Anna Bower
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NEW: Kilmar Abrego Garcia’s lawyers seek permission to file an amended complaint in his civil case in Maryland.

Among other things, the amended complaint “includes Abrego Garcia's first-hand account of torture and mistreatment at CECOT…”
Case 8:25-cv-00951-PX
Document 211
Filed 07/02/25 Page 2 of 5
3. The proposed Amended Complaint details the Government's defiance of court
orders after this Court granted preliminary injunctive relief. The Amended Complaint includes
allegations that the Government made decisions to defy judicial mandates. These allegations are
new to the Complaint, but have been cited in various filings in this Court as the case has developed.
They are directly relevant to Plaintiffs' constitutional claims and outstanding requests for
declaratory and prospective injunctive relief.
4. Plaintiffs also seek to incorporate evidence that emerged in a June 2025
whistleblower disclosure from former DOJ official Erez Reuveni, who was previously counsel for
the Government in this case. The new allegations include government officials internally
acknowledging that Abrego Garcia's removal was an "administrative error" while simultaneously
working to prevent his return and to make post-hoc justifications. These revelations provide
evidence of deliberate misconduct that was unavailable when the original Complaint was filed and
directly support Plaintiffs' claims.
5. The proposed Amended Complaint also Includes Abrego Garcia's first-hand
account of torture and mistreatment at CECOT, as well as developments regarding his return to the United States and the Government's stated plan to remove him again. These allegations identify
the severe harm actually suffered and the threat of repeated unlawful removal that supports
Plaintiffs' request for prospective injunctive relief. The inclusion of these facts, which could not
have been pleaded at the time of the original filing, is essential to present a complete picture of the
violations and ensure adequate relief.
6. Plaintiffs also propose to clarify that the relief sought includes restoring the status
quo ante, which requires (among other things) the Government to return Abrego Garcia to
2
ALT
July 2, 2025 at 5:22 PM

Anna Bower
‪@annabower.bsky.social‬

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Here’s Abrego Garcia’s amended complaint.

It alleges that Abrego Garcia “was subjected to severe mistreatment upon arrival at CECOT, including but not limited to severe beatings, severe sleep deprivation,
inadequate nutrition, and psychological torture..”

https://storage.courtlistener.com/recap/gov.uscourts.mdd.578815/gov.uscourts.mdd.578815.211.3.pdf

Case 8:25-cv-00951-PX Document 211-3 Filed 07/02/25 Page 22 of 40
114. Inmates in CECOT are confined to their cells for 23.5 hours daily and cannot go
outdoors. They are denied access to reading materials, including even letters from friends or
family. Inmates are prohibited from receiving visits from family and friends. Meals are provided
through the bars, and the facility enforces strict regulations to maintain order. See Ex. H.
115. In May 2023, Cristosal, a leading human rights organization in El Salvador,
released a comprehensive report detailing severe human rights abuses within the country's prison
system, especially CECOT. See Ex. I. The investigation documented the deaths of 153 inmates
between March 27, 2022, and March 27, 2023, attributing many to torture, beatings, mechanical
asphyxiation (strangulation), and lack of medical attention. Id. Autopsies revealed common
patterns of lacerations, hematomas, sharp object wounds, and signs of choking or strangulation.
Id. Survivors reported being forced to pick food off the floor with their mouths, subjected to
electric shocks, and exposed to untreated skin fungus epidemics. Id. Cristosal's director has
emphasized that these systemic violations have become state policy. Id.
116. Plaintiff Abrego Garcia reports that he was subjected to severe mistreatment upon
arrival at CECOT, including but not limited to severe beatings, severe sleep deprivation,
inadequate nutrition, and psychological torture
117. Plaintiff Abrego Garcia was the first name called to disembark the plane that
transported him to El Salvador on March 15, 2025. As he exited the aircraft, still in chains, two officials grabbed his arms and pushed him down the stairs, forcing his head down.
118. There were strong lights illuminating the area despite it being nighttime, and
cameras were filming the detainees' arrival.
119. Plaintiff Abrego Garcia was pushed toward a bus, forcibly seated, and fitted with a
second set of chains and handcuffs. He was repe…
ALT
July 2, 2025 at 5:32 PM

Asha Rangappa
‪@asharangappa.bsky.social‬

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This is why they didn’t want him back: He is a witness.

‪Anna Bower‬
‪@annabower.bsky.social‬
· 1h
“In Cell 15, Plaintiff Abrego Garcia and 20 other Salvadorans were forced to kneel from approximately 9:00 PM to 6:00 AM, with guards striking anyone who fell from exhaustion. During this time, Plaintiff Abrego Garcia was denied bathroom access and soiled himself…”
120. Upon arrival at CECOT, the detainees were greeted by a prison official who stated,
"Welcome to CECOT. Whoever enters here doesn't leave." Plaintiff Abrego Garcia was then
forced to strip, issued prison clothing, and subjected to physical abuse including being kicked in
the legs with boots and struck on his head and arms to make him change clothes faster. His head
was shaved with a zero razor, and he was frog-marched to cell 15, being struck with wooden batons
along the way. By the following day, Plaintiff Abrego Garcia had visible bruises and lumps all over his body.
121. In Cell 15, Plaintiff Abrego Garcia and 20 other Salvadorans were forced to kneel
from approximately 9:00 PM to 6:00 AM, with guards striking anyone who fell from exhaustion.
During this time, Plaintiff Abrego Garcia was denied bathroom access and soiled himself The
detainees were confined to metal bunks with no mattresses in an overcrowded cell with no
windows, bright lights that remained on 24 hours a day, and minimal access to sanitation.
122. After approximately one week at CECOT, prison director Osiris Luna and other
officials separated the 21 Salvadorans who had arrived together. Twelve individuals with visible gang-related tattoos were moved to another cell, while Plaintiff Abrego Garcia remained with eight
others who, like him, upon information and belief had no gang affiliations or tattoos.
123. As reflected by his segregation, the Salvadoran authorities recognized that Plaintiff Abrego Garcia was not affiliated with any gang and, at around this time, prison officials explicitly acknowledged that Plaintiff Abrego Garcia's tattoos were not gang-related, telling him "your
ALT
July 2, 2025 at 6:08 PM

Mrs. Betty Bowers
‪@mrsbettybowers.bsky.social‬

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Apparently, along with no longer liking free speech and due process, the United States now embraces cruel and unusual punishment.
July 2, 2025 at 6:13 PM