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Jesse Newmark (SBN 247488)

Aidin Castillo (SBN 280262)

CENTRO LEGAL DE LA RAZA

3022 International Blvd., Suite 410

Oakland, California 94601

Telephone: (510) 437-1863

jnewmark@centrolegal.org

acastillo@centrolegal.org

Attorneys for Plaintiffs and the Class

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

JUAN QUINTANILLA VASQUEZ, 

GABRIELA PERDOMO ORTIZ, VICTOR 

HUGO CATALAN MOLINA, and KEVIN 

CALDERON, individually and on behalf of 

all others similarly situated,

 Plaintiffs,

v.

LIBRE BY NEXUS, INC. and JOHN DOES 

1-50,

 Defendants.

Case No. 4:17-cv-00755-CW

DECLARATION OF KEVIN 

CALDERON IN SUPPORT OF 

PLAINTIFFS’ MOTION FOR FEES, COSTS, AND SERVICE AWARDS

Judge: Hon. Claudia Wilken

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW

CALDERON DECL. ISO MOTION FOR FEES, COSTS, AND SERVICE AWARDS

Case 4:17-cv-00755-CW Document 147-7 Filed 09/01/20 Page 1 of 5
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1. My name is Kevin Calderon. I am a named Plaintiff and Class Representative in this 

case. I have personal knowledge of the facts set forth in this declaration and could and 

would testify competently to them if called upon to do so. I am providing this declaration 

in support of Plaintiffs’ Motion for Fees, Costs, and Service Awards.

2. I came to the United States in April 2013, fleeing death threats by gang members and 

criminals who murdered my father.

3. My wife, Gabriela Perdomo Ortiz, came to the United States in April 2015 seeking 

asylum. 

4. She was placed in detention in Houston, Texas, and an Immigration Judge set her bond 

for $20,000.

5. My wife and I eventually contacted Libre by Nexus (LBN), who arranged for her bond to 

be paid.

6. In exchange, we made payments to LBN and my wife had to wear an ankle monitor. 

7. My wife and I believed that LBN could cause her to be sent back to immigration 

detention or Honduras. At one point, an LBN employee told her that she could be 

incarcerated if we missed payments.

8. We paid a total of over $23,000 to LBN, including up front and monthly fees.

9. My family has a modest income and we have undergone substantial hardship paying fees 

to LBN and for our other expenses. For instance, we have had to forgo buying groceries 

at times.

10. In May 2017, I met with Aidin Castillo, an attorney for Centro Legal to discuss my 

experience with LBN and participating in a lawsuit that my wife was already a part of.

11. Over the course of several weeks in June 2017, I had multiple meetings and calls with 

Ms. Castillo and other attorneys about the facts in this case. I traveled to Centro Legal’s 

office at least two times that month for meetings and a call with other attorneys on the 

case.

12. In June 2017, I also met with the attorneys to review the complaint in the case and to 

share and discuss the documents involved. 

Page 1 of 4

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CALDERON DECL. ISO MOTION FOR FEES, COSTS, AND SERVICE AWARDS

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13. In July 2017, I had phone calls and met with the attorneys to prepare for a deposition. I 

then went to the deposition in San Francisco, which lasted all day. 

14. In 2018 and 2019, I stayed in contact with the attorneys to answer questions about facts 

and get updates on the case and settlement talks. 

15. In about October 2019, I met with the attorneys to review and sign a retainer to become a 

named plaintiff and represent the sponsors in this case.

16. In 2020, I had more phone calls with my attorneys to discuss and review the settlement 

and other updates. 

17. During this time, I have also spent many hours talking with my wife and family and 

thinking about the case on my own, to prepare for meetings and the deposition. I also 

made time to be available to speak with the attorneys during a number of mediations, and 

reviewed and corrected my deposition transcript.

18. I did all of this even though it was very difficult for me and my family, because I cared 

about changing the policies at LBN for others in my situation.

19. I decided to file this class action because I knew that many others were affected by the 

same policies, but would be too scared to come forward. I felt a responsibility to stand 

up for their rights too.

20. However, I was also very frightened about proceeding. My wife had fled Honduras 

because of violence to seek asylum. She had also just gotten out of immigration 

detention, because LBN had arranged for her bond to be paid. Our immigration removal 

proceedings to decide our asylum claims were pending. 

21. I was particularly frightened that LBN or ICE could retaliate against us for filing this 

lawsuit, and put my wife back in detention or send her back to Honduras. I was scared 

they would call immigration about both of us. 

22. Our immigration case is still ongoing and just thinking that we could be sent back would 

make us feel very anxious. We have a young daughter who is a U.S. citizen and she 

deserves to grow up here, but that could have been taken away if LBN ever called 

immigration. 

Page 2 of 4

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CALDERON DECL. ISO MOTION FOR FEES, COSTS, AND SERVICE AWARDS

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23. My wife and I definitely had moments where we thought we had not made the right 

decision in joining the lawsuit. We were scared, but then we remembered how hard it has 

been for us to make payments. There were times when we didn’t buy enough groceries 

because we knew we had to save money to make payments, and that was really difficult 

to remember. We also had to borrow money on two occasions to be able to make the 

monthly payments. It is always difficult to ask for money. People don’t really want to 

help you and you feel like you owe them more than the money.

24. My attorneys also told me that a class action could take a long time and that there was no 

guarantee we would win anything. They also told me that class actions could be difficult 

and time-consuming and that I would have to act in the best interest of others who went 

through a similar process with LBN, even if it meant a greater sacrifice from me. 

25. Over the last three years, I have been very anxious about this case and possible 

retaliation.

26. The deposition was especially hard. I couldn’t sleep for about two weeks before then. I 

was worried LBN would retaliate against my wife and put the ankle shackle back on her. 

I was really nervous the entire time. 

27. My goal has always been to make sure LBN is fair to everyone who is in the program, 

not just those who have lawyers. I am hopeful that this case will make sure things turn 

out that way for everyone. 

28. I did not expect, nor was I ever promised that I would receive a service award. However, 

I believe that the proposed service award would fairly compensate me for the time, effort, 

and sacrifices I have made with this case. I also understand that I have signed a release 

of all claims I could have against LBN, which is a bigger release than the rest of the class.

29. I am very proud of the outcome of this case because I believe it will make things better 

for other clients and sponsors of LBN.

Page 3 of 4

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CALDERON DECL. ISO MOTION FOR FEES, COSTS, AND SERVICE AWARDS

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I declare under penalty of perjury under the laws of California that the foregoing is true 

and correct, and that this declaration was executed in Oakland, California, on September 1, 2020. 

____________________________ 

KEVIN CALDERON

Page 4 of 4 

Vasquez v. Libre by Nexus, Inc. Case No. 4:17-cv-00755-CW

CALDERON DECL. ISO MOTION FOR FEES, COSTS, AND SERVICE AWARDS

Case 4:17-cv-00755-CW Document 147-7 Filed 09/01/20 Page 5 of 5