Declaration of Erin Ellis

Case 3:18-cv-00050-JD Document 17-5 Filed 01/31/18 Page 1 of 4
LAW OFFICES OF YOLANDA HUANG

1
YOLANDA HUANG, SBN 104543
2 475 14th Street, Suite 500
Oakland, CA 94612
3 Telephone: (510) 329-2140
Facsimile: (510) 580-9410
4
5 DENNIS CUNNINGHAM, SBN 112910
115A Bartlett St.
6 San Francisco, CA 94110
7 Telephone: 415-285-8091
Facsimile: 415-285-8092
8
Attorneys for Plaintiffs
9
10 UNITED STATES DISTRICT COURT
11 FOR THE NORTHERN DISTRICT OF CALIFORNIA
12
13 JACLYN MOHRBACHER, ERIN ELLIS,
DOMINIQUE JACKSON, CHRISTINA
No. 3:18-cv-00050-JD
14 ZEPEDA, ALEXIS WAH, AND KELSEY
ERWIN, on behalf of themselves and others
15 similarly situated,
DECLARATION OF ERIN ELLIS IN
16 Plaintiffs, SUPPORT OF PLAINTIFFS’ MOTION FOR A
PRELIMINARY INJUNCTION
17 vs.
18
19 ALAMEDA COUNTY SHERIFF’S OFFICE, et
al.,
20 Defendants.
21 I, ERIN ELLIS, declare:
22 1. I make this declaration based upon my own true knowledge and if called to testify, I can and
23 will testify as stated herein.
24 1. I am currently in custody in Santa Rita Jail. Off and on for my adult life, I have had to
25 combat substance dependence, particularly meth. I am currently serving a 6-month term for
26 receiving stolen property. I was arrested on October 30, 2017 and my release date is currently
April 29, 2018.
27
2. I am 27 weeks pregnant and my due date is April 25, 2018. When I first arrived, I was tested
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and Santa Rita confirmed my pregnancy. On or around December 2, 2017, I began bleeding
Page 1 of 4
Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050, Dec. Erin Ellis in Support; Motion for Preliminary Injunction
and spotting so they placed me into the Infirmary. The Infirmary contains several small
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rooms, essentially cages, where I was totally alone. For the two days I was in the Infirmary, I
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slept on the floor on two yoga mats. The only care I received was having someone come in
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and check up on me, check my blood pressure, and monitor the baby’s heartbeat.
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3. Although I am supposed to have a care plan and healthy nutritious food, I don’t know what
5 the care plan is, and the food is horrible, and consists of:
6 Breakfast- oatmeal or Cream of Wheat with bread and canned fruit;
7 Lunch- Primarily Peanut butter sandwich or 1-2x a week, hard boiled eggs; once every
8 two weeks or so some bologna, milk and 4 to 5 carrot nubs; a piece of fruit- an apple
9 or orange every day;
10 Snack- Peanut butter sandwich, milk;

Dinner- Meat patty, potatoes, cooked carrots, 2 slices of bread, canned fruit.
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4. Up until I was past four (4) months pregnant, the medical staff kept handing me pamphlets to
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tell me that the “option for abortion is available.” I ignored the medical staff and therefore,
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did not feel too much pressure to abort because I want this child, but I witnessed Santa Rita
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pressuring other pregnant women and in particular Plaintiff Jaclyn Mohrbacher to get an
15 abortion. I heard Santa Rita’s medical staff say that Jaclyn “needs to have an abortion.”
16 5. There is a medical provider named Nina who sees the women. However, I am not confidant
17 of Nina’s abilities because she tends to over diagnose everyone with the same problem.
18 Currently, she’s telling everyone that we have trichomonas vaginalis, a STD and then
19 prescribes antibiotics for everyone. I have heard that the antibiotics she is prescribing may
20 cause birth defects so I am reluctant to take them. One of the problems with STD is that it can
be contracted through vaginal discharge. And if there is a problem of STDs in jail, it is
21
because of the laundry system. Underwear are distributed that are not clean, are stained and
22
often have pubic hairs on them. Many of us hand-wash our underwear in the shower in a
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bucket. And when I hand wash the supposedly clean laundry exchange underwear, the water
24
coming off the laundry exchange underwear is brown. Prevention of any transmission of
25 bacteria from vagina fluids can easily be stopped by a more thorough laundry process.
26 6. Because of my history of drug dependence, the guards have been very hostile, always
27 claiming that there are drugs, despite a large number of shake downs and searches. In
28 December, during one week, there were 3 shakedowns and no drugs were found. I am not
Page 2 of 4
aware of drugs ever being found in my pod while I have been here. When no drugs are found,
1
the guards then punish the entire POD by denying everyone POD TIME, turning off the
2
television or phones. Sometimes, they will pull individuals out of POD time, and very often,
3
those with dietary restrictions get no lunch.
4
7. In one of the raids, the guards, including Defendant Divine came in in the very early morning,
5 and made everyone in the Lower C get up and then handcuffed or zip tied everyone outside
6 the cell. I watched as they put Jaclyn Mohrbacher, who was also pregnant into the ISO cell in
7 the hallway. The ISO cell is really cold. Then the guards raided the POD and took
8 everyone’s underwear and menstrual pads. When they finally strip-searched Jaclyn and
9 brought her back to the POD, she was bleeding badly and had no pads. Despite the fact that
10 Jaclyn was pregnant and visibly bleeding, none of the deputies took Jaclyn to the Infirmary. I
personally asked defendant Caine several times for menstrual pads for Jaclyn before some
11
were finally given to her. Jaclyn was never taken to the Infirmary.
12
8. After repeated searches where no drugs were found, and despite our repeated request to be
13
drug tested, the guards finally drug tested me on January 3rd or 4th, and I was clean. There
14
were no drugs in my system. I am not using while pregnant and committed to being clean.
15 9. All of the women have limited access to yard time and exercise opportunities. I believe that
16 pregnant women are supposed to have walks every day, but I have only had very limited
17 access to walks since I’ve been here.
18 10. There is a Big Yard, which has grass and open space. The men are given access to the Big
19 Yard regularly. We know because we can hear them. Women are generally only given the
20 small yard, which is a concrete pen that is open at the top. However, since the lawsuit has
been filed, we have been out to the Big Yard a few times.
21
11. I am requesting that the Court order:
22
a) Less harassment from the guards;
23
b) Better quality food and more food;
24
c) More fresh fruits and vegetables;
25 d) More pregnancy walks and access to exercise.
26 //
27
//
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ration under penalty of perjury under the laws of the State of California, executed
2==
on_--=-__...._,____, 2018 in Dublin, California.
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Mohrbacher v. Alameda County Sheriffs Office 3:18-cv-00050, Dec. Erin Ellis in Support; Motion for Preliminary Injunction

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Case 3:18-cv-00050-JD Document 17-5 Filed 01/31/18 Page 1 of 4

LAW OFFICES OF YOLANDA HUANG

10 Snack- Peanut butter sandwich, milk;

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