See corresponding notes.

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NORTHWEST IMMIGRANT RIGHTS PROJECT
615 Second Ave., Ste. 400
Seattle, WA 98104
Telephone (206) 957- 8611
Fax (206) 587-4025
DUBALE DECL. - !1
(No. 14-cv-01026-TSZ)
The Honorable Thomas S. Zilly
UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
I, Sarah Dubale, declare as follows:
1. I submit this declaration in support of Plaintiffs’ Brief Supplementing Their Opposition to the
Defendants’ Motion to Dismiss. I have personal knowledge of the facts set forth herein, and, if
called as a witness, I could and would testify competently as follows:
J.E.F.M., a minor, by and through his Next Friend,
Bob Ekblad, et al.,
Plaintiff-Petitioners,
v.
Eric H. HOLDER, Attorney General of the United
States, et al.,
Defendants-Respondents.
No. 14-cv-01026-TSZ
DECLARATION OF SARAH
DUBALE
Case 2:14-cv-01026-TSZ Document 99 Filed 01/26/15 Page 1 of 3

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NORTHWEST IMMIGRANT RIGHTS PROJECT
615 Second Ave., Ste. 400
Seattle, WA 98104
Telephone (206) 957- 8611
Fax (206) 587-4025
DUBALE DECL. - !2
(No. 14-cv-01026-TSZ)
2. I am an attorney licensed to practice in Georgia.
3. On January 22, 2015, beginning at 1:00 p.m., I observed an expedited docket at the Atlanta
Immigration Court, presided over by Immigration Judge (IJ) Earle B. Wilson. The docket
included a mix of cases of unaccompanied children and cases of women in proceedings with
their children.
4. There were approximately twenty-three cases, with approximately twenty-five children as
respondents. None of the respondents spoke English at the hearing.
5. Approximately fourteen children did not have attorneys, including eight in proceedings on
their own and approximately six in proceedings with family members. Seven of the
unaccompanied children were granted continuances to obtain an attorney. Four of those children
were given continuances until February 5, 2015; two of the children, who provided
documentation of scheduled appointments with attorneys in early February, received slightly
longer continuances to February 12 and 19, 2015; one of the children, who claimed she had an
attorney who was unable to make the hearing, received a continuance to February 3, 2015. IJ
Wilson told the unrepresented children who were granted continuances that if they did not have
an attorney representing them at their next hearing, they would have to speak for themselves.
One of the children who received a two week continuance told IJ Wilson that he could not
currently afford an attorney, but that his father was working in order to earn enough money to
pay for one. IJ Wilson nonetheless told the child that, at his next hearing, he would not receive
Case 2:14-cv-01026-TSZ Document 99 Filed 01/26/15 Page 2 of 3
IJ Wilson’s 2-4 weeks continuances were so short it rendered them meaningless.
Additionally, IJ Wilson improperly prejudged future motions to continue. t
The combined effect of prejudhed denial of future motions to continue with 2-4 week was
brazen deprivation of children’s right to due process and rights under TVPRA.

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NORTHWEST IMMIGRANT RIGHTS PROJECT
615 Second Ave., Ste. 400
Seattle, WA 98104
Telephone (206) 957- 8611
Fax (206) 587-4025
DUBALE DECL. - !3
(No. 14-cv-01026-TSZ)
any additional continuances to try to find an attorney.
6. In four cases, IJ Wilson proceeded against respondents. These cases included one child in
proceedings on her own and approximately six children in proceedings with family members. In
two cases where approximately four children were in proceedings with family members, the
respondents stated that they would not or could not obtain an attorney because they could not
afford one. IJ Wilson took pleadings on the charges on the Notices to Appear and then found
each of the respondents removable. In one of the cases, the respondent requested and was given
a voluntary removal. In three of the cases, IJ Wilson asked the respondents, including the child
in proceedings on her own, why they did not want to return to their home countries. When they
expressed fear of return, the IJ gave them asylum applications and granted two-week
continuances to complete and file the applications.
I declare under penalty of perjury of the laws of the State of Georgia and the United States that the
foregoing is true and correct to the best of my knowledge and belief.
Executed this 26th day of January, 2015, in Atlanta, Georgia.
_________________________________
SARAH DUBALE
Case 2:14-cv-01026-TSZ Document 99 Filed 01/26/15 Page 3 of 3
IJ failed to advise children that USCIS had intial jurisdiction over I589 applications. Additionally, IJ
appears to have practice of assuming initial jurisdiction over unaccompanied children’s asylum
applications in clear violation of the TVPRA.