Juan Manuel Montes Bojorquez v. U.S. Customs & Border Protection, et al.

Briefs, Memos, and Orders Filed with/Issued by the U.S. District Court for the Southern District of California (from latest to earliest):

• Joint Motion of Voluntary Dismissal (filed 10/18/17, PDF).
• Memorandum of Law in Support of Plaintiff’s Motion for Preliminary Injunction (7/14/17, PDF). “Plaintiff … moves for a preliminary injunction to restore the status quo pending resolution of this case. [He] arrived in the United States from Mexico as a child and obtained authorization to live and work here pursuant to … Deferred Action for Childhood Arrivals …. Yet Defendants unlawfully expelled [him] … earlier this year, tearing him away from his family, home, work, and education.” Declarations filed in support of this motion are listed below.
• First Amended Complaint under the Freedom of Information Act; Complaint for Declaratory and Injunctive Relief; and Petition for Writ of Habeas Corpus and Mandamus (5/22/17, PDF). “Plaintiff … brings this action to secure his return to the United States after U.S. Customs and Border Protection … agents unlawfully expelled him … in the middle of the night on February 18-19, 2017, in or near Calexico, California.”
• Complaint for Declaratory and Injunctive Relief under the Freedom of Information Act, 5 U.S.C. § 552 (4/18/17, PDF). “Plaintiff Juan Manuel Montes Bojorquez brings this action under the Freedom of Information Act, 5 U.S.C. § 552, for injunctive and other appropriate relief seeking the disclosure and release of agency records improperly withheld by Defendants United States Customs and Border Protection and United States Citizenship and Immigration Services.”

Declarations Filed in Support of Motion for Preliminary Injunction:

• Declaration of Juan Manuel Montes Bojorquez (7/14/17, PDF).
• Declaration of Jane Doe (Juan Manuel’s Mother) (7/14/17, PDF).
• Declaration of Danielle Alessandra Jimenez (7/14/17, PDF).
• Declaration of Jose Manuel Zarate (7/14/17, PDF).
• Declaration of Kamylee Gabriela Zarate (7/14/17, PDF).
• Declaration of R. Gil Kerlikowske (7/14/17, PDF).
• Declaration of Madelon V. Baranoski, Ph.D (7/14/17, PDF).
• Declaration of Leslie Itzel Ramirez Vega (7/14/17, PDF).