code is for "Guard Services."

Compliance Inspection of Laredo Processing Center (12 pages) Conducted on January 24-26, 2012; found to be "well managed" (p.5)

Stewart County, GA  CCA
IGSA for 2006 to 2009 (60 pages)

Annual Compliance Review (May 13-15, 2008) (76 pages)

Tacoma, Washington GEO
66 pages
(1999-2009) (166 pages)
p. 48  Refers to "Detainee Labor" and not "wages."  Indicates program should be viewed as benefit to INS and detainees, not contractor.

p. 76  Much more aggressive policy on reporting grievances.  No encouragement of "informal" resolutions.

p. 77  Food must be prepared on site.

p. 83  Contractor may not profit from Commissary

p. 119  Reference to attachment with 44 pages on Detainee Volunteer Work program

Amendments (200 pages)

Contract (2010) (184 pages)

Tri-County, IL

IGSA (2010)(17 pages)

York County, Pennsylvania (IGSA)
ICE contract with York County (73 pages)


Yuba County, California
Yuba County Jail IGSA 2008-2013  (15 pages)

No reference to detainee work program. 

INVOICES AND PAYMENTS

 FIRST FOIA Release on ICE Detainee Work Program, 2011.

Additional Materials 

Meltzer Letter, 10-28-2013.