Case 2:17-cv-00094-RAJ Document 107 Filed 02/06/18 Page 1 of 8

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The Honorable Richard A. Jones

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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ABDIQAFAR WAGAFE, et al.,
Plaintiffs,

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v.

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UNITED STATES CITIZENSHIP AND

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IMMIGRATION SERVICES, et al.,

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Defendants.

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No. 2:17-cv-00094-JCC
DEFENDANTS’ STATEMENT ON
COURT’S ORDER ON LCR 37
SUBMISSION REGARDING
REQUESTS FOR PRODUCTION
NOS. 23 & 24

Defendants respectfully submit this statement pursuant to the Court’s February 1,

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2018 Order setting a hearing on the Court’s January 10, 2018 Order, ECF No. 104. 1

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The dispute now before the Court arises from the Court’s order directing the

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parties “to discuss search terms and other means of review, as well as alternative

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custodians and non-custodial sources, if necessary, that Defendants will use to search for

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relevant documents” responsive to Plaintiffs Requests for Production (“RFP”) Numbers

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23 and 24. ECF No. 104, at 4, 5. The parties met and conferred twice (January 26 and 31,

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2018), and have exchanged correspondence between those dates. Should the Court find it

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helpful, a detailed list of the agreed upon and disputed search terms, custodians, date

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ranges, and non-custodial sources is attached hereto as Exhibit 1.

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Although the parties agree on a large number of search parameters, they disagree
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On February 1, 2018, Plaintiffs informed Defendants that Plaintiffs “decided to file [their] own
submission” without discussion as to whether the parties could reach agreement on a joint briefing.

STATEMENT ON COURT’S ORDER ON LCR 37 SUBMISSION - 1
(2:17-cv-00094-RAJ)

UNITED STATES DEPARTMENT OF JUSTICE
Civil Division, Office of Immigration Litigation
District Court Section
Ben Franklin Station, P O Box 868
Washington, DC 20044
(202) 532-4542

 Case 2:17-cv-00094-RAJ Document 107 Filed 02/06/18 Page 2 of 8

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about certain additional search terms, custodians, and non-custodial sources, 2 as well as

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whether Defendants have an obligation to search President-Elect Transition Team

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(“PETT”) materials and U.S. Immigration and Customs Enforcement (“ICE”) records. 3

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President-Elect Transition Team Materials: For the first time on January 31,

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2018, Plaintiffs asked Defendants to search president-elect transition team materials not

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on Department of Homeland Security (“DHS”) information systems. Although

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Defendants had agreed to search the e-mail of the “DHS beachhead team” assigned to

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USCIS, who later assumed federal government positions, Defendants did not agree to

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search materials in the legal control of the PETT, and could not so agree as such

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materials are not federal government records. Now, even though Defendants are

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searching the records of high-level political appointees housed on DHS systems, such as

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former Secretary Kelly and current Secretary Nielsen, Plaintiffs seek non-government

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PETT materials located on a server “hosted by GSA(or some other agency), another

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government/military address, or something else.” D. A. Perez e-mail to E.S. White (Feb.

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5, 2018).
PETT materials are not within the legal control of Defendants. In this Circuit,

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“[c]ontrol is defined as the legal right to obtain documents upon demand.” 7-UP Bottling

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Co. v. Archer Daniels Midland Co. (In re Citric Acid Litig.), 191 F.3d 1090, 1107 (9th

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Cir. 1999) (quotations omitted). “The materials that [PETT] members create or receive

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are not federal or presidential records, but are considered private materials.” L. Brewer,

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MEMO. TO FED. AGENCY RECORDS OFFICERS: GUIDANCE RELATING TO PRESIDENTIAL

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TRANSITION TEAM MATERIALS (available at www.archives.gov/records-mgmt/memos/

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ac09-2017). Mr. Brewer is the Chief Records Officer for the U.S. Government. Id.

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Although Defendants have agreed to certain search parameters in light of the Court’s prior rulings,
Defendants maintain and preserve all objections.

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Plaintiffs may seek to raise other issues, but have not informed Defendants of precisely what those
issues might be. Despite a request for such information, Plaintiffs declined to provide specifics,
indicating only that they “intend to advise the court about the status of discovery . . . and the status of
other issues on which the Court ordered compliance in its October 19 Order.” D.A. Perez e-mail to E.S.
White (Feb. 2, 2018).

STATEMENT ON COURT’S ORDER ON LCR 37 SUBMISSION - 2
(2:17-cv-00094-RAJ)

UNITED STATES DEPARTMENT OF JUSTICE
Civil Division, Office of Immigration Litigation
District Court Section
Ben Franklin Station, P O Box 868
Washington, DC 20044
(202) 532-4542

 Case 2:17-cv-00094-RAJ Document 107 Filed 02/06/18 Page 3 of 8

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Additionally, pursuant to the Transition Act, Pub. L. 88-277, 78 Stat. 153 (Mar. 7,

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1964) (codified, as amended, at 3 U.S.C. § 102 note), “[t]he transition staff . . . is outside

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of the executive branch.” Illinois Inst. for Continuing Legal Educ. v. U.S. Dep’t of Labor,

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545 F. Supp. 1229, 1232–33 (N.D. Ill. 1982) (presidential transition report stored by

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Labor Secretary in his Department office not “agency record” under FOIA). See also

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Kissinger v. Reporters Comm. for Freedom of the Press, 445 U.S. 136, 157 (1980) (notes

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Kissinger took while National Security Advisor and brought to State Department not

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subject to State Department control); Wolfe v. Dep’t of Health & Human Svcs., 711 F.2d

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1077, 1082 (D.C. Cir. 1983) (transition report simply stored in HHS employee’s office

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not “agency record”). Finally, given the recent notice, Defendants have not yet had the

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opportunity to complete an inquiry into this issue. 4

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ICE Records: Plaintiffs have demanded that Defendants search DHS sub-

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components, explicitly identifying ICE, for documents responsive to their RFPs. Such

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discovery is beyond the scope of Federal Rule of Civil Procedure 26(b), because (1) ICE

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is not a party, and (2) as ICE does not adjudicate immigration benefit applications, the

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materials sought are irrelevant to the claims and defenses. Further, such discovery would

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be disproportionate.

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ICE is not a party, and therefore Plaintiffs may not use discovery tools, such as

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requests for production, that may only be directed to parties. FED. R. CIV. P. 34(a).

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Although ICE is a DHS subcomponent, Plaintiffs did not name it as a party, and in

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describing then-Secretary Kelly in the Second Amended Complaint, stated he “has

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supervisory responsibility over USCIS”; they did not invoke his supervisory authority

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over ICE. ECF No. 47 at ¶ 31. Further, Plaintiffs described their case as “seek[ing] to

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stop the federal government from unconstitutionally preventing Plaintiffs, and others like

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them, from obtaining immigration benefits.” Id. at ¶ 1 (emphasis added). Notably,

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Plaintiffs named fellow subcomponent USCIS as a party.

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To the extent the Court has remaining questions regarding whether PETT records are discoverable from
Defendants, Defendants respectfully submit the Court should order further briefing, providing sufficient
time for further inquiry.

STATEMENT ON COURT’S ORDER ON LCR 37 SUBMISSION - 3
(2:17-cv-00094-RAJ)

UNITED STATES DEPARTMENT OF JUSTICE
Civil Division, Office of Immigration Litigation
District Court Section
Ben Franklin Station, P O Box 868
Washington, DC 20044
(202) 532-4542

 Case 2:17-cv-00094-RAJ Document 107 Filed 02/06/18 Page 4 of 8

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ICE does not adjudicate immigration benefit applications. Rather, it is tasked with

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immigration enforcement functions. See 6 U.S.C. § 251; cf. 6 U.S.C. § 271(b) (transferring

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immigration benefit application adjudication to USCIS). In addition, ICE has no role in

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CARRP, other than that of a law enforcement agency that USCIS interacts with in carrying

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out its own assigned duties. Further, searching ICE for responsive documents would be

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disproportionate in this case. To the extent ICE has materials relevant to immigration benefit

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adjudication, there is no reason to think those records would not also be found at USCIS, the

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agency responsible for adjudicating such applications. To the extent Plaintiffs seek records

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not related to the adjudication of immigration benefit applications, their requests are not

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relevant to the claims and defenses in this case.

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Search and Collection Methodology: Defendants’ search and collection

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methodology as proposed to Plaintiffs amounts to a reasonable inquiry to locate documents

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potentially responsive to RFP Nos. 23 and 24. See FED. R. CIV. P. 26(g) (requiring a

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reasonable inquiry occur before certifying a discovery response). After consultation with the

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agencies, Defendants have proposed searching the e-mails of the DHS and USCIS officials

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most likely to hold responsive documents, applying search terms that are tailored to return

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the documents sought and collecting documents from non-custodial sources that are most

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likely to hold responsive documents. Defendants have been open and cooperative with

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Plaintiffs on attempting to reach consensus on search terms, custodians, non-custodial

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sources, and date ranges. In an effort to resolve disputes without court intervention,

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Defendants agreed to additional custodians, additional search terms, and broader date ranges

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than they consider necessary to locate responsive materials. But this cooperation does not

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discount the need for balance and proportionality required under Federal Rules of Civil

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Procedure 26(b)(1) and (b)(2)(C). See Salazar v. McDonald’s Corp., No. 14-cv-02096, 2016

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U.S. Dist. LEXIS 23293, *6, 7 (N.D. Cal. Feb. 5, 2016) (“the revised rule places a shared

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responsibility on all the parties to consider the factors bearing on proportionality before

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propounding discovery requests, issuing responses and objections, or raising discovery

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disputes before the courts”); see also Hon. Elizabeth C. Laporte & Jonathan M. Redgrave, A
STATEMENT ON COURT’S ORDER ON LCR 37 SUBMISSION - 4
(2:17-cv-00094-RAJ)

UNITED STATES DEPARTMENT OF JUSTICE
Civil Division, Office of Immigration Litigation
District Court Section
Ben Franklin Station, P O Box 868
Washington, DC 20044
(202) 532-4542

 Case 2:17-cv-00094-RAJ Document 107 Filed 02/06/18 Page 5 of 8

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Practical Guide to Achieving Proportionality Under New Federal Rule of Civil Procedure

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26, 9 Fed. Cts. L. Rev. 19, 64 (2015) (“transparency should not be morphed into an

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opportunity for unending questions and fishing expeditions”).

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For RFP No. 23, Defendants have agreed to search the e-mails of 16 custodians,

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including the then-Secretary of Homeland of Security and the then-Director of USCIS

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and their immediate subordinates, and to use the search terms “Controlled Application

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Review and Resolution Program,” “CARRP,” and “Articulable Link” (a term unique to

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the CARRP). Defendants’ proposed methodology focused on the specific language of the

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RFP, which seeks documents that discuss the specific consideration of the Controlled

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Application Review and Resolution Program (“CARRP”) in the drafting of Executive

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Orders 13769 and 13780. See ECF No. 92, Ex. A; ECF No. 104, at 4 (finding RFP No. 23

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was targeted to seek “documents specifically related to CARRP”). Plaintiffs insist,

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however, on 12 additional search terms, all of which are not exclusively used to refer to

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the CARRP. See W.D. Wash. Model ESI Agreement (noting that “focused terms and

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queries should be employed; broad terms or queries . . . generally should be avoided”).

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For RFP No. 24, Defendants have agreed to search the e-mails of 17 DHS and USCIS

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custodians, including those who are either responsible for the oversight of USCIS actions or

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responsible to track DHS and DHS component actions related to the programs, policies, or

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procedures implemented pursuant to section 4 of E.O. 13769 and sections 4 and 5 of E.O.

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13780, as well as to collect documents from 8 non-custodial sources. Defendants have

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agreed to use 11 search terms that relate or refer to implementation of sections 4 of E.O.

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13769 and sections 4 and 5 of E.O. 13780. Plaintiffs insist, however, on an additional 16

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custodians—senior leaders who would likely only hold responsive communications between

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themselves and Defendants’ proposed custodians. A search of the senior leaders’ e-mails is

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not proportional to the needs of the case, see FED. R. CIV. P. 26(b)(2)(C)(i) (the court should

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limit the frequency or extent of discovery . . . if it determines that the discovery sought is

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unreasonably cumulative or duplicative”), and the burden of including them as custodians

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outweighs any likely benefit. See FED. R. CIV. P. 26(b)(1).
STATEMENT ON COURT’S ORDER ON LCR 37 SUBMISSION - 5
(2:17-cv-00094-RAJ)

UNITED STATES DEPARTMENT OF JUSTICE
Civil Division, Office of Immigration Litigation
District Court Section
Ben Franklin Station, P O Box 868
Washington, DC 20044
(202) 532-4542

 Case 2:17-cv-00094-RAJ Document 107 Filed 02/06/18 Page 6 of 8

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Dated: February 6, 2018

Respectfully submitted,

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CHAD A. READLER
Acting Assistant Attorney General

/s/ Edward S. White
EDWARD S. WHITE
Senior Litigation Counsel,
National Security & Affirmative
Litigation Unit
District Court Section
Office of Immigration Litigation
U.S. Department of Justice
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044-0868
Tel: (202) 616-9131
Fax: (202) 305-7000
Email: edward.s.white@usdoj.gov

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WILLIAM C. PEACHEY
Director, District Court Section
Office of Immigration Litigation

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Timothy M. Belsan
Deputy Chief, National Security
& Affirmative Litigation Unit

AARON R. PETTY
Trial Attorney, National Security
& Affirmative Litigation Unit
JOSEPH F. CARILLI, JR.
Trial Attorney, National Security
& Affirmative Litigation Unit
Counsel for Defendants

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STATEMENT ON COURT’S ORDER ON LCR 37 SUBMISSION - 6
(2:17-cv-00094-RAJ)

UNITED STATES DEPARTMENT OF JUSTICE
Civil Division, Office of Immigration Litigation
District Court Section
Ben Franklin Station, P O Box 868
Washington, DC 20044
(202) 532-4542

 Case 2:17-cv-00094-RAJ Document 107 Filed 02/06/18 Page 7 of 8

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on February 6, 2018, I electronically filed the

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foregoing with the Clerk of the Court using the CM/ECF system, which will send

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notification of such filing to the following CM/ECF participants:

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Harry H. Schneider, Jr., Esq.
Nicholas P. Gellert, Esq.
David A. Perez, Esq.
Kathryn Reddy, Esq.
Perkins Coie L.L.P.
1201 Third Ave., Ste. 4800
Seattle, WA 98101-3099
PH: 359-8000
FX: 359-9000
Email: HSchneider@perkinscoie.com
Email: NGellert@perkinscoie.com
Email: DPerez@perkinscoie.com
Email: KReddy@perkinscoie.com

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Matt Adams, Esq.
Glenda M. Aldana Madrid, Esq.
Northwest Immigrant Rights Project
615 Second Ave., Ste. 400
Seattle, WA 98104
PH: 957-8611
FX: 587-4025
E-mail: matt@nwirp.org
E-mail: glenda@nwirp.org
Emily Chiang, Esq.
ACLU of Washington Foundation
901 Fifth Avenue, Suite 630
Seattle, WA 98164
Telephone: (206) 624-2184
E-mail: Echiang@aclu-wa.org
Jennifer Pasquarella, Esq.
ACLU Foundation of Southern California
1313 W. 8th Street
Los Angeles, CA 90017
Telephone: (213) 977-5211
STATEMENT ON COURT’S ORDER ON LCR 37 SUBMISSION - 7
(2:17-cv-00094-RAJ)

UNITED STATES DEPARTMENT OF JUSTICE
Civil Division, Office of Immigration Litigation
District Court Section
Ben Franklin Station, P O Box 868
Washington, DC 20044
(202) 532-4542

 Case 2:17-cv-00094-RAJ Document 107 Filed 02/06/18 Page 8 of 8

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Facsimile: (213) 997-5297
E-mail: jpasquarella@aclusocal.org
Stacy Tolchin, Esq.
Law Offices of Stacy Tolchin
634 S. Spring St. Suite 500A
Los Angeles, CA 90014
Telephone: (213) 622-7450
Facsimile: (213) 622-7233
E-mail: Stacy@tolchinimmigration.com
Trina Realmuto, Esq.
Kristin Macleod-Ball, Esq.
National Immigration Project of the National Lawyers Guild
14 Beacon St., Suite 602
Boston, MA 02108
Telephone: (617) 227-9727
Facsimile: (617) 227-5495
E-mail: trina@nipnlg.org
E-mail: kristin@nipnlg.org
Hugh Handeyside, Esq.
Lee Gelernt, Esq.
Hina Shamsi, Esq.
American Civil Liberties Union Foundation
125 Broad Street
New York, NY 10004
Telephone: (212) 549-2616
Facsimile: (212) 549-2654
E-mail: lgelernt@aclu.org
E-mail: hhandeyside@aclu.org
E-mail: hshamsi@aclu.org

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/s/ Edward S. White
EDWARD S. WHITE
Senior Litigation Counsel, National Security
& Affirmative Litigation Unit

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STATEMENT ON COURT’S ORDER ON LCR 37 SUBMISSION - 8
(2:17-cv-00094-RAJ)

UNITED STATES DEPARTMENT OF JUSTICE
Civil Division, Office of Immigration Litigation
District Court Section
Ben Franklin Station, P O Box 868
Washington, DC 20044
(202) 532-4542

 Case Document 107-1 Filed 02/06/18 Page 1 of 5

Eh?tl

Custodians (ICE)
Date Range

Custodians (DHS)

Custodians (USCIS)

Search Terms

Item
Search Terms

Description
“CARRP,” “Controlled Application Review and Resolution Program,” “Articulable
Link”
“Deconflict*,” “Known or Suspected Terrorist,” “KST,” “National Security
Concern,” “National Security Indicator,” “Non National Security,” “Non-Known or
Suspected Terrorist,” “Non-KST,” “NS Activities,” “NS Concern,” “NS Hit,” “NS
Indicator”
Lori Scialabba (Acting Director); Tracy Renaud (Acting Deputy Director); Molly
Groom (Acting Chief Counsel); Larry Levine (Acting Policy Director); Craig
Symons, Carl Risch, and Kathy Neubel Kovarik (DHS transition beachhead team);
Daniel M. Renaud (Associate Director of Field Operations); Donald Neufeld
(Associate Director of Service Center Operations); Matthew D. Emrich (Associate
Director of the Fraud Detection and National Security Directorate)
John Kelly (Secretary); Elaine Duke (Acting Secretary and Deputy Secretary);
Kirstjen Nielsen (Secretary and Chief of Staff); Joseph Maher (Acting General
Counsel); Gene Hamilton (Senior Counselor to the Secretary); Chip Fulghum (Acting
Deputy Secretary of Homeland Security)
Thomas Homan (Acting Director); Daniel Ragsdale (Deputy Director)
November 9, 2016 to March 6, 2017

Request for Production Number 23

Case 2:17-cv-00094-RAJ Document 107-1 Filed 02/06/18 Page 2 of 5

Disputed
Agreed

Agreed

Agreed

Disputed

Agreed / Disputed
Agreed

 Search Terms
Custodians (USCIS)

Search Terms

Search Terms

Search Terms

Item
Search Terms

Description
“13769,” “13780,” “Continuous Immigration Vetting,” “Extreme Vetting,”
“Interview Expansion,” “Interview Waiver,” “Recurrent Vetting,” “Section 4,”
“Section 5,” “Uniform Screening,” “Uniform Vetting”
(“Protecting the Nation” OR “Foreign Terrorist Entry” OR “Executive Order” OR
“EO”) AND (screen* OR vet* OR adjudicate* OR “national security” OR suspend*)
“Wicklander” and “Enhanced Communication Course” to custodian Julie Spencer
(Branch Chief of Field Operations Training Division)
“Code 5,” “ASC” AND “Identity Verification,” “Livescan” AND “Identity
Verification” to custodian Lee Bowes (Acting Deputy Associate Director,
Immigration Records and Identity Services)
“Application Support Center” AND “Identity Verification”
Julie Farnam (Chief, Case Analysis Branch, Fraud Detection and National Security
Directorate, formerly detailed to the USCIS Acting Director’s Office as a Senior
Advisor); Vania Lockett (Special Assistant, Front Office, Fraud Detection and
National Security Directorate); Teresa Downey (Chief, Screening Coordination
Office, Fraud Detection and National Security Directorate); Christopher Heffron
(Immigration Officer, Program Management Office, Field Operations Directorate,
formerly Chief, Screening Coordination Office, Fraud Detection and National
Security Directorate); Brett Rinehart (Chief, Program Management Office, Field
Operations Directorate); Julie Spencer (Chief, Training Division, Field Operations
Directorate); Brandi Blackburn (Assistant Center Director, National Benefit Center,
Field Operations Directorate); Linda Dougherty (Chief, Adjustment and
Naturalization Team, Service Center Operations); Albert Davis (Chief, Program
Management Office, Fraud Detection and National Security Directorate); Lee Bowes
(Acting Deputy Associate Director, Immigration Records and Identity Services)

Request for Production Number 24

Case 2:17-cv-00094-RAJ Document 107-1 Filed 02/06/18 Page 3 of 5

Disputed
Agreed

Disputed

Disputed

Disputed

Agreed / Disputed
Agreed

 Custodians (ICE)
Non-custodial
Sources (USCIS)

Custodians (DHS)

Custodians (DHS)

Item
Custodians (USCIS)

Description
Lori Scialabba (Acting Director); Tracy Renaud (Acting Deputy Director); Molly
Groom (Acting Chief Counsel); Larry Levine (Acting Policy Director); Craig
Symons, Carl Risch, and Kathy Neubel Kovarik (DHS transition beachhead team);
Daniel M. Renaud (Associate Director of Field Operations); Donald Neufeld
(Associate Director of Service Center Operations); Matthew D. Emrich (Associate
Director of the Fraud Detection and National Security Directorate)
Olivia Troye (Chief, Strategy, Policy, and Plans, Office of Intelligence and Analysis);
Teresa Downey (Advisor, Office of Intelligence and Analysis); Frank Wuco
(Executive Director, Executive Order Task Force); John Latta (Director, Screening
Coordination Office, Office of Policy); Victoria Lester-Saura (Acting Principal
Director, Screening Coordination Office, Office of Policy); Michael Scardaville
(Principal Director and Senior Advisor, Information Sharing, Office of Policy);
Briana Petyo (Chief Of Staff, Office of Policy); John Dermody (Attorney Advisor,
Office of the General Counsel)
John Kelly (Secretary); Elaine Duke (Acting Secretary and Deputy Secretary);
Kirstjen Nielsen (Secretary and Chief of Staff); Joseph Maher (Acting General
Counsel); Gene Hamilton (Senior Counselor to the Secretary); Chip Fulghum (Acting
Deputy Secretary of Homeland Security)
Thomas Homan (Acting Director); Daniel Ragsdale (Deputy Director)
USCIS Field Operations Directorate ECN sites relevant to Continuous Immigration
Vetting and Expanded Interview efforts; USCIS Fraud Detection and National
Security Directorate ECN sites relevant to Continuous Immigration Vetting and
Expanded Interviews; USCIS National Benefits Center ECN sites relevant to
Expanded Interviews; USCIS Field Operations Directorate share drive folders related
to interview training; USCIS Fraud Detection and National Security Directorate share
drive folders related to Continuous Immigration Vetting; USCIS National Benefits
Center share drive folders related to Expanded Interviews; USCIS Immigration
Records and Identity Services Directorate ECN site pages relevant to ASC identity
verification

Case 2:17-cv-00094-RAJ Document 107-1 Filed 02/06/18 Page 4 of 5

Disputed
Agreed

Disputed

Agreed

Agreed / Disputed
Disputed

 Item
Non-custodial
Sources (DHS)
Non-custodial
Sources (ICE)
Date Range
Disputed
Agreed

November 9, 2016 to present

Agreed / Disputed
Disputed

Description
Section of DHS Executive Order Task Force SharePoint site related to Section 5 of
E.O. 13780
None named

Case 2:17-cv-00094-RAJ Document 107-1 Filed 02/06/18 Page 5 of 5