The following document is a legal request made to an immigration judge to terminate the deportation of our unaccompanied child client. Under United States law, we believe that DHS’s egregious violations of the legal and human rights of our client should legally bar ICE from pursuing her deportation.
This week the U.S. Senate released a scathing report on how the CIA participated in torture of individuals suspected of terrorism during the Bush administration.
President Obama condemned the “techniques” that “did significant damage to America’s standing in the world and made it harder to pursue our interests with allies and partners.”
He concluded that he hopes the report “can help us leave these techniques where they belong — in the past,”
Some of the CIA’s techniques (i.e. torture) included depriving detainees of sleep for up to a week.
From the New York Times:
One clandestine officer described the prison as a “dungeon” and another said that some prisoners there “literally looked like a dog that had been kenneled.”
Under the Obama administration, DHS has treated unaccompanied minors in border holding cells in many of the exact same ways that the CIA has terrorist suspects under the Bush administration.
From the words of a 15 year old girl who was a victim:
She lost significant weight and was extremely weakened as a result of the almost total deprivation of food, water, sleep, clothing, and medical assistance during her time in DHS custody. She could have suffered irreparable physical injury from the acute lack of sufficient water and food for a 96 hour period. HHS officials also failed to provide Respondent with sufficient food and shelter for 7 consecutive days given that she was only able to eat cookies and juice, the temperatures in the shelter dropped to very cold temperatures at night, and the lights were kept on for 24 hours a day for 7 days straight.
Below is the full request to the immigration judge. If you are an attorney of accredited representative, please feel free to use this motion as a template to help your clients.