New Orleans Workers Center for Racial Justice 217 N. Prieur St., New Orleans, LA Phone: (504) / Facsimile (504)

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217 N. Prieur St., New Orleans, LA 70112 Phone: (504) 309-5165/ Facsimile (504) 309-5205 October 16, 2015 VIA ELECTRONIC MAIL Chief Danny Hunt New Llano Police Deparmtnet 109 Stanton St. New Llano, Louisiana 71461 Re: Request for Meeting to Address Racial Profiling, Enforcement of Immigration Law, and Other Constitutional Violations By Certain Officers of the New Llano Police Department Dear Chief Hunt: The New Orleans Workers Center for Racial Justice ( Workers Center ), on behalf of Gustavo Barahona-Sanchez and Jose Adan Fugon-Cano requests that you meet with us to discuss a pattern and practice of violations of the Fourth Amendment, Fourteenth Amendment, and the Supremacy Clause by certain officers of the New Llano Police Department. On or about the morning of May 29, 2015, a group of Latino construction workers, including Mr. Barahona-Sanchez and Mr. Fugon-Cano, were standing on the public sidewalk waiting for their transportation to work. Shortly after, certain officers of the New Llano Police Department approached the sidewalk where the workers were standing and immediately asked workers to show me your papers, stating that they were going to check if you re legals or illegals. Without legal authority or criminal charge, the workers were arrested and transported to the jail where they waited until Border Patrol agents arrived at the call of certain officers of your Department. As you may know, DHS Office for Civil Rights and Civil Liberties has found that the only basis for the arrest seems to have been to give Border Patrol an opportunity to run an immigration investigation, and your Department s interest in the immigration status of the men was based on their ethnicity. 1 We are deeply concerned that these actions of detaining these individuals based on their race or ethnic appearance and interrogating them about their immigration status is not an isolated incident, but rather part of a wider pattern and practice of Fourth Amendment, Fourteenth Amendment, and Supremacy Clause violations of the U.S. Constitution.!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 1!Available at http://www.latimes.com/nation/la-na-border-profiling-20151015- story.html.!

Wherefore, we respectfully request a meeting with you to discuss how we can remedy these unconstitutional policing practices. Respectfully, s/yihong Julie Mao Yihong "Julie" Mao Jennifer J. Rosenbaum Jan Collatz* Attorneys for Complainants New Orleans Workers Center for Racial Justice * Admitted only in California and the District of Columbia!

217 N. Prieur St., New Orleans, LA 70112 Phone: (504) 309-5165/ Facsimile (504) 309-5205 October 16, 2015 VIA FAX AND EMAIL Chief Danny Hunt New Llano Police Department 109 Stanton St. New Llano, Louisiana 71461 Fax Number: 337-239-0031 Re: Public Record Requests New Llano Police Department! Chief Hunt: Under the Louisiana Public Records Act 44:1 et seq., I am requesting copies of the following public records on behalf of the New Orleans Workers Center for Racial Justice: a. Any and all records relating to communications between officers of the New Llano Police Department and U.S. Border Patrol (herein CBP ). b. Any and all records relating to communications between officers of the New Llano Police Department and U.S. Immigration and Customs (herein ICE ). c. Any and all records relating to communications between New Llano Police Department and DHS Office for Civil Rights and Civil Liberties (herein CRCL ). d. Any and all records regarding five individuals, including Mr. Jose Adan Fugon and Mr. Gustavo Barahona, who were arrested by certain officers of your Department on or about May 28, 2015. This includes but is not limited to: a. Any field information cards; b. Any records of custody processing; c. Any police reports, statements or notes; d. Any charges or allegations filed; e. Call logs regarding the individuals aforementioned including but not limited to calls for assistance to Border Patrol. e. Any and all records relating to statement made by Lt. Josh Foster to the Los Angeles Times on or about October 15, 2015. f. From 2013 onward, all field information cards broken down by race, ethnicity,

and gender. g. Any and all records regarding your Department s policy and/or practice of referring individuals to federal immigration authorities. h. Any and all records regarding your Department s policy and/or practice of bias policing including but not limited to the targeting of Hispanic or Latino individuals for immigration status checks. I respectfully request a waiver of all fees in that the disclosure of the requested information is in the public interest and will contribute significantly to the public s understanding of whether and how your Department is engaged in a pattern and practice of racial and ethnic profiling and enforcement of immigration law in violation of the Fourth Amendment, Fifth Amendment, Fourteenth Amendment, Supremacy Clause and other constitutional protections. There has already been significant local and national interest regarding the actions of certain New Llano Police Department officers towards Latino and immigrant community members. See e.g. Homeland Security email points to ongoing racial profiling by local police," LA Times, October 15, 2015, available at http://www.latimes.com/nation/la-na-border-profiling-20151015-story.html. Section 44:32(D) of the Louisiana Public Records Act requires a response to this request within three business days. If you deny any or all of this request, please cite each specific exemption you feel justifies the refusal to release the information and notify me of the appeal procedures available under the law. I am available for any question or to provide further background at (504) 309-5165 or jmao@nowcrj.org. You can send the responsive records to: Yihong Julie Mao New Orleans Workers Center for Racial Justice 217 N. Prieur St. New Orleans, LA 70112 Thank you for considering my request. Respectfully, s/yihong Julie Mao Yihong "Julie" Mao Jennifer J. Rosenbaum Counsel