1 2 3 4 5 6 7 8 SUPERIOR COURT OF , 9 CENTRAL DISTRICT — 10 PUBLIC COUNSEL on behalf of its Case No. staff and clients, et ai., 11 Plaintiffs, 12 DECLARATION OF SILVIA R. v. ARGUETA 13 14 COUNTY OF LOS ANGELES; PRESIDING JUDGE, SUPERIOR 15 COURT OF LOS ANGELES 16 COUNTY,in his or her official capacity. 17 Defendants. 18 19 20 21 22 23 24 25 26 27 28

DECLARATION OF SILVIA R. ARGUETA 1 DECLARATION OF SILVIA R. ARGUETA 2 I, Silvia R. Argueta am over the age of 18 and fully competent to make the 3 following declaration. The facts in this declaration are based on my personal 4 knowledge and upon information available to me through the files and records of 5 Legal Aid Foundation of Los Angeles where I serve as Executive Director. If called 6 upon as a witness, I would testify to these facts. Under penalty of perjury, I declare 7 and state the following: 8 9 1. I am the Executive Director of Legal Aid Foundation of Los Angeles 10 (LAFLA)I have served in this capacity since October, 2008. My business address 11 is 1550 W. 8th Street , Los Angeles, CA 90017. My business phone number is 323- 12 801-7906. 13 2. For over 90 years, LAFLA has fought to achieve equal justice for 14 people living in poverty across greater Los Angeles. With close to 200 employees, 15 five office locations, three domestic violence clinics and four self-help legal access 16 centers located in courthouses throughout the Los Angeles metropolitan area, 17 LAFLA is an integral part of the communities it serves. LAFLA's practice spans 18 the entire County and we serve approximately 100,00 people each year. Our client 19 services range from maintaining affordable housing and helping people move from 20 welfare to work, to providing eviction defense, relief from domestic violence and 21 assistance with record expungements. 223 3. LAFLA has paid local, state, and federal taxes in the past year, 23 including property taxes and payroll taxes. LAFLA is an accredited 501 (c)(3) non- 24 profit organization. 25 4. In my role as Executive Director, I am responsible for the health and 26 well-being of the organization and all our staff. As LAFLA's Executive Director, I 27 oversee strategy, advocacy, fund development, and finances. 28 5. Due to COVID-19 and stay at home orders, we were forced to close

DECLARATION OF[NAME] 1 our offices, court-based domestic violence clinics and self-help centers, and move 2 entirely to working remotely. LAFLA has put into place protocols for when a 3 limited number of advocates need to come into offices and/or meet with clients. We 4 have purchased personal protective equipment for offices, and N95 masks for 5 attorneys needing to go to court or other hearings. 6 6. LAFLA employs 86 attorneys who practice in a variety of poverty 7 related areas. 57 of our attorneys are people of color who may potentially be more 8 vulnerable to COVID-19. To our knowledge, we also have a few attorneys with 9 serious underlying medical conditions including cancer and diabetes. To our 10 knowledge at least one of our attorneys had COVID-19. 1 1 7. LAFLA has opened 5,496 housing cases, for various levels of service 12 from counselling to representation, since the first stay at home order was issued by 13 the State. LAFLA employs approximately twenty-one attorneys primarily 14 dedicated to defending unlawful detainer cases, a number that is increasing with 15 new funding to address the looming eviction crisis. Those attorneys have made over 16 40 in-person court appearances during the pandemic in the following courthouses: 17 Stanley Mosk, Compton, Inglewood, -Long Beach, Norwalk, 18 Santa Monica and Van Nuys. We have had multiple clients who have refused to go 19 to court or refused to return to court for a trial. We have clients who have had to go 20 to court in-person in order to pick up documents because they could not get 21 information over the phone. LAFLA is the lead contractor for Los Angeles 22 County's Eviction Defense Program (StayHousedLA County) and we subcontract 23 to eight other legal service providers for eviction defense services. Since that 24 program began in September, 2020, 406 tenant households have been retained, 25 primarily for unlawful detainers. Over 7000 tenants were counselled on housing 26 matters. 27 8. LAFLA employs approximately five attorneys who are dedicated to re- 28 entry work and practice in traffic court. These attorneys have made approximately

2 DECLARATION OF SILVIA R. ARGUETA 1 ten in-person court appearances in the following courts: Airport, Compton, Long 2 Beach and Metro. They have been denied the ability to do remote hearings eight 3 times. 4 9. LAFLA's clients are majority people of color living below the federal 5 poverty line. Over the last five years 33% of our total clients have identified as 6 black, 36% as latinx, and 20% of our clients have a primary language other than 7 English, which limits their ability to access court information. 49% of those clients 8 contacted us about housing issues. Of those housing clients 41% are black and 29% 9 are latinx. 10 10. Although LAFLA is a large legal services organization, we do not 1 1 have the financial or staff resources to file a lawsuit for every client who feels 12 unsafe going in-person to court. 13 14 I declare under penalty of perjury pursuant that the foregoing is true and 15 correct. 16 Executed: , 2021 17 18 Silvia R. Argueta 19 20 21 22 23 24 25 26 27 28

3 DECLARATION OF SILVIA R. ARGUETA