Archambeault

I. FACTUAL BACKGROUND

4 Decedent Carlos Escobar Mejia (“ Escobar”), originally from El Salvador, 5 lived in the United States with his sisters for over 40 years. (SAC ¶¶ 33-34.) In 6 January 2020, Escobar was detained by ICE after Border Patrol stopped him in 7 Chula Vista (Id. at ¶ 37.) Escobar had criminal convictions, including a DUI, that

8 were 30 years old. (Id. at ¶ 36.) Escobar was in ICE Custody until his death on 9 May 6, 2020, at age 57, although no criminal charges were pending against him. 10 (Id. at ¶ 29, 37-38.) Escobar had been waiting to appear before an immigration 11 judge to resolve an issue related to his immigration status. (Id. at ¶ 39.) Escobar 12 was vulnerable to COVID-19; he suffered from diabetes, his foot had been 13 amputated due to complications from diabetes and he suffered high blood 14 pressure and heart problems. (Id. at ¶¶ 40-41.) 15 Escobar became infected with COVID-19 while in custody at the Otay 16 Mesa Detention Center, an immigration detention center owned and operated by 17 Defendant CoreCivic. (Id. at ¶¶ 39, 43, 122.) CoreCivic is a private operator of 18 correctional facilities with contracts for services with U.S. Immigration and…