CASE 0:25-cv-04669-KMM-DTS Doc. 107 Filed 01/24/26
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
SUSAN TINCHER, JOHN BIESTMAN,
JANET LEE, LUCIA WEBB,
ABDIKADIR NOOR, and ALAN
CRENSHAW, on behalf of themselves and
other similarly situated individuals,
Plaintiffs,
V.
KRISTI NOEM, Secretary, U.S.
Department of Homeland Security (DHS); TODD LYONS, Acting Director, U.S. Immigration and Customs Enforcement (ICE); MARCOS CHARLES, Acting Executive Associate Director, Enforcement and Removal Operations (ERO), ICE; DAVID EASTERWOOD, Acting Field Office Director, ERO, ICE Saint Paul Field Office; JOHN A. CONDON, Acting Executive Associate Director, Homeland Security
Investigations (HSI); The Department of Homeland Security; Unidentified Federal Agencies; and Unidentified Federal Agents; in their official capacities,
Defendants.
1,
declare as follows:
1
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Case No. 25-cv-04669
DECLARATION OF
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