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COMPLAINT FOR VIOLATION OF 42 U.S.C. § 1981

No. 17 Civ. 454

Jahan C. Sagafi 

Cal. Bar No. 224887 

Katrina Eiland 

Cal. Bar No. 275701 

OUTTEN & GOLDEN LLP 

One Embarcadero Center, 38th Floor 

San Francisco, CA 94111 

Telephone: (415) 638-8800 

Facsimile: (415) 638-8810 

jsagafi@outtengolden.com 

keiland@outtengolden.com 

Thomas Saenz

Cal. Bar No. 159430

Victor Viramontes 

Cal. Bar No. 214158 

MEXICAN AMERICAN LEGAL DEFENSE AND

EDUCATIONAL FUND

634 S. Spring St., 11th Floor 

Los Angeles, CA 90014 

Telephone: (213) 629-2512 

Facsimile: (213) 629-0266 

tsaenz@maldef.org 

vviramontes@maldef.org 

Attorney for Plaintiffs and the Proposed Class 

(Additional Counsel Listed on Signature Page) 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

MITZIE PEREZ, individually and on behalf of 

all others similarly situated, and 

CALIFORNIA LEAGUE OF UNITED 

LATIN AMERICAN CITIZENS, 

Plaintiffs, 

v. 

WELLS FARGO & CO. and WELLS 

FARGO, N.A., 

Defendants. 

CASE NO. 17 Civ. 454 

COMPLAINT FOR VIOLATION OF 

42 U.S.C. § 1981 

CLASS ACTION

DEMAND FOR JURY TRIAL

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2 COMPLAINT UNDER 42 U.S.C. § 1981

No. 17 Civ.454 

Plaintiff Mitzie Perez (the “Individual Plaintiff”), individually and on behalf of all others 

similarly situated, and the California League of United Latin American Citizens (“California 

LULAC”) (collectively, “Plaintiffs”) by their attorneys, bring the following allegations against 

Defendants Wells Fargo & Co. and Wells Fargo, N.A. (“Wells Fargo” or “Defendants”): 

SUMMARY OF CLAIM

1. Plaintiff Mitzie Perez, individually and on behalf of all others similarly situated, 

and California LULAC bring this case against Wells Fargo for unlawful discrimination in violation 

of the Civil Rights Act of 1866, as codified by 42 U.S.C. § 1981 (“Section 1981”), the Unruh Civil 

Rights Act, as codified by California Civil Code §§ 51 et seq., and the Unfair Competition Law, as 

codified by California Business and Professions Code §§ 17200 et seq.

2. Wells Fargo, an American multinational banking and financial services holding 

company, outright refuses to extend loans to individuals who are not U.S. citizens or permanent 

residents. This company-wide policy and practice of denying individuals the right to contract for a 

loan based on alienage is discriminatory and unlawful under Section 1981, Sections 51(b) and 51.5 

of the Unruh Civil Rights Act, and Section 17200 of the California Unfair Competition Law. 

PARTIES 

Plaintiff Mitzie Perez 

3. Plaintiff Mitzie Perez is a third-year undergraduate student at the University of 

California, Riverside, majoring in Gender & Sexuality Studies. 

4. Ms. Perez has authorization to work in the U.S. under Deferred Action for 

Childhood Arrivals (“DACA”). 

Plaintiff California LULAC 

5. Plaintiff California LULAC is a Latino organization with members and chapters 

located in many cities and towns throughout the State of California. Plaintiff California LULAC 

files this action individually as a distinguished Latino civil rights organization and on behalf of 

its DACA recipient members, who are also members of the proposed class. One of LULAC’s 

primary functions and purposes is the improvement and advancement of educational 

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3 COMPLAINT UNDER 42 U.S.C. § 1981

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opportunities for persons of Latino and Mexican-American descent or nationality and the 

protection and defense of the civil rights of this major ethnic and national origin group. As an 

organization and on behalf of its members, California LULAC has championed the rights of 

Latino students for decades. 

6. Plaintiff California LULAC’s members include members of the proposed class. 

Defendants’ policy of denying loans to DACA recipients affects many of California LULAC’s 

members. Additionally, Defendants’ policy impedes California LULAC’s ability to carry out its 

mission to advance the educational attainment and civil rights of the Latino population in 

California and, more broadly, throughout the United States. 

Defendants

7. Wells Fargo is an American multinational banking and financial services holding 

company headquartered in San Francisco, California. It is the fourth largest bank in the United 

States. 

8. Wells Fargo & Co. is a Delaware corporation authorized to do business in this state. 

9. Wells Fargo, N.A. is a South Dakota corporation authorized to do business in this 

state. 

10. Wells Fargo offers consumers a range of financial services, including private 

student loans to help undergraduate and graduate students pay for eligible academic expenses. 

11. Wells Fargo, by soliciting, conducting, and transacting business in the state of 

California, engages in continuous, permanent, and substantial activity within the state. 

12. Wells Fargo is not a federal enclave and therefore is subject to Plaintiff’s Section 

1981 claim. 

JURISDICTION AND VENUE 

13. This Court has subject matter jurisdiction over Plaintiff’s Section 1981 claim 

pursuant to 28 U.S.C. § 1331. This Court has supplemental jurisdiction over Plaintiff’s state law 

claims pursuant to 28 U.S.C. § 1367. 

 

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4 COMPLAINT UNDER 42 U.S.C. § 1981

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14. This Court is empowered to issue a declaratory judgment pursuant to 28 U.S.C. §§ 

2201 and 2202. 

15. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b)(2) because a 

substantial part of the events or omissions giving rise to the claims occurred in this district and 

Defendant conducts business within this district. 

16. Intradistrict assignment: Pursuant to N.D. Cal. Local Rules 3-2(c) and (d), 

intradistrict assignment to the San Francisco Division is proper because a substantial part of the 

events which give rise to the claims asserted herein occurred at Wells Fargo’s headquarters located 

in San Francisco County. 

BACKGROUND 

17. On June 15, 2012, President Obama announced that the Department of Homeland 

Security (“DHS”) would no longer remove certain young immigrants under its authority to grant 

deferred action as embodied in DACA. 

18. DACA’s purpose, according to President Obama, was to “[stop] expel[ling] talented 

young people, who . . . [have] been raised as Americans; understand themselves to be part of this 

country . . . [and] who want to staff our labs, or start new businesses, or defend our country.”1

19. DACA is a form of deferred action, a discretionary grant of authorized stay by the 

federal government. Deferred action granted through DACA is valid for two years and is subject 

to renewal thereafter. 

20. DACA mandates that persons who are granted deferred action will be eligible to 

obtain an Employment Authorization Document (an “EAD” or “federal work permit”) and a 

Social Security number. In other words, those granted deferred action and in possession of an 

EAD are legally authorized to work in the United States, and can prove their identity. 

 

1

 President Obama, Remarks by the President on Immigration (June 15, 2012), available at

http://www.whitehouse.gov/the-press-office/2012/06/15/remarks-president-immigration (last 

visited January 30, 2017). 

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5 COMPLAINT UNDER 42 U.S.C. § 1981

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21. As of March 31, 2016, the United States Citizenship and Immigration Services 

(“USCIS”) has approved over 1.3 million initial and renewal requests for DACA.2 

22. There is no federal or state law or regulation that restricts banks from providing 

financial products to customers because the customer is an alien. Under federal law, alienage is 

merely one factor among many used to verify enough information to confirm the true identity of 

the customer. 

23. For instance, the Federal Financial Institutions Examination Council (“FFIEC”) 

provides uniform principles and standards to offer guidance for federal regulators. The FFIEC 

annually publishes the Bank Secrecy Act/Anti-Money Laundering Examination Manual for Money 

Services, which contains a compliance program called the Customer Identification Program 

(“CIP”), as required by section 326 of the USA PATRIOT Act, 31 U.S.C. § 5318. Pursuant to 

CIP, institutions providing financial services, including banks, must have a written policy in place 

to enable them to form a reasonable belief that they know the true identity of each customer. The 

goal behind this requirement is to prevent the funding of terrorism both inside and outside of the 

United States.3

24. According to the Bank Secrecy Act/Anti-Money Laundering Examination Manual, 

a bank’s CIP must contain account-opening procedures detailing the identifying information that 

must be obtained from each customer. At a minimum, the bank must obtain the following 

information from each customer before opening an account: 1) name, 2) date of birth, 3) address, 

 

2

 USCIS, Number of I-821D, Consideration of Deferred Action for Childhood Arrivals by 

Fiscal Year, Quarter, Intake, Biometrics and Case Status: 2012-2016 (March 31), available at

https://www.uscis.gov/sites/default/files/USCIS/Resources/Reports%20and%20Studies/Immig

ration%20Forms%20Data/All%20Form%20Types/DACA/I821d_performancedata_fy2016_qtr

2.pdf (last visited January 30, 2017). 

3

 See 12 C.F.R. 208.63(b), 211.5(m), 211.24(j) (Board of Governors of the Federal Reserve 

System); 12 C.F.R. 326.8(b) (Federal Deposit Insurance Corporation); 12 C.F.R. 748.2(b) 

(National Credit Union Administration); 12 C.F.R. 21.21 (Office of the Comptroller of the 

Currency); 12 C.F.R. 563.177(b) (Office of Thrift Supervision); and 31 C.F.R. 103.121 

(FinCEN). 

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6 COMPLAINT UNDER 42 U.S.C. § 1981

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and 4) identification number (e.g., Social Security number, taxpayer identification number or an 

alien identification number).4 

25. The bank’s procedure must also describe when it will use documents, nondocumentary methods, or a combination of both. Federal banking agencies expect that banks will 

review an unexpired government-issued form of identification from most customers. The 

identification must include evidence of the customer’s nationality or residence and bear a 

photograph or similar safeguard.5 

26. Compliance with the CIP is to ensure that a bank verify enough information to form 

a reasonable belief that it knows the true identity of the customer.6 

27. “Opening an account” and a financial services “customer” for purposes of the Bank 

Secrecy Act/Anti Money Laundering Examination Manual for Money Services includes an 

individual who has applied for a loan application.7

 

STATEMENT OF FACTS 

Plaintiff Perez 

28. Ms. Perez is a DACA recipient with an EAD. She is a third-year student at UC 

Riverside. 

29. On August 26, 2016, Ms. Perez sought a student loan through the Wells Fargo 

website to help pay for college and college-incurred debt. After answering a few preliminary 

questions, including that she was seeking a loan to pay student expenses, that she was a junior in 

college, and that she was neither a U.S. citizen nor a permanent resident, she was denied a loan, 

receiving a message that read: “Thank you for your interest in a Wells Fargo student loan. 

 

4

 Fed. Fin. Inst. Examination Council, Bank Secrecy Act/Anti-Money Laundering 

Examination Manual 54 (2010), available at 

http://www.ffiec.gov/bsa_aml_infobase/documents/bsa_aml_man_2010.pdf (last visited 

January 30, 2017). 

5

 Id. at 54 n.48. 

6

 Id. at 52-4. 

7

 Id. at 53. 

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7 COMPLAINT UNDER 42 U.S.C. § 1981

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However, based on information you provided, we do not have a student loan option that meets 

your needs. This could be due to the school you selected, your field of study, and/or your 

citizenship status.” 

30. In an attempt to better understand the reason for the denial, Ms. Perez returned to 

the prior screen and changed the response to the question about citizenship to “I am a permanent 

resident alien,” and she received information about a student loan option. At the top of the 

screen there was a note that read: “Based on the citizenship status you provided, a U.S. citizen 

cosigner will be required for this application.” Ms. Perez was thus denied a student loan due to 

her citizenship status. Had Ms. Perez been allowed to apply for a loan, she would have had a 

cosigner available to meet Wells Fargo’s cosigner requirement. 

31. As a result of Wells Fargo’s denial, Ms. Perez was forced to cover her entire 

tuition using various credit cards. 

32. Had Wells Fargo allowed Ms. Perez to proceed with her loan application, Ms. 

Perez would have provided Wells Fargo with personal identification documents including her 

EAD, Social Security number, license and passport—all of which serve to confirm Ms. Perez’s 

identity in order to fulfill CIP requirements, see infra pp. 4-6 (section on “CIP Requirements”). 

Defendants’ Policy is Unlawful and Harms Plaintiffs 

33. Wells Fargo’s refusal to offer Plaintiff Perez and other DACA recipients who are 

members of California LULAC an opportunity to contract for private loans because of its arbitrary 

citizenship requirements is a violation of 42 U.S.C. § 1981. 

34. Wells Fargo’s refusal to offer Plaintiff Perez and DACA recipients who are 

members of California LULAC an opportunity to contract for private loans violates California’s 

Unruh Civil Rights Act. 

35. Wells Fargo’s refusal to offer Plaintiff Perez and DACA recipients who are 

members of California LULAC an opportunity to contract for private loans violates the California 

Unfair Competition Law. 

 

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8 COMPLAINT UNDER 42 U.S.C. § 1981

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36. In addition, Defendants’ unlawful policy harms California LULAC’s ability to carry 

out its mission and forces it to divert resources from its primary advocacy projects in order to assist 

its members who are adversely affected by their inability to obtain student loans from Defendants. 

37. There is an actual and substantial controversy between Plaintiffs and Defendants. 

CLASS ACTION ALLEGATIONS

38. Plaintiff Perez brings her class allegations under Fed. R. Civ. P. 23(a), (b)(2) and 

(b)(3) on behalf of a class defined as follows: All persons within the jurisdiction of the United 

States who were denied the right to contract for a loan or other financial product by Wells Fargo 

because they were not U.S. citizens despite satisfying Wells Fargo’s CIP requirements between 

January 30, 2013 and the date of judgment in this action (the “Class”). 

39. Plaintiff Perez is a member of the Class. 

40. Upon information and belief, the members of the Class are so numerous that joinder 

of all of them is impracticable. Wells Fargo has offices throughout the United States, USCIS has 

approved over 1.3 million initial and renewal requests for DACA, and there are thousands of 

people who do not meet Wells Fargo’s citizenship status requirements. Plaintiffs do not know the 

precise number of Class members as this information is in Wells Fargo’s possession. 

41. There are questions of law and fact common to the Class, and these questions 

predominate over any questions affecting only individual members. Common questions include, 

among others: (1) whether it is Wells Fargo’s policy or practice to reject loan applicants because 

they are not U.S. citizens or permanent residents despite satisfying CIP requirements; (2) whether 

Wells Fargo’s policy as set forth above deprives Plaintiff Perez and the Class of the right to 

contract in violation of Section 1981; (3) whether Wells Fargo’s policy as set forth above deprives 

Plaintiff Perez and the Class of rights Under the Unruh Civil Rights Act; (4) whether Wells 

Fargo’s policy as set forth above deprives Plaintiff Perez and the Class of rights under the 

California Unfair Competition Law; (5) whether the Plaintiff Perez and the Class suffered harm by 

reason of Defendant’s unlawful policy; (6) whether Plaintiff Perez and the Class are entitled to 

compensatory damages; (7) whether Plaintiff Perez and the Class are entitled to punitive damages; 

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9 COMPLAINT UNDER 42 U.S.C. § 1981

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(8) what equitable and injunctive relief for the Class is warranted; and (9) the scope of a resulting 

permanent injunction. 

42. Plaintiff Perez’s claims are typical of the claims of the Class: (1) Plaintiff was 

within the jurisdiction of the United States and not a citizen of the United States; (2) Plaintiff 

sought a loan from Wells Fargo; and (3) Plaintiff was refused due to her alienage status. All of 

these claims are substantially shared by each and every class member. All of the claims arise from 

the same course of conduct by Defendants, and the relief sought is common. 

43. Plaintiff Perez will fairly and adequately represent and protect the interests of the 

members of the Class. Plaintiff Perez has no conflict with any class member. Plaintiff Perez is 

committed to the goal of having Wells Fargo revise its lending requirements to stop discriminating 

against Plaintiff Perez and others who are not U.S. citizens. 

44. Plaintiff Perez has retained counsel competent and experienced in complex 

discrimination class actions. 

45. The universe of people affected by Wells Fargo’s unlawful policy is ascertainable 

through Defendants’ records and therefore the proposed class is ascertainable. 

46. Class certification is appropriate pursuant to Fed. R. Civ. P. 23(b)(2) because Wells 

Fargo has acted and/or refused to act on grounds generally applicable to the Class, making 

appropriate declaratory and injunctive relief with respect to Plaintiff and the Class as a whole. 

Wells Fargo has refused to extend financial services to anyone who does not fit its citizenship 

requirements, i.e., the Class. The Class members are entitled to injunctive relief to end Wells 

Fargo’s common, uniform, unfair, and discriminatory policy and/or practice and other make-whole 

relief. 

47. Class certification is also appropriate pursuant to Fed. R. Civ. P. 23(b)(3) because 

common questions of fact and law predominate over any questions affecting only individual 

members of the Class, and because a class action is superior to other available methods for the fair 

and efficient adjudication of this litigation since joinder of all members is impracticable. The 

Class members have been damaged and are entitled to recovery as a result of Wells Fargo’s 

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common, uniform, unfair, and discriminatory policies and practices. Damages are capable of 

measurement on a classwide basis. The propriety and amount of punitive damages are based on 

Wells Fargo’s conduct, making these issues common to the Class. Plaintiff Perez and the Class 

will rely on common evidence to resolve their legal and factual questions. There are no pending 

actions raising similar claims. Defendants engage in continuous, permanent, and substantial 

activity in California. There will be no undue difficulty in the management of this litigation as a 

class action. 

FIRST CLAIM FOR RELIEF 

Alienage Discrimination 

(42 U.S.C. § 1981) 

48. Plaintiffs incorporate by reference the allegations in all preceding paragraphs. 

49. Plaintiff Perez brings this claim on her own behalf and on behalf of the Class. 

50. Plaintiff California LULAC brings this claim on its behalf. 

51. Plaintiff Perez is a person within the jurisdiction of the United States. 

52. Plaintiff Perez is an alien. 

53. Plaintiff Perez satisfied Wells Fargo’s CIP requirements to obtain a private loan. 

54. Plaintiff Perez has the right to make and enforce contracts in the United States and 

is entitled to the full and equal benefits of the law. 

55. Wells Fargo intentionally discriminated against Plaintiff Perez and the Class on the 

basis of alienage by denying them the opportunity to contract for a loan. 

56. Wells Fargo’s intentional discrimination against Plaintiff Perez and the Class 

interfered with their right to make and enforce contracts for financial products. 

57. Defendant’s policy and practice of denying loans based on Plaintiff Perez’s and the 

Class’s alienage harmed Plaintiff Perez and the Class and constitutes unlawful alienage 

discrimination in the making and enforcing of contracts in violation of 42 U.S.C. § 1981. Plaintiff 

California LULAC has also been harmed, as it has been forced to divert resources from its primary 

advocacy projects in order to assist its members who are adversely affected by their inability to 

obtain student loans from Defendants. 

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58. Plaintiffs and the Class have no plain, adequate, or complete remedy at law to 

redress the wrongs alleged herein, and the injunctive relief sought in this action is the only means 

of securing complete and adequate relief. Plaintiff Perez and the Class she seek to represent are 

now suffering, and will continue to suffer, irreparable injury from Defendant’s discriminatory acts 

and omissions. 

59. Defendant’s conduct has caused, and continues to cause, Plaintiff Perez and the 

members of the Class substantial losses in earnings and other work benefits. 

SECOND CLAIM FOR RELIEF 

Violation of the Unruh Civil Rights Act 

(California Civil Code §§ 51 and 52 et seq.) 

60. Plaintiffs incorporate by reference the allegations in all preceding paragraphs. 

61. Plaintiff Perez brings this claim on her own behalf and on behalf of the Class. 

62. Plaintiff California LULAC brings this claim on its behalf. 

63. Plaintiff Perez is a person within the jurisdiction of the United States. 

64. Plaintiff Perez is an alien who holds DACA status. 

65. Plaintiff Perez satisfied Wells Fargo’s CIP requirements to obtain a private loan. 

66. Plaintiff Perez is entitled to the full and equal accommodations, advantages, 

facilities, privileges, or services in all business establishments of every kind whatsoever no matter 

her immigration status and no business establishment of any kind whatsoever may refuse to 

contract with Plaintiff Perez because of her immigration status. 

67. Wells Fargo intentionally discriminated against Plaintiff Perez and the Class on the 

basis of immigration status by denying them the opportunity to contract for a loan, and in doing so 

denied them the full and equal services of its business. 

68. Wells Fargo’s intentional discrimination against Plaintiff Perez and the Class 

interfered with their right to full and equal services and their right to make and enforce contracts 

for financial products. 

69. Defendant’s policy and practice of denying loans based on Plaintiff Perez’s and the 

Class’s immigration status harmed Plaintiff Perez and the Class and constitutes unlawful 

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discrimination in violation of Sections 51(b) and 51.5 of the Unruh Civil Rights Act. Plaintiff 

California LULAC has also been harmed, as it has been forced to divert resources from its primary 

advocacy projects in order to assist its members who are adversely affected by their inability to 

obtain student loans from Defendants. 

70. Pursuant to the Section 52(a) of the Unruh Civil Rights Act, Plaintiff Perez and the 

Class are entitled to actual damages suffered, statutory damages of up to three times the amount of 

actual damages suffered per violation, but no less than $4,000, and attorney’s fees. Pursuant to 

Section 52(c) of the Unruh Civil Rights Act, Plaintiffs and the Class are also entitled to injunctive 

and other equitable relief against such unlawful practices in order to prevent future damages, for 

which there is no adequate remedy at law, and to avoid a multiplicity of lawsuits. 

THIRD CLAIM FOR RELIEF 

Violation of Unfair Competition Law 

(California Business and Professions Code §§ 17200 et seq.) 

71. Plaintiffs incorporate by reference the allegations in all preceding paragraphs. 

72. Plaintiff Perez brings this claim on her own behalf and on behalf of the Class. 

73. Plaintiff California LULAC brings this claim on its behalf. 

74. Wells Fargo’s policy and practice of denying loans based on Plaintiff Perez’s and 

the Class’s alienage and immigration status harmed Plaintiff Perez and the Class and constitutes 

unlawful discrimination in violation of Sections 51(b) and 51.5 of the Unruh Civil Rights Act and 

42 U.S.C. Section 1981. Plaintiff California LULAC has also been harmed, as it has been forced 

to divert resources from its primary advocacy projects in order to assist its members who are 

adversely affected by their inability to obtain student loans from Defendants. 

75. Wells Fargo’s violations of Sections 51(b) and 51.5 of the Unruh Civil Rights Act 

and 42 U.S.C. Section 1981 constitute unfair business practices in violation of Section 17200 of 

the California Unfair Competition Law.

76. Plaintiffs and the Class are entitled to injunctive and other equitable relief against 

such unlawful practices in order to prevent future damages, for which there is no adequate remedy 

at law, and to avoid a multiplicity of lawsuits. 

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13 COMPLAINT UNDER 42 U.S.C. § 1981

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77. Under the California Unfair Competition Law, Plaintiffs and the Class are entitled 

to injunctive relief and attorney’s fees. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiffs and the Class pray for relief as follows: 

78. Certification of the case as a class action on behalf of the proposed Class; 

79. Designation of Plaintiff Mitzie Perez as a representative on behalf of the Class; 

80. Designation of Plaintiffs’ counsel of record as Class counsel; 

81. A declaratory judgment that the practices complained of herein are unlawful and 

violate Section 1981, the Sections 51(b) and 51.5 of the Unruh Civil Rights Act, and Section 

17200 et seq. of the California Unfair Competition Law; 

82. A preliminary and permanent injunction against Defendants and its officers, agents, 

successors, employees, representatives, and any and all persons acting in concert with them, from 

engaging in each of the unlawful policies, practices, customs and usages set forth herein; 

83. All damages sustained as a result of Wells Fargo’s conduct, including damages for 

emotional distress, humiliation, embarrassment, and anguish, according to proof; 

84. Statutory damages to the extent allowable by law; 

85. Exemplary and punitive damages in an amount commensurate with Wells Fargo’s 

ability to pay and to deter future conduct; 

86. Injunctive remedies including restitution; 

87. Costs incurred herein, including reasonable attorneys’ fees to the extent allowable 

by law; 

88. Pre-judgment and post-judgment interest, as provided by law; and 

89. Such other and further legal and equitable relief as this Court deems necessary, just, 

and proper. 

Dated: San Francisco, California Respectfully submitted, 

 January 30, 2017 

 OUTTEN & GOLDEN LLP 

 By: Jahan C. Sagafi 

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14 COMPLAINT UNDER 42 U.S.C. § 1981

No. 17 Civ.454 

OUTTEN & GOLDEN LLP 

Jahan C. Sagafi 

Cal. Bar No. 224887 

Katrina Eiland 

Cal. Bar No. 275701 

One Embarcadero Center, 38th Floor 

San Francisco, CA 94111 

Telephone: (415) 638-8800 

Facsimile: (415) 638-8810 

jsagafi@outtengolden.com 

keiland@outtengolden.com 

Adam T. Klein* 

Ossai Miazad* 

Michael N. Litrownik* 

Olivia J. Quinto* 

685 Third Avenue, 25th Floor 

New York, NY 10017 

Telephone: (212) 245-1000 

Facsimile: (646) 509-2060 

atk@outtengolden.com 

om@outtengolden.com 

mlitrownik@outtengolden.com 

ojq@outtengolden.com 

Patrick David Lopez* 

601 Massachusetts Avenue 

Second Floor West Suite 

Washington DC, 20001 

Telephone: (202) 847-4400 

Facsimile: (202) 847-4410 

pdl@outtengolden.com 

MEXICAN AMERICAN LEGAL DEFENSE AND

EDUCATIONAL FUND

Thomas A. Saenz 

Victor Viramontes 

634 S. Spring St., 11th Floor 

Los Angeles, CA 90014 

Telephone: (213) 629-2512 

Facsimile: (213) 629-0266 

tsaenz@maldef.org 

vviramontes@maldef.org

* pro hac vice application forthcoming

Attorneys for Plaintiffs and the Proposed Class 

Case 3:17-cv-00454-JCS Document 1 Filed 01/30/17 Page 14 of 14