ORIGINAL eran ROBBINS GELLER RUDMAN & DOWD LLP DARREN J. ROBBINS (168593) RACHEL L. JENSEN (211456) JUAN CARLOS SANCHEZ (301834) 655 West Broadway, Suite 1900 San Diego, CA 92101 Telephone: 619/231-1058 619/231-7423 (fax) darrenr@rgrdlaw.com rjensen@rgrdlaw.com Jsanchez@rgrdlaw com ABLISH M. BAIG (201279) Post Montgomery Center One Montgomery Street, Suite 1800 San Francisco, CA 94104 Telephone: 415/288-4545 415/288-4534 (fax) aelishm@rgrdlaw.com Attorneys for Plaintiff e IMA 21091342 FILED ALAMEDA COUNTY NOV 08 2018 oe Pacer SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA ROCIO CORDOVA, Individually and on Behalf of All Others Similarly Situated, Plaintiff, vs. GREYHOUND LINES, INC., and DOES 1-100, Defendants. VIA FAX RGis9280z28 Case No, CLASS ACTION COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF ‘COMPLAINT FOR PUBLIC INJUNCTIVE RELIEFSee raga u 13, 14 15 16 7 18 19 20 2 22 23 24 25 26 27 28 Plaintiff Rocfo Cordova (“Plaintiff”) brings this action against Defendants Greyhound Lines, Inc. (“Greyhound” or the “Company”) and Does 1-100 (collectively, “Defendants”), individually and on behalf of a statewide class of similarly situated California citizens (as defined below), for public injunctive relief. Plaintiff alleges the following based upon personal knowledge as to her own acts, and upon information and belief as to all other matters based on the investigation of counsel. Plaintiff believes that substantial additional evidentiary support will exist for the allegations in this Complaint after a reasonable opportunity for discovery. INTRODUCTION 1. Greyhound Lines, Inc. (“Greyhound” or the “Company”) is a private intercity bus company that operates throughout the State of California. Greyhound has adopted a policy or practice of voluntarily opening its doors to armed and uniformed U.S, Customs and Border Protection (“CBP”) agents in order to allow discriminatory immigration raids to be conducted in the passenger cabins of domestic buses without a warrant, probable cause, or reasonable suspicion. Greyhound’s policy has and continues to impact thousands, if not tens of thousands, of consumers in California. 2. Greyhound uniformly promises California consumers that all of its passengers have a “right” to be free from discrimination aboard its buses, assuring passengers that, at Greyhound, “[w]e have no room for discrimination. ... We're not concerned about your race, your color, what you believe or where you're from. We just want to get you safely to your destination. No person or group of persons shall be discriminated against on the basis of race, color, [or] national origin...” Greyhound even assures consumers: “If your English is limited . .. that’s ok!” 3. What Greyhound omits is that it has a policy or practice of voluntarily providing CBP agents with access upon request to its bus fleet for random and discriminatory immigration raids of Greyhound’s own paying customers, As a result of Greyhound’s actions, California consumers who contract for safe passage on Greyhound’ coach services have been subjected to ~ and are at ongoing risk for ~ discrimination based on race, color, ancestry, national origin, and primary language. Ona macro level, Greyhound buses are the sites for such raids precisely because Greyhound’s ridership is disproportionately non-white and low-income, particularly Latino, Indeed, CBP agents have’ pejoratively referred to such raids as “immigration Dumpster-diving.” And onboard, passengers of | ee ‘COMPLAINT FOR PUBLIC INJUNCTIVE RELIEFcolor are targeted for harassment and demeaning accusations like “a}re you illegal?” It is widely reported that interrogations are focused on non-white passengers. For example, passengers of color are woken up and harshly questioned, whereas white passengers are left to sleep. 4. Greyhound’s policy or practice is to voluntarily grant CBP agents’ requests to conduct sweeps in the restricted-access passenger cabin (ie., non-public areas) after the passengers are trapped within the confines of the bus, Videos taken by Greyhound passengers confirm Defendants’ voluntary policy or practice and show agents working from the front of the bus to the back, blocking narrow aisles and bus doors, hovering over passengers of color, and asking demeaning and accusatory questions about. their citizenship and immigration status. Se 5. This is all by design; otherwise, passengers would be approached before they board or after they disembark the bus. And some passengers are detained well beyond the initial 15-30 minute delay ~ those who do not provide proof of their status are taken off the bus and often arrested. 6. Greyhound’s voluntary policy or practice also includes delaying buses while agents interrogate passengers and providing CBP agents with access to Greyhound’s private staff break rooms and back office areas at bus stations for secondary questioning. Greyhound station managers have prevented dissenters from videotaping such raids and defended Greyhound’ policy, with one manager reportedly proclaiming: “Greyhound will always welcome Border Patrol here.” Ee COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF