Attachment to State of California Government Claim (Form DGS ORIM 006)

Bukle and the class of individuals who are similarly-situated; Doe individual employees who are employees of CDCR and engaged in actual notification of ICE of Mr. [...] Prior to June 17, 2020, and after and up to the date of this claim, CDCR, Governor Newsom, the CDCR Secretary, and CDCR employees transferred similarly-situated individuals from CDCR custody to ICE custody. [...] This claim uses the term “transfer” to include the range of actions, policies, and procedures adopted and implemented by the state and its employees to facilitate ICE’s ability to take custody of an individual from CDCR custody. [...] As a direct and proximately result of the actions of the state and its employees described below, a class of similarly-situated individuals suffered a deprivation of their liberty; detention by ICE and G4S; physical pain; mental suffering; loss of enjoyment of life; inconvenience; grief; anxiety; humiliation; and emotional distress. [...] The actions of CDCR, Governor Newsom, the CDCR Secretary, and other CDCR employees constitute false imprisonment, a violation of the Bane Act, and a violation of the rights of Mr.