Case 3:18-cv-00050-JD Document 17-10 Filed 01/31/18 Page 1 of 4

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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UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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JACLYN MOHRBACHER, ERIN ELLIS,
15 DOMINIQUE JACKSON, CHRISTINA
No. 3:18-cv-00050-JD
ZEPEDA, ALEXIS WAH, AND KELSEY
16 ERWIN, on behalf of themselves and others
17 similarly situated,
DECLARATION OF JANE DOE IN SUPPORT
18 Plaintiffs, OF PLAINTIFFS’ MOTION FOR A
PRELIMINARY INJUNCTION
19 vs.

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ALAMEDA COUNTY SHERIFF’S OFFICE, et
21 al.,
Defendants.
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23 I, JANE DOE 1, declare:

24 I make this declaration based upon my own true knowledge and if called to testify, I can and will
testify as stated herein.
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1. I am currently in custody in Santa Rita Jail, due to an alleged probation violation.
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2. I am requesting that the Court permit me to make this declaration with just my initials and to
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not require that I disclose my identity to defendants. I am happy to provide my full identity to
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the Court in camera, or under seal. I believe that what I am saying in this declaration will

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subject me to retaliation the next time I am incarcerated, if my identity is disclosed to the

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Alameda County Sheriff’s Office
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3. I have been an inmate worker in the Santa Rita kitchen. Approximately 8 to 12 women work
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in the kitchen Monday through Friday from about 8 pm to 1:30 a.m. This is not paid and has
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no benefits other than we are allowed out of cells.
5 4. I have work experience in commercial restaurants, and I know that cleanliness and hygiene is
6 a paramount concern when preparing food, particularly food that will be put away and
7 consumed later.
8 5. Santa Rita’s kitchen prepares food not just for prisoners in the jail, but also for other jails in
9 the area. One of the jobs for the women is placing ketchup and mustard into cups. We fill

10 pallets, and each pallet has 3000 servings. We do approximately one and a half pallet a night.
6. The kitchen at Santa Rita is filthy. There are birds that live in the kitchen and there are bird
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droppings all over. I have counted seven (7) birds who appear to live in the kitchen. There
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are rats. I have personally seen rats running across the kitchen floor and rat droppings on the
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food. When I found rat droppings, I asked the paid staff what should be done, and she just
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brushed the droppings off and told me to continue what I was doing.
15 7. Food in the kitchen is not kept so the rats cannot have access. The bread is in plastic bags in
16 open plastic crates. There is nothing that prevents the rats from climbing over the bread and
17 chewing open packages. I have seen bread bags chewed by rats, and a few pieces are thrown
18 away but the rest of the bread is served to prisoners.
19 8. The sandwich meat, which is primarily bologna, often has white spots on them. I do not

20 know what the white spots are, but that meat is still given to prisoners to eat. I know that
when the bologna with white spots is given to the women prisoners, the women prisoners
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refuse to eat it, and it is thrown away.
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9. There is very little variety in the food served. It is the same, day in and day out. The food
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available for purchase in the commissary is generally unhealthy food, the type found in 7-11’s
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such as candy, soda, chips, and pastries. The healthiest alternative are granola bars. The
25 commissary also has dried foods which require boiling water such as rice, dried noodles, dried
26 beans or dried chili, or dried lasagna. The problem with these “foods” is that there is no
27 boiling water. The hottest water comes out of the shower, and it is not hot enough to really
28 make these foods edible.

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Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050, Dec. Jane Doe 1 in Support; Motion for Preliminary Injunction
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10. Plus, it is very difficult to get through to the commissary to place orders. All orders to the
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commissary has to be done through the phone system, and for whatever reason the phone
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number rings and rings, or one is put on hold for long periods of time and the call is not
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answered. There is no soap in any bathroom. Therefore, a prisoner must have her own soap.
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All soap, even the indigent packet of soap and shampoo which is free for those without money
5 on the commissary, requires that we place these orders through the phone system. Because of
6 the difficulty with the phone system, I and others often run out of soap and shampoo.
7 11. There is no soap in the kitchen bathroom. In every commercial kitchen, there is a sign saying
8 it is the law that kitchen staff must wash our hands after using the bathroom. Clean hands
9 require soap and water. However, the Santa Rita kitchen bathroom has no soap, and often no

10 paper towels. I know that our hands are not clean after using the bathroom because we have
no way to clean our hands. The kitchen bathroom is also very dirty and often the floor is wet.
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There is only one bathroom for the kitchen, so men and women both use the same bathroom.
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This is not a problem because men and women work in the kitchen at different times. But it is
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a problem because I know that no one who works in the kitchen uses soap to wash their
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hands.
15 12. All commercial kitchens I have worked in has a daily clean-up crew who comes in and cleans
16 all aspects, ovens, stoves, venthoods, floors, etc of the kitchen. Usually the clean-up crew
17 comes in the early morning before the start of the new day. I have never seen a clean-up crew
18 for the Santa Rita kitchen, and it is clear, looking at the kitchen that it is never cleaned.
19 13. Here we are, being punished because we have broken a law. And Santa Rita Jail and the

20 Sheriff is regularly breaking basic health laws, while preparing food for thousands of people.
I am asking the court to insure that the kitchen in Santa Rita is inspected by the Health
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Department and required to meet the same health standards that everyone is required to meet.
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I am also asking the court to have the actual food inspected, as I believe that the sandwich
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meats being served are bad and should not have white spots.
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I make this declaration under penalty of perjury under the laws of the State of California.
25 Executed in Dublin, California.
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27 Dated: Jan. 23, 2018 JANE DOE 1

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___/s/ Jane Doe 1________________________
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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
3 document from Jane Doe 1 on January 23, 2018.
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By: __/s/ Yolanda Huang______________
5 YOLANDA HUANG

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Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050, Dec. Jane Doe 1 in Support; Motion for Preliminary Injunction