10. Attorneys routinely contact their clients in both TCJ and TCCC by phone or  videoconference to discuss confidential matters. They do so with the understanding their  conversations are private. Similarly, inmates understand remote conversations with their  attorneys are confidential and not recorded.   11. TCJ and TCCC’s phone and videoconferences services are provided by Securus  Technologies. Its software automatically records communications between inmates and the  outside world, including (and unlawfully) inmates’ communication with attorneys. It stores those  recordings in a computer server, to which the Sheriff’s Department has access.   12. The Sheriff’s Department tells the public it does not record attorney-client calls. For  instance, its “Jail Information” webpage says an inmate’s calls to his attorney “are free of charge  and are not recorded.”1 Similarly, Securus Technology’s website promises “[video] visits are  secure and completely private for legal counsel.”2   13. But in reality, Securus Technology and the Sheriff’s Department do record  confidential attorney-client communications. They also disclose those recorded conversations to  prosecutors in the Travis County and District Attorneys’ Offices.   15. Although defense attorneys in Austin have discerned Defendants’ practices and  confronted them, Defendants appear to have no intention of ceasing their unlawful,  unconstitutional eavesdropping and invasion of attorney-client communication.  24. Pursuant to Federal Rule of Civil Procedure 23(a) and 23(b), Plaintiffs bring this  action on behalf of themselves and a class of similarly situated persons, defined as attorneys  practicing criminal defense in Austin or Travis County. The Class seeks certification of claims  for declaratory and injunctive relief.   26. Commonality: The Class has a well-defined community of interest in the questions  of law and fact in this matter – including the recording/use of their confidential communications,  the practice’s unlawfulness, and the necessity for declaratory and injunctive relief.   27. Typicality: The individual Plaintiffs’ claims are typical of Class members’ claims,  because Plaintiffs are individual members of the larger community of local criminal defense  attorneys with clients in the TCJ and TCCC, who have similar practices and operate under  similar constraints.   28. Adequacy: Plaintiffs are adequate representatives of the Class because their  interests do not conflict with the interests of the Class members they seek to represent. Plaintiffs  will fairly and adequately protect the interest of the members of the Class; they intend to  prosecute this action vigorously.    29. This suit may also be maintained as a class action pursuant to Federal Rule of Civil  Procedure 23(b)(2) because Plaintiffs and the Class seek declaratory and injunctive relief.  Defendants have acted on grounds generally applicable to Plaintiffs and the Class as a whole,  thereby making declaratory and/or injunctive relief proper.  9.  A person is arrested in Austin or Travis County is typically brought to TCJ  downtown to be booked. TCJ is run by the Sheriff’s Department. In most cases, if the Sheriff’s  Department plans to hold that person for more than a short time, it soon transfers the individual  to TCCC in Del Valle, Texas.   OFFICE, and DAVID ESCAMILLA, in his  official capacity.  Defendants.  §  §  §  §  §  §  §  §  §  §  and GREG HAMILTON, in his official  capacity; TRAVIS COUNTY DISTRICT  ATTORNEY’S OFFICE, and ROSEMARY  LEHMBERG, in her official capacity; and 