Case 3:18-cv-00050-JD Document 21-1 Filed 02/04/18 Page 1 of 3

LAW OFFICES OF YOLANDA HUANG

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YOLANDA HUANG, SBN 104543
2 475 14th Street, Suite 500
Oakland, CA 94612
3 Telephone: (510) 329-2140
Facsimile: (510) 580-9410
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5 DENNIS CUNNINGHAM, SBN 112910
115A Bartlett St.
6 San Francisco, CA 94110
7 Telephone: 415-285-8091
Facsimile: 415-285-8092
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Attorneys for Plaintiffs
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10 UNITED STATES DISTRICT COURT
11 FOR THE NORTHERN DISTRICT OF CALIFORNIA
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13 JACLYN MOHRBACHER, ERIN ELLIS,
DOMINIQUE JACKSON, CHRISTINA
14 No. 3:18-cv-00050-JD
ZEPEDA, ALEXIS WAH, AND KELSEY
ERWIN, on behalf of themselves and others DECLARATION OF CHRISTINA JONES IN
15 similarly situated, SUPPORT OF PLAINTIFFS’ PETITION FOR
AN ORDER TO SHOW CAUSE FOR RELIEF
16 Plaintiffs, FROM FALSE ARREST, INTIMIDATION
AND OTHER HARASSMENT OF
17 vs. PLAINTIFFS BY DEFENDANT ALAMEDA
COUNTY SHERIFFS’ DEPUTIES
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19 ALAMEDA COUNTY SHERIFF’S OFFICE, et
al.,
20 Defendants.
21 I, CHRISTINA JONES, declare:
22 1. I make this declaration based upon my own knowledge, and if called to testify, I can and will
23 testify as stated herein.
24 2. On Wednesday, January 31, 2018, at around 2:30 to 3 p.m., I was in the home of Jaleh Kanalis,
25 also known as Jaleh Munos. I was sitting in the bedroom chatting with a female friend of Jaleh’s.

26 Earlier, Christina Zepeda had stopped by with Christopher Plascencia, another friend of Jaleh, for
just a brief moment, and told us about the press conference. Then she asked Christopher if she
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could use his car to go get some food. Christopher stayed and Christina Zepeda left. A short
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while after Christina Zepeda had left, suddenly, we all heard loud banging at the front door, of
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the apartment and voices demanding that we open the door.
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3. Christopher Plascencia, went into the living room, and through the blinds I could all see a lot of
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police dressed not in regular uniforms, but black jump suits such as those a swat team would
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wear. They all had guns drawn and were yelling “Open up, Open the door” and “We’re going to
5 kick it in”.
6 4. Chris said, he didn’t live there and was not going to open the door.
7 5. Jaleh had been in the shower and walked into the living room with a towel wrapped around her. I
8 could tell she was scared. The police kept yelling “Open up” “we’re going to kick it in.”
9 Suddenly, all of these police were in the apartment, calling everyone to come out of the bedroom.

10 I was petrified. I walked into the living room and they immediately handcuffed me and took me
outside into the downstairs parking lot.
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6. It turned out these police were Alameda County Sheriff deputies and there were at least eight (8)
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or more of them. I asked, “Why am I being arrested.” One of the officers stated “You’re not
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being arrested, you are being detained.”
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7. After that, these police had us standing in the parking lot in front of the apartment building, and
15 administered sobriety tests, over and over for almost two hours. “Close your eyes;” “Walk;”
16 “Tilt your head back;” “Count to thirty”. After I was repeatedly able to do these requests
17 successfully, one of the officers asked ‘How did you do that?” “Do what?” I responded. And
18 the officer said, “Count to thirty without a mistake.” It was the most ridiculous question.
19 8. After two hours of doing these tests repeatedly, it was clear that the police wanted me to fail the

20 test. It was also clear that I was not going to be able to leave unless I failed the test, so I
deliberately “failed” these tests that I had just done correctly, over and over. After I “failed” the
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test, they then placed me into the back of a squad car.
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9. Christina Zepeda was also arrested but she was placed into a different squad car. I could see that
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she had been handcuffed, and when they placed her in the back of a squad car, I assumed she had
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been arrested too. They placed Jaleh into the back of the squad car with me, and drove the two of
25 us to the Sheriff sub-station in San Leandro where we were held for many hours.
26 10. I was cited and released around midnight. The Sheriff confiscated my cell phone and did not
27 give it back. I was cited for violating Health & Safety Code 11550, being under the influence.
28 Jaleh and I then both went to her house.

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11. As a result of what I considered a completely wrongful and unjustified arrest, I missed my 9 year
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old son’s birthday, and hurt his feelings, terribly.
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12. The next morning, I got up and was walking down the hill to get coffee, when suddenly two
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Alameda County Sheriff vehicles pulled across the intersection and blocked my way. In the cars
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were two of the same officers from the afternoon before. They said “Did you get out of jail
5 o.k.?” I asked them, “Why did you take my phone?” Their response was “Evidence” And then
6 they asked me “You sure you don’t want to work for us?” I understood this to mean that they
7 wanted me to work for them and be a police informer. I said, “Hell no” and walked away.
8 I make this declaration under penalty of perjury, under the laws of the State of California, executed
9 this 4th day of January in Contra Costa County.

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12 CHRISTINA JONES
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Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050,