Case 3:18-cv-00050-JD Document 3-4 Filed 01/04/18 Page 1 of 3

LAW OFFICES OF YOLANDA HUANG

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YOLANDA HUANG, SBN 104543
2 475 14th Street, Suite 500
Oakland, CA 94612
3 Telephone: (510) 329-2140
Facsimile: (510) 580-9410
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5 DENNIS CUNNINGHAM, SBN 112910
115A Bartlett St.
6 San Francisco, CA 94110
7 Telephone: 415-285-8091
Facsimile: 415-285-8092
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Attorneys for Plaintiffs
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10 UNITED STATES DISTRICT COURT
11 FOR THE NORTHERN DISTRICT OF CALIFORNIA
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13 JACLYN MOHRBACHER, ERIN ELLIS,
DOMINIQUE JACKSON, CHRISTINA
14 No. 18-cv-
ZEPEDA, ALEXIS WAH, AND KELSEY
ERWIN, on behalf of themselves and others
15 similarly situated,
DECLARATION OF ALEXIS WAH IN
16 Plaintiffs, SUPPORT OF PLAINTIFFS’ APPLICATION
17 FOR A TEMPORARY RESTRAINING
vs. ORDER AND MOTION FOR A
18 PRELIMINARY INJUNCTION
19 ALAMEDA COUNTY SHERIFF’S OFFICE, et
al.,
20 Defendants.
21 I ALEXIS WAH, declare:
22 1. I make this declaration based upon my own true knowledge and if called to testify, I can and
23 will testify as stated herein.
24 2. I am a long time resident of Alameda County. I have been incarcerated in Santa Rita on
25 multiple occasions, usually for durations from 5 days to 6 months. My issues have been with

26 marijuana and meth, which I use to self medicate due to my anxiety.

3. As a result of my incarcerations in Santa Rita, I have had the opportunity to observe and
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experience the way Santa Rita treats women prisoners, which is not equal and sub-par
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compared to Santa Rita’s treatment of men.
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 Case 3:18-cv-00050-JD Document 3-4 Filed 01/04/18 Page 2 of 3

4. Male prisoners are always processed first, so they are held in holding cells for shorter time.
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Holding cells are concrete boxes, usually very cold, and usually filthy, being rarely cleaned
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and full of garbage. Because women are processed after the jail is finished processing the
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men, women are held for significantly longer periods of time in these awful holding cells.
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The holding cells are in what is called ITR, Intake, Transfer and Release. So anyone coming
5 into or out of Santa Rita, must go through ITR. This includes each and every time someone
6 has to go to court.
7 5. Women have fewer jobs available to them, and the jobs are not as good.
8 6. Women have fewer educational classes to them, and the classes are less relevant to what
9 women are interested in or want to learn.

10 7. Women are strip searched more frequently than men, even under the same situation and
circumstance. For example, women are always strip searched or have body cavity searches
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when we return to our housing units after a work shift. Men are not.
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8. While the rules say we are suppose to have clean laundry once a week, this is more often not
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the case. We will be told they ran out of clothing for us. I know of no situation where the jail
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has run out of clothing for the men. This is especially difficult for women because the rules
15 require us to wear bras, and they are generally in the wrong sizes and in short supply.
16 9. In the medium security, Housing Unit 24, we are housed in groups of 18, in bunk beds. With
17 this many women, there are always some who are menstruating, and often quite a few of us.
18 The guards, instead of finding out how many women are menstruating will just hand out some
19 small number of menstrual pads, like 8 or 10, and no matter how many women are

20 menstruating. And these pads are tiny and thin to begin with. This means that regularly and
routinely, there are insufficient menstrual pads, and women end up bleeding through their
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clothes. Because laundry is only once a week, often women are forced to endure dirty bloody
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clothing for long periods of time. And if the laundry is short, then one could be stuck in
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disgusting, filthy, blood stained clothes for longer.
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10. Women receive fewer privileges. We have less access to the outdoor yard. We have fewer
25 freedoms. For example, during meal times, women are prohibited from conversing. If
26 someone speaks, then frequently the entire pod is punished and deprived of privileges.
27 During meal times, we cannot even choose where to sit. The guards will tell us where to sit. I
28 know that the guards do not treat the men like this.

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 Case 3:18-cv-00050-JD Document 3-4 Filed 01/04/18 Page 3 of 3

11. It is difficult to file grievances and complaints about the situation since we are under the total
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control of the guards. Complaints and grievances just lead to retaliation and reprisals. Guards
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will place a woman prisoner into isolation or solitary confinement as punishment. They will
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take away privileges not just for the individual but for the entire pod. The guards’ have carte
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blanche to do searches, including strip searches and body cavity searches. So, one means of
5 easy retaliation is to force, sometimes repeatedly a woman prisoner who files grievances and
6 complaints, to endure the humiliating and degrading process of a strip search or a body cavity
7 search.
8 12. The unequal treatment of women is part of the fabric of Santa Rita Jail.
9 13. I have agreed to be a class representative for similarly situated individuals.

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I make this declaration under penalty of perjury under the laws of the State of California. Executed
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in Berkeley, California.
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13 Dated: Jan. 3, 2018 ALEXIS WAH
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16 ___/s/ Alexis Wah________________________

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Under N.D. Cal. Local Rule 5-1(i)(3), I attest that I obtained concurrence in the filing of this
19 document from Alexis Wah on January 3, 2018.
.
20 By: __/s/ Yolanda Huang______________
YOLANDA HUANG
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Mohrbacher v. Alameda County Sheriff’s Office