Case 8:25-cv-00951-PX Document 211-3 Filed 07/02/25
Page 11 of 40
46.
Prior to April 2025, Plaintiff Abrego Garcia had no criminal history. Separate and
apart from his May 21, 2025 Tennessee indictment, he has never been charged or convicted of any
criminal charges, in the United States, El Salvador, or any other country.
Plaintiff Abrego Garcia’s 2019 removal proceedings
47.
Plaintiff Abrego Garcia left El Salvador when he was around sixteen years old, fleeing gang violence. Beginning around 2006, gang members stalked, hit, and threatened to kidnap and kill him in order to coerce his parents to succumb to their increasing demands for
extortion.
48.
Sometime around 2011, Plaintiff Abrego Garcia entered the United States without inspection. He then made his way to the state of Maryland, where his older brother, a U.S. citizen, resided. In the United States, Plaintiff Abrego Garcia has only ever resided in Maryland.
49.
Around 2016, Plaintiff Abrego Garcia met Plaintiff Jennifer Vasquez Sura, a U.S. citizen with two U.S.-citizen children from a prior relationship. Over time, they became close and eventually became romantically involved.
50. Around December 2018, Plaintiff Abrego Garcia moved in with Plaintiff Vasquez Sura and her two children, after Plaintiff Vasquez Sura learned she was pregnant with their child. Plaintiff Abrego Garcia supported himself, Plaintiff Vasquez Sura, and her two children through work in the construction industry.
51. On March 28, 2019, Plaintiff Abrego Garcia went to a Home Depot in Hyattsville, Maryland to solicit employment. When he arrived, he joined three other young men who were also at Home Depot soliciting employment, two of whom he recognized from prior occasions at the Home Depot, though he had never interacted with them in any other context.
52.
At 2:27 PM, while the four of them were chatting, a detective from the Hyattsville City Police approached the group. The detective did not speak to Plaintiff Abrego Garcia, but only
10
