June 25, 2018

Via U.S.P.S. Certified Mail and Electronic Mail, FOIA Online Portal or Fax
Sam Kaplan
Chief Privacy Officer/Chief FOIA Officer
The Privacy Office
U.S. Department of Homeland Security
245 Murray Lane SW
STOP-0655
Washington, D.C. 20528-0655
foia@hq.dhs.gov
For Department of Homeland Security and
the Office of Civil Rights and Civil Liberties

Valerie H. Yancey
FOIA Officer and Executive Officer
Office of the Solicitor General
Department of Justice
950 Pennsylvania Avenue, N.W.
Room 6627
Washington, DC 20530-0001
OSGFOIA@usdoj.gov

Catrina Pavlik-Keenan
U.S. Immigration and Customs Enforcement
Freedom of Information Act Office
500 12th Street, SW, Stop 5009
Washington, D.C. 20536-5009
ice-foia@dhs.gov

Melissa Golden
Lead Paralegal and FOIA Specialist
Department of Justice
950 Pennsylvania Avenue, N.W.
Room 5511
Washington, DC 20530-0001
usdoj-officeoflegalcounsel@usdoj.gov

Jill Eggleston
FOIA Officer/Public Liaison
U.S. Citizenship and Immigration Services
National Records Center, FOIA/PA Office
150 Space Center Loop, Suite 300
Lee’s Summit, MO 64064-8010
uscis.foia@uscis.dhs.gov

Sabrina Burroughs
FOIA Officer/Public Liaison
Customs and Border Protection
300 Pennsylvania Avenue N.W.
Room 3.3D
Washington, D.C. 20229

Hirsh D. Kravitz
FOIA, Records, and E-Discovery Office
Civil Division
Department of Justice
Room 8314

Dionne Hardy
FOIA Officer
Office of Management and Budget
725 17th Street NW, Suite 9204
Washington, DC 20503
OMBFOIA@omb.eop.gov

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June 25, 2018
Page 2
1100 L Street, NW
Washington, DC 20530-0001
Civil.routing.FOIA@usdoj.gov
Douglas Hibbard
Chief, Initial Request Staff
Office of Information Policy
Department of Justice, Suite 11050
1425 New York Avenue, N.W.
Washington, DC 20530-0001
Fax: (202) 514-1009
For U.S. Department of Justice and
the Office of the Attorney General

Michael Marquis
FOIA Officer
Department of Health and Human Services
Hubert H. Humphrey Building Room 729H
200 Independence Avenue, SW
Washington, D.C. 20201
FOIARequest@hhs.gov

Kimberly Epstein
FOIA Officer (Acting)
Administration for Children and Families
(ACF)
Mary E. Switzer Building
330 C ST SW, Suite 4004
Washington, DC 20201
FOIA@acf.hhs.gov
For Administration for Children and Families
and the Office of Refugee Resettlement

Department of the Navy
Chief of Naval Operations
FOIA/Privacy Act Program Office
ATTN: DNS 36
2000 Navy Pentagon
Washington DC 20350-2000
DONFOIA-PA@Navy.mil

OSD/JS FOIA Requester Service Center
Office of Freedom of Information
1155 Defense Pentagon
Washington, DC 20301-1155
Fax: (571) 372-0500

Dear FOIA Officers:
The National Immigration Law Center (NILC) (“NILC” or “Requestor”) makes this request for
information under the Freedom of Information Act (FOIA), 5 U.S.C. § 552 et seq, for records,
regarding the separation of children and their parents or adult guardians, held by the United
States Department of Homeland Security (DHS); DHS Office of Civil Rights and Civil Liberties
(OCRCL); United States Citizenship and Immigration Services (USCIS); U.S. Immigration and
Customs Enforcement (ICE); U.S. Customs and Border Protection (CBP); White House Office
of Management and Budget (including the Office of Information and Regulatory Affairs)
(OMB); United States Department of Justice (DOJ); Office of the Attorney General (OAG);

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June 25, 2018
Page 3
DOJ Civil Division (CIV); Office of the Solicitor General (OSG); Office of Legal Counsel (DOJOLC); the U.S. Department of Health and Human Services (HHS), including the Administration
of Children and Families (ACF) and the Office of Refugee Resettlement (ORR); the U.S. Navy
(NAVY); and the Office of the Secretary of Defense (DOD).
BACKGROUND
On April 6, 2018, Attorney General Sessions announced a “zero-tolerance policy” that increased
the number of individuals prosecuted for criminal entry. As a result of that policy, over 2,300
children were forcibly removed from their parents or adult guardians and placed in detention
facilities. Numerous high-ranking administration officials have referred to the purpose of the
zero-tolerance policies and family separation policies as deterrence. White House Chief of Staff
John Kelly declared that “a big name of the game is deterrence” and that family separation
“could be a tough deterrent – would be a tough deterrent.” 1 Before the policy was announced,
Mr. Kelly said that he was considering a family separation policy because “in order to deter
more movement along this terribly dangerous network, I am considering exactly that. They will
be well cared for as we deal with their parents.” 2 On June 20, 2018, President Trump issued an
executive order entitled “Affording Congress an Opportunity to Address Family Separation.”
RECORDS REQUESTED
The Requestor seeks DHS, OCRCL, ICE, CBP, USCIS, OMB, DOJ, DOJ-OLC, OAG, CIV,
OSG, HHS, ACF, ORR, NAVY, and DOD records 3 related to or referring to (1) the policy and/or
practice of separating children from their parents or adult guardians after entry into the United
States (hereinafter, “Separation of Families Policy/Practice”) after entry into the United States,
(2) the “zero-tolerance policy” for prosecuting attempted illegal entry and illegal entry under 8
1

See Here Are the Administration Officials Who Have Said That Family Separation Is Meant as
a
Deterrent,
WASHINGTON
POST,
June
19,
2018,
https://www.washingtonpost.com/news/politics/wp/2018/06/19/here-are-the-administrationofficials-who-have-said-that-family-separation-is-meant-as-adeterrent/?utm_term=.58e8e27f41aa.
2
Id.
3
The term “records” as used herein includes but is not limited to all records or communications
preserved in electronic or written form, including but not limited to correspondence, including but
not limited to intra-governmental correspondence, documents, data, videotapes, audio tapes, faxes,
files, forms, e-mails, guidance, guidelines, evaluations, legal opinions, instructions, analyses,
directives, memoranda, agreements, notes, orders, policies, procedures, protocols, reports, rules,
technical manuals, technical specifications, training manuals, questionnaires, studies, including
records kept in written form, or electronic format on computers and/or other electronic storage
devices, electronic communications and/or video tapes, or any other sub- regulatory guidance.

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June 25, 2018
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U.S.C. § 1325(a) announced by Attorney General Sessions on April 6, 2018 4 (hereinafter, the
“Zero-Tolerance Policy”); or (3) the Executive Order entitled “Affording Congress an
Opportunity to Address Family Separation” dated June 20, 2018 (hereinafter, the “Executive
Order”). The children who have been separated from their parents or adult guardians by the
federal government after entry into the United States will be referred to in this document as
“Separated Children,” and the parents or adult guardians of those children will be referred to as
“Parents/Guardians of Separated Children.” The time frame for this request is January 20, 2017
to the present, unless otherwise indicated.
These records include, but are not limited to:
1.

4

Any records, including but not limited to reports, memoranda, guidance, analyses, policies
or procedures, or communications, relating to the development, adoption, implementation,
or monitoring of the “Zero-Tolerance Policy,” including but not limited to:
a.

Any memoranda, guidance, guidelines, instructions, directives, or communications
sent to or received from the Attorney General’s office, the Deputy Attorney
General’s office, United States Attorneys’ offices, CBP, ICE, or USCIS, including
but not limited to CBP, ICE and USCIS field officers, regarding the implementation
of the policy;

b.

Any communications between the Attorney General’s office or the Deputy
Attorney General’s office and United States Attorneys’ offices relating to the
policy;

c.

Any communications between the Attorney General’s office, the Deputy Attorney
General’s Office or the DOJ Civil Division and the White House relating to the
policy;

d.

Any records related to or referring to any purported deterrent effect of the policy;

e.

Any records relating to the effect or expected effect of the policy on the number of
people in immigration detention;

f.

Any records relating to or referring to the number of children who have been
separated from their parents/adult guardians;

See Attorney General Announces Zero-Tolerance Policy for Criminal Illegal Entry, Apr. 6, 2018,
https://www.justice.gov/opa/pr/attorney-general-announces-zero-tolerance-policy-criminalillegal-entry.

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June 25, 2018
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g.

Any records relating to or referring to any policy and/or practice of identifying
and/or tracking children who have been separated from their parents or adult
guardians;

h.

Any records relating to or referring to any policy and/or practice of housing and/or
detaining children who have been separated from their parents or adult guardians;

i.

Any records relating to or referring to any policy and/or practice concerning the
conditions of the housing and/or detention of children who have been separated
from their parents or adult guardians;

j.

Any records relating to the effect or expected effect of the policy on the number of
people being apprehended at the border;

k.

Any records relating to the effect or expect effect of the policy on the number of
people attempting to enter the United States, either at a port of entry or outside a
port of entry;

l.

Any records relating to the effect or expected effect of the policy on children and
their parents or adult guardians being separated after entry into the United States;

m.

Any records relating to the effect or expected effect of the policy on the health
(physical, emotional, mental, or otherwise) of children who are separated from their
parents/adult guardians;

n.

Any records relating to the effect or expected effect of the policy on the health
(physical, emotional, mental, or otherwise) of parents/or adult guardians who are
separated from their children;

o.

Any records relating to the effect or expected effect of the policy on convictions or
plea agreements;

p.

Any records relating to the effect or expected effect of the policy on the average
length of detention of people in immigration detention;

q.

Any records relating to the legality of the policy;

r.

Any records relating to the number of individuals who have been criminally
prosecuted on or after 04/06/2018 under 8 U.S.C. § 1325 or 8 U.S.C. § 1326,
including a breakdown of the charge/s and the amount of time each person has spent
in immigration detention;

s.

Any records relating to the number of individuals seeking asylum at the border who
have been criminally prosecuted as of January 1, 2018;

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June 25, 2018
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2.

t.

Any records relating to the effect of the zero-tolerance policy on the treatment of
individuals seeking asylum at the border;

u.

Any records relating to guidance, training, or other materials regarding the
implementation of the policy.

Any records, including but not limited to reports, memoranda, analyses, or
communications, relating to the development, adoption, implementation, or monitoring of
the Separation of Families Policy/Practice, including but not limited to:
a.

Any memoranda, guidance, or communications sent to or received from the
Attorney General’s office, the Deputy Attorney General’s office, United States
Attorneys’ offices, CBP, ICE, or USCIS, including but not limited to CBP, ICE and
USCIS field officers, regarding the implementation of the policy/practice;

b.

Any communications between the Attorney General’s office or the Deputy
Attorney General’s office and United States Attorneys’ offices relating to the
policy/practice;

c.

Any communications between the Attorney General’s office, the Deputy Attorney
General’s office or the DOJ Civil Division and the White House relating to the
policy/practice;

d.

Any records related to or referring to any purported deterrent effect of the
policy/practice;

e.

Any records relating to the effect or expected effect of the policy/practice on the
number of children in immigration detention;

f.

Any records relating to the effect or expected effect of the policy/practice on the
number of Separated Children;

g.

Any records relating to the effect or expected effect of the policy on the health
(physical, emotional, mental, or otherwise) of children who are housed in
immigration detention;

h.

Any records relating to the number of children who have been separated from their
parents or adult guardians;

i.

Any records relating to the number of parents or adult guardians who have been
separated from their children;

j.

Any records relating to guidance, training, or other materials regarding the
implementation of the policy;

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June 25, 2018
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k.

Any notes, memoranda, reports, or analyses relating to a February 2, 2017 town
hall for USCIS asylum officers;

l.

Any memoranda relating to efforts to deter immigration to the United States,
including but not limited to memoranda drafted in preparation for or resulting from
an August 2017 meeting with Gene Hamilton; 5

m.

Any records reflecting the results of the “pilot program” conducted in the Rio
Grande Valley during 2017 relating to the zero-tolerance prosecutions for illegal
entry and separation of children from their parents or adult guardians;

n.

Any records related to or referring to the legality, lawfulness, or perceived legal
infirmities of the separation of families, including the separation of children from
adult guardians;

3.

A list of all the facilities where Separated Children are presently being held by DHS, HHS,
DOD, or other federal entities, including the facility name, location, capacity, and a list of
the number of Separated Children held at each facility broken down by age and by
nationality. We also request the name, title, and contact information of the individual in
charge of each facility, as well as a list of the number of staff expected to be present at each
facility.

4.

Any records, including but not limited to reports, memoranda, analyses, or
communications, relating to the facilities where Separated Children are presently being
held, or where it is anticipated that they will be held in the future, including but not limited
to:

5

a.

Any records relating to the plans for housing or detaining Separated Children;

b.

Any records relating to the roles of staff present at each facility and the descriptions
of their roles as they relate to caring for the Separated Children;

c.

Any records relating to overcrowding, unsafe, or unhygienic conditions in facilities
where Separated Children are presently being held or where it is anticipated they
will be held in the future;

See Jonathan Blitzer, How the Trump Administration Got Comfortable Separating Immigration
Kids From Their Parents, May 30, 2018 https://www.newyorker.com/news/news-desk/how-thetrump-administration-got-comfortable-separating-immigrant-kids-from-their-parents.

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June 25, 2018
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d.

Any records relating to the adequacy of the facilities to be used for detaining
children;

e.

Any records, guidance, or training materials relating to the services and/or care to
be provided to the separated children, including medical, educational, and other
services needed for child development;

f.

Any records, guidance, or training materials relating to the services, supervision,
attention and/or care to be provided to separated children based on the child’s age
and specific needs;

g.

Any records relating to known incidents of physical or sexual abuse in any of the
facilities where Separated Children are being held.

h.

Any records relating to forced administration to Separated Children of psychotropic
medication

5.

A list of the locations where Parents/Guardians of Separated Children are presently being
held by DHS, HHS, DOD, DOJ, or any other federal entity, including the facility name,
capacity, and location. We also request the name, title, and contact information of the
individual in charge of each facility.

6.

A list cross-referencing the facility where a Separated Child is held and the facility where
that child’s parent or adult guardian is held.

7.

Any records, including but not limited to reports, memoranda, analyses, trainings, policies
or procedures, or communications, relating to DHS, HHS, or any other federal entity’s
systems for tracking the identity and/or location of the parent or adult guardian of Separated
Children.

8.

Any records relating to HHS’s unaccompanied children reunification task force, including
communications between the HHS Assistant Secretary of Preparedness and Response and
the ACF Office of Refugee Resettlement, including but not limited to:
a.

Any records related to the expected timing of reunification of Separated Children
and Parents/Guardians of Separated Children

b.

Any records related to the system for tracking the reunification of Separated
Children and Parents/Guardians of Separated Children

c.

Any records relating to the level of personnel and/or resources being devoted to
reunification of Separated Children and Parents/Guardians of Separated Children

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9.

10.

Any information, guidance, training, or other materials that the government has provided
to staff at facilities where Separated Children or Parents/Guardians of Separated Children
are being held concerning:
a.

Providing Separated Children and Parents/Guardians of Separated Children with an
advisal of their rights;

b.

Providing age-appropriate care;

c.

Providing medical or educational services appropriate for child development;

d.

Prohibiting physical contact between family members;

e.

Ensuring adequate tracking of Separated Children and their parents/adult
guardians;

f.

Preventing coercion of children or adults.

Any records, including but not limited to reports, memoranda, analyses, or
communications, relating to the development, adoption, implementation, or monitoring of
the implementation of the Executive Order, including but not limited to:
a.

Any records related to the limitation in Section 2 that “alien family” means only a
“legal parent-child relationship”;

b.

Any records related to the drafting, interpretation, or implementation of Section
3(b), including under what circumstances an alien family will not be detained
together because of a “concern that detention of an alien child with the child’s alien
parent would pose a risk to the child’s welfare”;

c.

Any records related to the drafting, interpretation, or implementation of Section
3(c), including a list of the “existing facilities available for the housing and care of
alien families.” We also request the name, title, and contact information of the
individual in charge of each facility;

d.

Any records related to the drafting, interpretation, or implementation of Section
3(d), including under what circumstances “[h]eads of executive departments and
agencies” are required to make facilities “available to the Secretary, for the housing
and care of alien families”;

e.

Any records related to the drafting, interpretation, or implementation of Section 4,
including how the Attorney General intends to “prioritize the adjudication of cases
involving detained families”;

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June 25, 2018
Page 10

11.

12.

f.

Any records related to the effect of the Executive Order on the approximately 2,300
children who were separated from their parents/adult guardians by the federal
government prior to issuance of the June 20, 2018 executive order;

g.

Any records relating to the procedures to be taken to reunite the 2,300 children who
were separated from their parents/adult guardians;

h.

Any records, including memoranda, analyses, or communications, created by or
received by OLC, OSG, or DOJ relating to the legality or interpretation of the June
20, 2018 Executive Order;

i.

Any records reflecting how the Executive Order will be implemented if the Court does not
modify the Settlement Agreement in Flores v. Sessions, CV 85-4544, including but
not limited to whether children will be separated from their parents or adult
guardians if the children can no longer legally be detained.

Any records regarding the Settlement Agreement in Flores v. Sessions, CV 85-4544
(“Flores settlement”), including but not limited to:
a.

Any records related to the drafting, interpretation, or implementation of Section
4(e) of the Executive Order;

b.

Any records related to the effect or perceived effect of the Flores settlement on the
Zero-Tolerance Policy and/or Separation of Families Policy/Practice;

c.

Any records or communications relating to the effect or perceived effect of the
Flores settlement on the drafting of the Executive Order;

Any communications relating to or referring to the separation of children from their parents
or adult guardians by the federal government after entry into the United States sent to or
received from any of the following individuals or organizations:
a.

John Kelly; Claire M. Grady; Chad Wolf; Katharine Gorka; Thomas Homan; Peter
Edge; Thomas Blank; Matthew Albence; James McAment; Tracy Renaud; Daniel
Renaud; Kevin McAleenan; Ronald Vitiello; Jeff Sessions; Stephen Miller; Jon
Feere; Julie Kircher; Brandon Judd; Brent Bombach; Ben Cassidy; Kevin
Chmielewski; Tiffany Cissna; Daniel Cox; Thomas Dinanno; Mario Flores; Gene
Hamilton; Harold Hanson; Matt Hayden; Jonathan Hoffman; Roman Jankowski;
Elizabeth Johnson; James Johnson; Quinn Jones O'Brien; Julie Kirchner; Kathy
Nuebel Kovarik; Scott Krause; David Lapan; Cora Mandy; Michael McKeown;
Alan Metzler; Jayne Neumann; Emily Newman; Kirstjen Nielsen; Lora Ries;
Dimple Shah; Tracy Short; Craig Symons; Thomas Szold; Kaitlin Vogt; Erin
Waters; Frank Wuco; Kris Kobach; James Mattis; Kenneth Wolfe; Noel Francisco;

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June 25, 2018
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Jeffrey Wall; Edwin Kneedler; Zack Tripp; Allon Kedem; August Flentje; Sharon
Swingle; William Peachey; Colin Kisor; Jeffrey Robins; Sarah Fabian; Chad
Readler; the National ICE Council; the Center for Immigration Studies; the
National Border Patrol Council; the National CIS Council; or the Federation for
American Immigration Reform.
13.

Any records relating to or referring to the Separation of Families Policy/Practice sent to or
received from any member of Congress, Congressional committee, or Congressional staff,
and any records created in preparation for or support of a communication with a member
of Congress, Congressional committee, or Congressional staff.

14.

Any records relating to or referring to the Separation of Families Policy/Practice sent to or
received from any governor of a United States state or territory, gubernatorial staff, or
association of governors or state officials (e.g. the National Governors Association,
National Conference of State Legislatures), and any records created in preparation for or
support of such communication.

15.

Any records relating to or referring to the Separation of Families Policy/Practice sent to or
received from any state Attorney Generals, and any records created in preparation for or
support of such communication.

16.

Any records relating to the standards or procedures for prosecuting illegal entry under 8
U.S.C. § 1325(a), including but not limited to:

17.

a.

Any proposed or actual changes to policies, procedures, or practices for seeking
pretrial detention; and

b.

Any training, guidance, or other communications regarding prosecutions under 8
U.S.C. § 1325(a);

c.

Any records reflecting plans to ensure that prosecutions under 8 U.S.C. § 1325(a)
comply with due process;

A list of all search terms used and databases accessed to respond to this FOIA request.

FEE WAIVER
NILC requests a waiver of all costs pursuant to the public interest/benefit fee waiver established
by 5 U.S.C. § 552(a)(4)(A)(iii) (“Documents shall be furnished without any charge . . . if
disclosure of the information is in the public interest because it is likely to contribute significantly
to public understanding of the operations or activities of the government and is not primarily in
the commercial interest of the Requestor.”). The public interest/benefit fee waiver provisions of
the FOIA are to be “liberally construed” and are “consistently associated with requests from

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June 25, 2018
Page 12
journalists, scholars, and non-profit interest groups who it was intended to benefit.” See Judicial
Watch, Inc. v. Rossotti, 326 F.3d 1309, 1312 (D.C. Cir. 2003) (“Congress amended FOIA to
ensure that it be ‘liberally construed in favor of fee waivers for FOIA noncommercial
requestors.’”) (citation omitted); see also Carney v. U.S. Dept. of Justice, 19 F.3d 807, 814 (2d
Cir. 1994) (reversing a fee waiver denial that was based on an “unduly restrictive construction
[of] the public interest fee waiver provision”).
NILC is a nonprofit national legal advocacy organization that engages in policy analysis,
advocacy, education, and litigation to promote and advance the rights of low-income immigrants
and their families. NILC serves as an important resource to a broad range of immigrant advocacy
groups, community organizations, legal service organizations, and the general public. As part of
its work, NILC disseminates information to the public through electronic newsletters, news alerts,
issue briefs, trainings, and other educational and informational materials. In addition, NILC
disseminates information to individuals, tax-exempt organizations, not-for-profit groups, and
members through its website (http://www.nilc.org). NILC’s website receives approximately
4,100 visits per day, and many visitors actively download NILC’s reports, brochures, and fact
sheets. NILC’s email listserv has about 70,000 subscribers. NILC’s Twitter account has over
51,000 followers.
The records requested are not sought for commercial use, and the Requestor plans to disseminate
the disclosed information to the public at no cost. See 6 C.F.R. § 5.11(k); 28 C.F.R. § 16.10(k).
Disclosure of the requested records is likely to contribute significantly to public understanding
of the separation of children and families. The requested information is of great interest to the
public at large, but it is not available in the public domain.
In the alternative, we request a limitation of processing fees pursuant to 5 U.S.C.
§ 552(a)(4)(A)(ii)(II). (“[F]ees shall be limited to reasonable standard charges for document
duplication when records are not sought for commercial use and the request is made by ... a
representative of the news media.”). See also 6 C.F.R. § 5.11(d); 28 C.F.R. § 16.10(d). If the fee
waiver request is denied, while reserving our right to appeal the denial, the Requestor agrees to
pay fees up to $50. If fees are estimated to exceed this limit, please inform us to obtain consent
to incur additional fees.
EXPEDITED PROCESSING
Expedited processing is warranted because there is “an urgency to inform the public about an
actual or alleged federal government activity” by organizations “primarily engaged in
disseminating information.” 5 U.S.C. § 552(a)(6)(E)(v)(II). The harm caused by the separation
of children and families threatens “the loss of substantial due process rights.” 6 C.F.R. §
5.5(e)(1)(iii); 28 C.F.R. § 16.5(e)(1)(iii). Moreover, the separation of families has been “[a]
matter of widespread and exceptional media interest in which there exist possible questions about

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June 25, 2018
Page 13
the government's integrity that affect public confidence.” 6 C.F.R. § 5.5(e)(1)(iv); 28 C.F.R. §
16.5(e)(1)(iv). Should you determine that expedited processing is not warranted, the Requestor
reserves the right to appeal that decision and expects a response within the twenty-day time limit
set forth under 5 U.S.C. § 552(a)(6)(A)(ii).
Disclosure of information regarding the separation of families is particularly urgent given the
ongoing trauma that children who have been separated from their families are suffering. Further,
questions about the rationales and consequences of the separation of families sow
misunderstanding, fear, panic, and distrust in the community.
If this Request is denied in whole or in part, please provide a written explanation for that denial,
including references to the specific supporting statutory provisions. To the extent that any
requested records are redacted, please redact only the necessary portions and immediately provide
us with the remaining portions. If any records, or portions thereof are withheld, please state the
exemption claimed and provide a list of the records being withheld.
Finally, without waiving any other appeal rights, the Requestor reserves the right to appeal a
constructive denial of this Request as well as decisions to deny expedited processing, to withhold
any information, to deny a waiver of fees, or to deny a limitation of processing fees. NILC also
reserves the right to challenge the adequacy of the search for responsive documents, the
withholding of any documents, as well as any redactions in the materials produced in response to
this Request.
I certify that the information contained in this request is true and correct to the best of
my knowledge. See 6 C.F.R. § 5.5(e)(3); 28 C.F.R. § 16.5(e)(3).

/s Nora A. Preciado
Nora A. Preciado
Senior Staff Attorney
NATIONAL IMMIGRATION LAW CENTER
3450 Wilshire Blvd. #108 – 62
Los Angeles, CA 90010
preciado@nilc.org