U.S. Department of Homeland Security Washington, DC 20528 Homeland Security April 8, 2019 Larry Schwartztol Counsel The Protect Democracy Project 2020 Pennsylvania Avenue, NW #163 Washington, DC 20006 Re: Protect Democracy Project 17-cv-02202 (2017-HQFO-01153/2018-HQLI-00008) 6th Interim Release Dear Mr. Schwartztol: This is the fifth interim response to your August 23, 2017, Freedom of Information Act (FOIA) request to the Department of Homeland Security (DHS) (2017-HQFO-01153). For this month’s production, DHS processed for release 609 pages. Of the 609 pages, 15 pages are released in full, 305 pages are withheld in full pursuant to 5 U.S.C 552(b)(5) and 290 pages were marked as duplicate. The 319 pages that are released to you are bates-numbered DHS-0011153-01799 to DHS-001-1153-02117. Sincerely, Bradley E. White Acting, Director FOIA Litigation Enclosure 1 Page 001 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01799 Page 002 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01800 Page 003 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01801 Page 004 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01802 Page 005 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01803 Page 006 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01804 Page 007 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01805 Page 008 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01806 Page 009 Withheld pursuant to exemption (W5) eftne Freedom of Information and 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Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01845 Page 048 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01846 Page 049 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01847 Page 050 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01848 Page 051 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01849 Page 052 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01850 Page 053 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01851 Page 054 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01852 Page 055 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01853 Page 056 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01854 Page 05? Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01855 Page 058 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01856 Page 059 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01857 Page 060 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01858 Page 061 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01859 Page 062 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01860 Page 063 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01861 Page 064 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01862 Page 065 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01863 Page 066 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01864 Page 06? Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01865 Page 068 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01866 Page 069 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01867 Page 07'0 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01868 Page 07'1 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01869 Page 072 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01870 Page 07'3 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01871 Page 07'4 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01872 Page 07'5 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01873 Page 07'6 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01874 WW CIVIL RIGHTS AND CIVIL LIBERTIES PRINCIPLES FOR DHS INTELLIGENCE PRODUCTS Version 1.0 (September 19, 2014) This guidance articulates a set of general principles to promote the protection of civil rights and civil liberties by the US. Department of Homeland Security (DHS) as DHS personnel craft intelligence products. When Department write or review products, they should apply the principles below. The principles apply not only to the products reviewed or cleared by the Office for Civil Rights and Civil Liberties (CRCL) but to all products, whether produced by the Intelligence Analysis Directorate or a DHS Component, and whether subject to CRCL clearance or not. This includes, for example, products shared only with other 1C partners, classified and unclassified products, and products drafted or promulgated by Components with or without headquarters involvement. The guidance presents eight civil liberties principles, describing each one, identifying areas of particular concern or application, and providing one or more examples of product texts that do not sufficiently respect the principle and how they can be rewritten to solve the problem. For a number of the principles, the examples are followed by a list of ?hot-button? terms that often give rise to concern. These principles are not an exhaustive list of every civil liberties concern that may arise in any given product, but do highlight common issues CRCL has observed. Where and how a civil rights and civil liberties issues may arise, however, is fact specific. should use the principles and the guidance as instructive but not a checklist of concerns. should be careful when crafting any product that may touch on individual liberties or focus on individuals as a result of their race, ethnicity, or religion. In situations where have questions or concerns on how best to approach a topic that may touch on these issues, they should feel free to contact CRCL for specific guidance on crafting their product. 1. The Violence Principle: Generally, reporting should focus on violence or criminality of a particular individual or group in order to avoid First Amendment concerns. 2. The No-Aspersions Principle: Reporting should present analysis of political, religious, or ideological speech or activity neutrally and without negative characterizations. In some cases, reporting on these types of activity may be improper, unless it relates to violence or criminality. 3. The Equality Principle: Reporting should provide a full, objective analysis of a particular threat and should not be based on race, ethnicity, or religion?or appear to be so based. 4. The Due Process Principle: Reporting should separate allegations of crime from determinations of guilt. 5. The Religious Debate Principle: Reporting should avoid taking part in religious debates, by using religious terms that carry multiple meanings or are subject to interpretation). 6. The Guill-By-Asseciutien Principle: Reporting should not implicate many individuals in the bad conduct of an individual or a small number of individuals. 7. The Clurity-Of-Source Principle: Reporting should accurately characterize and separate sources? facts or conclusions from DHS analytic judgments. 8. The Anti-Conveyor Bell Principle: Civil rights issues are not cured by attribution to another agency or source. DHS-001-11153-01875 WW Staff at CRCL are available to any Component or Office across the Department for consultation and training, and Components and Offices are encouraged to send draft products for CRCL feedback to any of the CRCL Product Review mailboxes available on each of the three networks: unclassified (A-LAN), secret or top secrethCI 1. THE VIOLENCE PRINCIPLE: REPORTING SHOULD FOCUS ON VIOLENCEICRMINALITY, TO AVOID FIRST AMENDMENT CONCERNS Generally, reporting should be about the violence or criminality of particular individuals or groups.1 Reporting on activities lacking a nexus to violence or criminal activity2 is generally inappropriate. Reporting on groups or individuals is appropriate where the product expressly and clearly articulates the nexus to violent or other criminal activity. For instance, it may be appropriate to report on an organization that engages in violent or other criminal activities, or on a group that facilitates violence by providing material support to an organization involved in known criminal activities, including a designated Foreign Terrorist Organization. In addition, when assessing the potential for violence or other criminal activity in the future violence that may be planned but has not yet been carried out) by an individual or group, it is appropriate to include examples of past violent or criminal activity. A predictive report should include relevant information to establish a well-supported and reasonable threat of violent or other criminal activity by an individual group, and the report must clearly support the assessment and appropriately characterize the reliability of supporting information. If a product discusses First Amendment protected activity (speech, press, religion, association, and ideology or beliefs), it must expressly state a nexus between the reported protected activity and a violent or other criminal activity or well-supported threat. For instance, include relevant background information to establish the linkage between the individual or group who is the subject of the report and violent or other criminal activity. should avoid analysis or presentation of elements of that activity without the appropriate context g. by describing political, religious, or ideological speech or activity in a footnote or text box that does not also provide the context indicating why the reporting is appropriate). 1 As used in this guidance, the term ?groups" includes organizations of all types private, nonprofit, for pro?t). 2 All references to ?violent or other criminal activity? in this guidance presume investigation of andfor reporting on the activity in question is also within the scope of an appropriate DHS mission. Special issues: 0 Websites: Viewing information contained on a website is generally protected under the First Amendment even if the website promotes (or users of the website promote) criminal or violent activities. Visitors to these websites may be journalists, students, government officials, and the general public conducting legitimate research or browsing. Accordingly, the act of viewing a website is not alone sufficient to justify reporting on any person. Taking additional steps in furtherance of a crime or violent activity that is advocated on a website is, however, not protected and may be the subject of a report. Characterization of a website is also a t0pic of concern. If the entire website is dedicated to the transmission of terrorist information, the term ?terrorist website? may be appropriate. When discussing websites with mixed uses some content addresses non-violent, First-Amendment-protected activities, while other content on the same site advocates violence or criminal activity), focus only on the content facilitating or supporting violence or terrorism; avoid broadly implicating all users of the website in the conduct of a few users. (See the Guilt by Association Principle, below.) 0 Support. Do not state that an individual ?supports? or is a ?supporter" of a terrorist or violent extremist organization or lone offender without explaining the nature and extent of the support. If using the term ?support? in the context of ?material support? as that term is defined in 18 U.S.C. 2339A, consult with the Office of the General Counsel (DOC) to ensure that the conduct described falls within the scope of that statute. I Schools. When a school is within the United States, its educational activities are protected under the First Amendment. A madrassa is a Muslim school, college, or university that may be associated with a mosque. Reporting on activities at a madrassa or other school is appropriate only if credible sources reveal that a particular school may, for example, be indoctrinating its students in violent or criminal teachings. The facts and citations supporting this assertion must be provided in the product. However, there may be situations where it is appropriate to report on individuals or groups that are not directly involved in violent or other criminal activity. These situations may include: 0 Recruitment. It is appropriate to discuss information indicating that a person or group has attempted or is attempting to recruit a specific individual or group to assist them in violent or other criminal activities recruitment of an individual with a background in explosives) as long as the report provides all known information, or identifies information gaps, about the attempted recruitment. Products containing this type of analysis should include a full discussion of the basis for believing an individual or group may be targeted in this manner to make clear that the interest in the individual or group is based on attempts to recruit them for violent or criminal activity, as opposed to monitoring them for non-nefarious (and consequently protected) associations. 0 It is appropriate to report on an individual?s fundraising or recruitment activities only if we can reasonably establish that the individual engaged in these activities with knowledge of and the intent to support the illegal goals3 of the group. 3 This standard is higher than the standard required for conviction for material support to terrorism under 13 USC. 22393 in order to ensure protection of the constitutional rights of those engaged in a wide range of activities mm The propriety of reporting on a group?s recruiting, fundraising, or other First Amendment activities is greatly enhanced if the U.S. government has publically indicated that the organization is connected to terrorism. Even in these situations, the product should contain enough information so that the reader understands the connection. I Targets. Individuals or groups may be targeted as victims or potential victims for violent or other criminal acts. In this case, it is particularly important to characterize those individuals or groups appropriately and avoid reporting on information other than information relevant to their potential status as victims. 0 Witnesses. A product may include information about an individual who has witnessed violent or other criminal acts. As with targets, it is important to accurately characterize these individuals and limit reporting 0 Providing context. Reporting provided for context may also be acceptable, but this type of reporting must be clear and distinct from judgments about violent or other criminal behavior. I Public safety/situational awareness. Reporting provided for ?situational awareness? may also be acceptable even where the individual, group or activity has no nexus to violence or criminality, but only where the reporting is appropriately tailored to provide the information necessary for a specific, appropriate government purpose or mission, and also where distribution is only to those who need that information to accomplish that specific purposeimission. For example, reporting the fact that a non-violent, lawful demonstration (protected activity under the First Amendment) is planned outside a particular federal building at a particular time may be appropriate for the purpose of situational awareness if distributed only to personnel at that building and individuals (such as local FPS personnel andfor the local police department) with public safety jurisdiction over that area. A product shared more broadly on this protected activity g. to other personnel at other federal buildings, or national FPS personnel) or including more information than the minimum necessary for situational awareness of the activity g. an analysis of the ideological leanings of the demonstrating group), is inappropriate. This is not an exhaustive list. are also encouraged to contact CRCL to discuss proposed reporting of this type to help determine whether such a report may be appropriate. protected by the First Amendment right to free association. This policy protection is necessary to ensure appropriate internal DHS scrutiny on reporting of acts that could be viewed as lending unwitting support to terrorist actors or groups. For instance, an individual giving to a charity which, unbeknownst to him supports terrorism. could be treated as material support. Where a product would report or analyze activities that may provide material support to terrorism. and it is not clear what the intent of the activities was, CRCL would work with on a case?by?case basis to ensure propriety under Constitutional and DHS policy standards. DHS-00111115301878 The Violence Principle in Action: Sample Problems and Solutions Problems: Original Texts Solutions: Revised Texts Recruitment Request for Information Concerning Fund-Raising and Recruitment within Libyan, Egyptian, Yemeni, or Tunisian Communities. (UHFOUO) Request for Information Concerning Fund-Raising and Recruitment for Violent, Armed Militant or Revolutionary Groups in Libya, Egypt, Yemen, or Tunisia. Context: Militia members typically adhere to extreme anti-government belief systems that oppose most federal and state laws, regulations, and authority. Many members combine their anti?govemment beliefs with various conspiracy theories. They tout the existence of a despotic ?New World Order? and cite religious apocalyptic/ end times beliefs to suppolt their outlook. Individuals within the movement believe militias are the last line of defense against a federal government they see as increasingly eroding citizens? personal rights, property rights, and the right to own Some members also embrace other extremist ideologies, such as sovereign citizen and white supremacist beliefs. Factional militia extremist cells and lone individuals carry out anti- government attacks under the militia extremist movement?s philosophy of lone offenders and leaderless resistance." Violent militia extremists share the overall militia movement?s adherence to anti-government belief systems that oppose most federal and state laws, regulations, and authority. Violent militia extremists have been known to adopt other anti- government belief systems found in the violent sovereign citizen and white supremacist extremist movements. Some factional militia cells or lone individuals carry out anti-government attacks under the philosophy of leaderless resistance. . .. Violent militia extremists, like many other militia members, combine their anti-government beliefs with various conspiracy theories. . .. Individuals within both the non-violent elements of the militia movement and the more violent extremist minority believe that militias are the last line of defense in protecting the U.S. Constitutional freedoms against a federal government that they see as increasingly eroding citizens? personal rights, property rights, and the right to own firearms. Public Safety 135A does not have any speci?c threat information related to ?International Judge the Koran Day." Nevertheless, we remain concerned that any anticipated or actual destruction of the Quran could result in violence in the Homeland, particularly if the event is widely publicized. High pro?le perceived desecrations of the Quran or depictions of the Prophet Mohammad have resulted in violence worldwide as well as threats against specific targeted individuals. (UJFOUO) does not have any specific threat information related to ?International Judge the Koran Day.? Nevertheless, we remain concerned that any anticipated or actual destruction of the Quran could result in instances of violence as well as threats and attacks on American Muslims and their places of worship, particularly if the event is widely publicized. DHs-oo1-5153-01879 WW Hot-button terms (use suggests that the product should be evaluated for compliance with this principle): ?beliefs,? ?believes,? ?ideas,? ?ideals,? ?ideology,? ?thought? 0 ?speech,? ?expression,? ?message? - ?opposition,? ?support? - ?recruit,? ?recruiting,? ?recruitment? I ?fundraising? 0 ?propaganda? 0 ?website,? ?blog,? ?social networking site? 0 ?madrassa? [variants include madrassah,? ??madrasah?) 2. THE NO-ASPERSIONS PRINCIPLE: DO NOT CAST ASPERSIONS ON RELIGIOUS, IDEOLOGICAL, OR POLITICAL SPEECH OR ACTIVITY, UNLESS IT CROSSES THE LINE INTO VIOLENCE OR OTHER CRIMINAL ACTIVITY. Under the Violence Principle, reporting on political, religious, or ideological speech is often inappropriate. But even when such reporting is appropriate, the US. government should not cast aspersions on any religious, ideological, or political speech or activity, unless there is a nexus to violence or other criminal activity. Thus, even where reporting of non-violent speech, religion, or ideology is appropriate, products should present an analysis that is neutral, without negative characterizations. For example, calling views ?extreme,? ?militant, anti-government,? or ?radical? is a negative characterization of protected speech and should be avoided unless there is a nexus to violence or criminal activity. ?6 Avoid using the terms ?right wing extremist? or ?left wing extremist"; products using these terms are likely to be interpreted as attacks on members of the left or right side of the political spectrum regardless of their connection to violence or other criminal activities. Instead of using these terms, expressly state the group?s or individual?s behavior that reflects facilitation or engagement in acts of violence or other criminal activity. Likewise, avoid using the term ?anti-govemment? to describe groups and organizations, because it tends to read as a criticism and the First Amendment protects anti-government sentiment. Instead, ?rst determine whether a term that more specifically describes the group is contained in the Domestic Terrorism and Homegrown Violent Extremism Lexicon (10 Nov. 2011). If a more specific term is contained in the lexicon, and the group has engaged in conduct that meets the lexicon definition, that term and de?nition should be used as long as the product includes sufficient factual support for using it. The use of a term and definition from the lexicon is not a substitute for describing what the particular group has done to bring itself within the definition of the term. Even if an applicable term more specific than ?anti-government? is not contained in the lexicon, the term ?anti-govemment? should be avoided in favor of a discussion of the speci?c violent or other criminal activity that is attributable to the group or its individual members. As always, the analyst must describe the DHS mission nexus for labeling the group or organization in a particular manner. DHS-001-6153-01880 WW The No-Aspersions Principle in Action: Sample Problems and Solutions Problem: Original Text Solution: Revised Text; (UHFOUO) Indicators of suspicious activity at (UHFOUO) Indicators of suspicious activity ?rearm shops and ranges include unusual at firearm shops and ranges include vague or comments made regarding anti-US, radical warnings that are violent in nature, theology, vague or warnings;? statements that appear to condone violence against ethnic groups or governments, statements focused on committing violent acts in support of a patticular ideology, or statements focused on committing acts of violence against the US. government. Hot-button terms {use suggests that the product should be evaluated for compliance with this principle}: 0 ?extreme,? ?extremist,? ?right-wing extremist,? ?left-wing extremist? I ?militant? 0 ?anti-government? 0 ?radical? 3. THE EQUALITY PRINCIPLE: DEGREE OF INTEREST (0R INTENSITY OF REPORTING) SHOULD NOT BE BASED ON RACE, ETHNICITY, OR APPEAR TO BE SO BASED. The Equality Principle protects civil rights by eliminating discrimination and its appearance, and supports strong analytical tradecraft by helping ensure objective analysis.4 Information must be presented in such a way that it does not focus?or appear to focus?unequal attention on particular individuals or groups due to their race, ethnicity, or religion or belief system. Of course, if a threat picture reveals that only one group or its individual members pose a threat, that can be discussed. But if, for example, multiple groups or organizations or their individual members may pose an actual or potential threat, be sure to treat similarly situated individuals, groups, and organizations in an even-handed fashion. Focusing without clear justification on some individuals or groups and not others, especially where discussing groups or individuals that share a particular ethnicity, religion, or belief system, is unequal and inappropriate. Include all relevant information to adequately characterize the nature of a threat and the confidence in any analytic judgment.5 4 See, e.g. Intelligence Community Directive (1CD) 203, Analytic Standards, which lists ?Objectivity" as one of the 1C Analytic Standards. requiring ?that and managers perform their analytical and informational functions from an unbiased perspective. Analysis should be free ofetnotional content, give due regard to alternative perspectives and contrary reporting, and acknowledge developments that necessitate adjustments to analytic judgments." 5 This is also consistent with 203, which states: ?Analytic products should accurately characterize the information in the underlying sources and explain which information proved key to analytic judgments and why.? It also states that analytic products should indicate ?both the level of confidence in analytic judgments and explain the basis for ascribing it.? DHS-001-?li?l 53-01881 The Equality Principle in Action: Sample Problems and Solutions Problem: Original Text Solution: Revised Text Unaf?liated hackers invoking Islam (UHFOUO) Unaf?liated hackers including to justify their actions already conduct low-level violent environmental extremists, violent cyber attacks, such as defacing web pages that animal rights extremists, and individuals who they deem anti-Islamic or propagating nuisance? invoke Islam to justify their actions, as well level viruses.? as others already conduct low-level cyber attacks, such as defacing web pages or propagating nuisance?level viruses. 4. THE DUE PROCESS PRINCIPLE: SEPARATE ALLEGATIONS OF CRIME FROM DETERMINATIONS 0F GUILT Until criminal suspects are convicted of a crime, their involvement in a crime is only an allegation. No matter how much evidence may exist, even if the suspect has been arrested, indicted or has confessed, the suspect has still only allegedly committed the crime. (For example, a confession may be suppressed because of how it was elicited.) A defendant should not be described or implied to be guilty of a crime until convicted by a court orjury or until a plea agreement is accepted by a court. (In addition, a criminal defendant?s agreement to a plea bargain is not enough without court approval of the plea). This does not mean that a product cannot discuss these facts?but guilt cannot be asserted until there is a conviction, whether by trial or court-accepted guilty plea. The consequences for error in implementing this principle are magnified if a product is widely disseminated. Where an individual has been found guilty at trial or pled guilty, reporting must also accurately re?ect the charges (Le. the speci?c criminal activities) on which an individual was found or pled guilty. It is important to note that this may be all, some, or none of the charges on which the individual was originally indicted. must research the outcome of the legal proceedings against individuals on whom they wish to report and verify that they have appropriately described the crime for which the individual was convicted. Minimize the use of the term ?allegedly? when you are citing evidence from a particular source. Instead, where possible, refer to the original source of information. There may be situations where it is dif?cult to identify the source or originator of a statement; in those situations, use the terms ?allegedly? or ?reportedly.? If an individual has been arrested, indicted, or convicted, use the most current, complete, timely, and accurate terms possible in describing his or her status. Cite the specific charges from the indictment or any admissions in the court accepted plea agreement. Not all facts need to be described as allegations. For example, a fact-based report about a shooting does not require using the phrase ?alleged shooting? if it is well-documented that a shooting took place. The ?allegation? requirement only applies when tying a suspect to the shooting (the ?alleged shooter?). Note, too, that an exception to this rule is justified for individuals who were killed (or killed themselves) during the conduct of a particular act of violence or criminal activity. Because the individual was killed during the commission of the violent or criminal activity?and therefore cannot be charged, tried, and accurately described in DHS-001-8153-01882 WW WW terms of the outcome of those proceedings?reports may describe the individual actor?s reasonably certain involvement in the violent or criminal activity without requiring terminology indicating that this involvement remains merely an allegation. One area where this principle frequently arises is the characterization of U.S. Persons as ?terrorists? or ?violent extremists?; this is appropriate only if there is suf?cient evidence stated in the product to support the conclusion. In deciding whether it is appropriate to refer to an individual or group by using one of these terms, use the term that is best supported by the intelligence and other information available. (If applicable and relevant, you may also state that an individual or group: has been (I) Designated as a ?Specially Designated Global Terrorist? under Executive Order 13224; or (2) Designated as a Foreign Terrorist Organizations (PTO) under the Immigration and Nationality Act; or (3) Placed on the ?Terrorist Exclusion List? under Section 411 of the USA PATRIOT ACT of 2001; or (4) Placed on the ?Specially Designated Nationals List? pursuant to 31 CPR. 500.306.) The Due Process Principle in Action: Sample Problems and Solutions Problem: Original Text Solution: Revised Teri; The identi?ed individual was able to The identi?ed individual was enter the station from an unlocked back door, but allegedly/reportedly able to enter the station was subsequently apprehended by the police from an unlocked back door, but was officers without incident. The individual was subsequently apprehended by the police armed with a handgun when the police took him officers without incident. The individual was into custody. allegedly armed with a handgun when the police took him into custody. According to court documents, According to court documents, Madison, Wisconsin police arrested Lang for Madison, Wisconsin police arrested Lang for reckless endangerment after he discharged his reckless endangerment after he allegedly .33?caliber handgun from a motel room in which discharged his .38?caliber handgun from a he was staying into an unoccupied room across motel room in which he was staying into an the hall. Upon his arrest, Lang told police that unoccupied room across the hall. Upon his he had a gun ?to lay out abortionists because arrest, Lang allegedly told police that he had they are killing babies.? a gun "to lay out abortionists because they are killing babies." Hot-button terms (use suggests that the product should be evaluated for compliance with this principle): 0 ?terrorist? - ?violent extremist? I ?perpetrator? DHS-001-9153-01883 WW 5. THE RELIGIOUS DEBATE PRINCIPLE: AVOID TAKING PART IN A RELIGIOUS DEBATE BY USING RELIGIOUS TERMS IN A NON-NEUTRAL WAY Avoid using religious terms that are subject to interpretation or have multiple meanings. Using such terms may legitimize the interpretation favored by a violent faction, or inappropriately engage DHS in an ongoing debate about the meaning accepted by the entire religion. For example, the terms ?jihad,? ?jihadi,? and ?jidahist? are terms with various meanings, subject to ongoing debate within Muslim communities of faith. Violent extremists certainly use the terms to refer to what they believe is a duty to conduct their terrorist activities, but others use them to mean a peaceful striving towards righteousness. ?In Arabic, jihad means ?striving in the path of God? and is used in many contexts beyond warfare.? Indeed, anti-terrorists sometimes couch their opposition to terrorism by stating that it is not truly jihad, because it is unrighteous. Using the term ?jihad? as synonymous to terrorism tends to ratify the violent extremists? interpretation, lending it legitimacy. The use of these words by the US. government, attaching a violent gloss, may appear to denigrate Islam and erroneously label its mainstream practice as violent. Therefore, avoid using these terms altogether, as a general principle. However, if such a term must be used must make every effort to illustrate that DHS is merely reporting use of the term in that manner. For example, where necessary, reporting may include quotes from violent extremists characterizing their activities as ?jihad,? and this should be indicated as a quote, both by direct association of the individual or group with the statement and by punctuating the reporting of the statement as a quotation. Wherever possible, reporting that must use this type of terminology should also include appropriate modifiers necessary to make clear why DHS is interested in its use; for example, ?violent jihad? is preferred over simply referring to ?jihad,? as DHS interest is only triggered if the term is used to imply a violent act. Likewise, avoid use of the terms ?Islamic? or Muslim? as adjectives to describe terrorists, violent extremists, or other criminal individuals or groups. Use of these terms provides Al Qai?da, its followers, and other terrorist organizations with the legitimacy they seek by giving them the appearance of being representatives of the religion rather than representatives of their own violent belief system. If the terms ?Islamic? or ?Muslim? are necessary in certain situations to provide context for an event described in a product, more descriptive language should be used to make clear the relevance of the term to the product. More broadly, use of the term ?fundamentalist? should be avoided in DHS products; the term is generally used to denote more traditional or conservative adherents of a religion and is commonly used in reference to religious organizations and individuals with no link to violence or criminality. The term should never be used as a synonym for ?terrorist? or ?violent extremist.? {1 National Words that Work and Words that Don A Guidelfor Countertermrism Common faction {2003). mm The Religious Debate Principle in Action: Sample Problems and Solutions Problem: Original Text Solution: Revised Text On or about 23 August 2009, LaRose traveled to Europe with the intent to live and train with jihadists. LaRose was charged with recruiting men online to wage violent jihad abroad, recruiting women online to provide logistical support, soliciting funds online for terrorist organizations, and conspiracy to commit the act of murder outside the United States. (UHFOUO) On or about 23 August 2009, LaRose traveled to Europe with the intent to live and train with violent extremists. LaRose was charged with recruiting men online to engage in violence abroad, recruiting women online to provide logistical support, soliciting funds online for terrorist organizations, and conspiracy to commit the act of murder outside the United States. Problem: Original Text Solution: Revised Text On 27 August 2014, ISIS jihadists captured a Syrian Army air base and executed 250 members of the Syrian government force, who had surrendered after a brief ?refight. ISIS is an Islamic extremist group that formed in response to the Syrian civil war, issued a statement threatenin to continue attacking in Syria and Iraq until Syrian President Assad was deposed and a fundamentalist government compliant with Sharia law was established. (UHFOUO) On 27 August 2014, violent extremists associated with the terrorist and paramilitary group ISIS captured a Syrian Army air base and executed 250 members of the Syrian government forces, who had surrendered after a brief firefight. IS IS, which formed in response to the Syrian civil war, is attempting to re?establish the caliphate (Islamic state), subsequently issued a statement claiming that the attacks would continue until Syrian President Assad was deposed and a government that comported with interpretation of Islam was established in Syria and Iraq. Hot-button terms (use suggests that the product should be evaluated for compliance with this principle): 0 ?Islamic extremist,? ?Islamic terrorist,? ?Islamist? 0 ?Muslim extremist,? ?Muslim terrorist? 0 ?Sunni extremist,? ?Shia extremist? ?Radical Islam,??Radical Muslim? ?Jihad,? ?Jihadi,? ihadist? ?Fundamentalist? DHS-001-11I153-01885 WW WW 6. THE GUILT-BY-ASSOCIA TION PRINCIPLE: IMPLICATE MANY IN THE BAD CONDUCT OF A FEW Do not attribute violent or other criminal acts of one or a limited number of a group?s members to an entire group unless: (1) the group claims responsibility for the act; (2) the group openly advocates violent or other criminal acts in a manner that should be known to all of its members; (3) the U.S. government has publicly indicated that the group is connected to a terrorist organization; or (4) the group has been convicted as an organization operating primarily for criminal purpose or by criminal means. Avoid stating that someone is connected to a group or organization engaged in some violent or other criminal activity unless you provide express support for that conclusion in the product. (Include a statement of and citation to the evidence that establishes the nature of the relationship. If the information regarding the nature and extent of the relationship was derived from another productfsource, that productt?source must be identi?ed and cited within the product and made available for review. See Clarity quonrce Principle.) What may not be reported: Individual members of a group do not become a proper subject for reporting simply because of their membership in the group in which one or a limited number of a group? other members engage in violent or other criminal acts. Some groups have violent extremist factions that engage in violent or other criminal acts. If reliable evidence indicates that an individual member of the group advocates or engages in the same violent or other criminal activities as members of a rogue faction of the group, this is a proper basis for reporting on that member?but is not a sufficient basis to report on the group as a whole. The participation in violent or other criminal activity by some members of a group does not warrant reporting on the group?s speeches, recruitment efforts, fundraising activities, associations by other members of the group, or other groups that share a similar ideology. What may be reported: If reliable evidence exists to support attributing the acts of individual members to the entire group, the group can be labeled accordingly, provided the basis for the label is fully explained in the product. Reporting about individuals or groups should discuss any challenge in distinguishing members who facilitate or engage in violent or other criminal activities from other law-abiding members of the group. As noted above, even where it is appropriate, reporting must not cast aspersions on religious, ideological, or political speech or activity unless that activity or speech includes the advocacy of violent or other criminal activity. In addition, when assessing the potential for violence or other criminal activity in the future g. violence is planned but has not yet been carried out) by an individual or group, it is appropriate to include examples of past violent or criminal activity. Furthermore, a predictive report should Such public documents include: The list of ?Specially Designated Global Terrorists? {as designated pursuant to Executive Order 13224); (2) the list of Foreign Terrorist Organizations (FTO) (as designated pursuant to the Immigration and Nationality Act); the ?Terrorist Exclusion List" (as designated pursuant to Section 41 1 of the USA PATRIOT Act of 2001]: and (4) the ?Specially Designated Nationals List? (as designated pursuant to 31 C.F.R. 500.306}. DHS-001-11253-01886 include relevant information to establish a well-supported and reasonable threat of violent or other criminal activity by a group, and the report must clearly support the assessment and appropriately characterize the reliability of supporting information. (See also the Vioience Principie above.) The Guilt by Association Principle in Action: Sample Problems and Solutions Problem: Original Text Solution: Revised Text The militia extremist movement has been rife with internal turmoil since its creation, primarily stemming from disagreements among its leaders over its mission, focus, and training. As a result, new militia factions commonly form, disband, or change names in a short period of time. Even so, militia extremists maintain the ability to organize meetings and training with a particular militia extremist group and to network with other militia extremist groups in neighboring states. Furthermore, they are still able to instigate and support violence that targets government officials, institutions, and facilities in the United States. (UIIFOUO) The larger militia movement and its violent fringe element have been rife with internal turmoil from their inception, primarily stemming from disagreements among its leaders over mission, focus, and training. As a result, new militia factions commonly form, disband, or change names in a short period of time. Militia members maintain the ability, however, to organize meetings and train with a particular militia group and to network with other militia groups in neighboring states. Some violent militia extremist groups and individuals are still able to instigate and support violence that targets government officials, institutions, and facilities in the United States. Hot-button terms (use suggests that the product should be evaluated for compliance with this principle): 0 ?af?liated with? ?connected to? ?related to? ?associated with? ?ties to? 7. THE CLARITY-OF-SOURCE PRINCIPLE: ACCURATELY CHARACTERIZE AND SEPARATE CONCLUSIONS FROM YOUR OWN A statement in the text of a report must be consistent with the cited sources. Further, where a product analyzes and reaches judgments based on information obtained from a third party (or multiple sources), the product should clearly identify what the third-party source ?alleges" and what ?concludes? after analyzing the information. The CiarigI-er-Source Principie ensures that reports are properly characterizing what is said in the underlying sources and helps separate the observations and conclusions by sources from 1&A's analytical judgments, and also accurately characterizes the reliability of the sources and the confidence in the analytical judgments.3 8 As noted above in footnote 5, this is also required by the standards set out under 203. DHS-001-11353-01887 What may not be reported: 1. Facts that are not supported by the cited authoritiesfsources. 2. Conclusions that do not reflect reasonable analytical judgments based on cited authoritiesi?sources. 3. Products that do not clearly distinguish between facts and opinions from third-party authoritiesfsources and assessments based on those facts. What may be reported: 1. Facts that are supported by the cited authoritiesi?sources. 2. Conclusions that do re?ect reasonable analytical judgments based on cited authoritiesr?sources.9 3. Products that clearly distinguish between facts and opinions from third-party authoritiesi?sources and 185A assessments based on those facts. The Clarity of Source Principle in Action: Sample Problems and Solutions Problem: Original Text Solution: Revised Teri; (UHFOUO) Anti-abortion extremists remain (UHFOUO) It is 1&A?s assessment that willing and capable to use violence against abortion providers remain a target of abortion doctors and clinics since the murder of violence by some anti-abortion extremists. abortion doctor George Tiller in May 2009. Our concern is that successful acts of violence, such as the murder of abortion doctor George Tiller in May 2009, may serve as inspiration for similar acts in the future. 8. THE ANTI-CONVEYOR BELT PRINCIPLE: CIVIL RIGHTS ISSUES ARE NOT NECESSARILY CURED BY ATTRIBUTION If the language used in a product is problematic from a civil rights or civil liberties perspective, the attribution of that language to another agency or source does not typically cure the problem. For example, if a third-party source foreign intelligence, news media, or other third party) makes unsupported conclusions about individuals or groups referring to a group as ?terrorist? without appropriate factual support), simply citing the fact to the third-party source does not fix the problem. If third-party sources use vague or inappropriate terminology, should consult applicable lexicons to determine whether the source has a definition for the term it uses that can be cited that is not objectionable to DHS. If there is no known definition available from the source, should seek to obtain additional information from the source to substantiate the use of the term. If the term is important to the overall report, and it is not feasible to obtain additional information from the source, the analyst should identify the statement or term as originating with the source and use quotations and appropriate citations to make clear that the language being 9 When relying upon open source information, should also take into consideration that news organizations often rely upon a single source, and their stories may then be reported in multiple secondary sources without direct attribution. This may give the appearance of widespread acceptance of a particular ?fact? actually attributable to only one source. DHS-001-11453-01888 WW used is derived from the third-party source and is not DHS language. Under these circumstances, the analyst will also need to provide factual background to support the fact that we are using the term in a manner that is within the DHS mission tying the use of the term to violent or other criminal activity). This may require the analyst to limit what is relayed about the third-party source?s conclusions. DHS-0011155301889 Page 092 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01890 Page 093 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01891 Page 094 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01892 Page 095 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01893 Page 096 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01894 Page 09? Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01895 Page 098 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01896 Page 099 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01897 Page 100 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01898 Page 101 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01899 Page 102 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01900 Page 103 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01901 Page 104 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01902 Page 105 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01903 Page 106 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01904 Page 10? Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01905 Page 108 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01906 Page 109 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01907 Page 110 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01908 Page 111 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01909 Page 112 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01910 Page 113 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01911 Page 114 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01912 Page 115 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01913 Page 116 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01914 Page 11? Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01915 Page 118 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01916 Page 119 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01917 Page 120 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01918 Page 121 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01919 Page 122 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01920 Page 123 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01921 Page 124 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01922 Page 125 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01923 Page 126 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01924 Page 12? Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01925 Page 128 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01926 Page 129 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01927 Page 130 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01928 Page 131 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01929 Page 132 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01930 Page 133 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01931 Page 134 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01932 Page 135 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01933 Page 136 Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01934 Page 13? Withheld pursuant to exemption of the Freedom of Information and Privacy Act DHS-001-1153-01935 Page 138 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01936 Page 139 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01937 Page 140 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01938 Page 141 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01939 Page 142 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01940 Page 143 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01941 Page 144 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01942 Page 145 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01943 Page 146 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01944 Page 147 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01945 Page 148 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01946 Page 149 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01947 Page 150 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01948 Page 151 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01949 Page 152 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01950 Page 153 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01951 Page 154 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01952 Page 155 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01953 Page 156 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01954 Page 157 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01955 Page 158 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01956 Page 159 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01957 Page 160 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01958 Page 161 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01959 Page 162 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01960 Page 163 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01961 Page 164 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01962 Page 165 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01963 Page 166 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01964 Page 167 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01965 Page 168 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01966 Page 169 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01967 Page 170 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01968 Page 171 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01969 Page 172 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01970 Page 173 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01971 Page 174 Withheld pursuant to exemption eftne Freedom of Information and Privacy Act DHS-001-1153-01972 Page 175 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01973 Page 176 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01974 Page 177 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01975 Page 178 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01976 Page 179 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01977 Page 180 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01978 Page 181 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01979 Page 182 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01980 Page 183 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01981 Page 184 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01982 Page 185 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01983 Page 186 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01984 Page 187 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01985 Page 188 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01986 Page 189 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01987 Page 190 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01988 Page 191 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01989 Page 192 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01990 Page 193 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01991 Page 194 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01992 Page 195 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01993 Page 196 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01994 Page 197 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01995 Page 198 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01996 Page 199 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01997 Page 200 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01998 Page 201 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-01999 Page 202 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02000 Page 203 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02001 Page 204 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02002 Page 205 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02003 Page 206 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02004 Page 207 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02005 Page 208 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02006 Page 209 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02007 Page 210 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02008 Page 211 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02009 Page 212 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02010 Page 213 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02011 Page 214 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02012 Page 215 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02013 Page 216 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02014 Page 217 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02015 Page 218 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02016 Page 219 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02017 Page 220 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02018 Page 221 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02019 Page 222 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02020 Page 223 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02021 Page 224 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02022 Page 225 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02023 Page 226 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02024 Page 22?r Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02025 Page 228 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02026 Page 229 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02027 Page 230 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02028 Page 231 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02029 Page 232 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02030 Page 233 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02031 Page 234 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02032 Page 235 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02033 Page 236 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02034 Page 23? Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02035 Page 238 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02036 Page 239 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02037 Page 240 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02038 Page 241 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02039 Page 242 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02040 Page 243 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02041 Page 244 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02042 Page 245 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02043 Page 246 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02044 Page 24?r Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02045 Page 248 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02046 Page 249 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02047 Page 250 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02048 Page 251 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02049 Page 252 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02050 Page 253 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02051 Page 254 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02052 Page 255 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02053 Page 256 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02054 Page 25?r Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02055 Page 258 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02056 Page 259 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02057 Page 260 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02058 Page 261 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02059 Page 262 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02060 Page 263 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02061 Page 264 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02062 Page 265 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02063 Page 266 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02064 Page 26? Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02065 Page 268 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02066 Page 269 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02067 Page 2?0 Withheld pursuant to exemption {bii5} of the Freedom of Information and Privacy Act DHS-001-1153-02068 Page 271 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02069 Page 272 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02070 Page 273 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02071 Page 274 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02072 Page 275 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02073 Page 276 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02074 Page 277 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02075 Page 278 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02076 Page 279 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02077 Page 280 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02078 Page 281 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02079 Page 282 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02080 Page 283 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02081 Page 284 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02082 Page 285 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02083 Page 286 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02084 Page 287 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02085 Page 288 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02086 Page 289 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02087 Page 290 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02088 Page 291 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02089 Page 292 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02090 Page 293 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02091 Page 294 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02092 Page 295 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02093 Page 296 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02094 Page 297 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02095 Page 298 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02096 Page 299 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02097 Page 300 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02098 Page 301 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02099 Page 302 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02100 Page 303 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02101 Page 304 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02102 Page 305 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02103 Page 306 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02104 Page 307 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02105 Page 308 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02106 Page 309 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02107 Page 310 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02108 Page 311 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02109 Page 312 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02110 Page 313 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02111 Page 314 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02112 Page 315 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02113 Page 316 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02114 Page 317 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02115 Page 318 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02116 Page 319 Withheld pursuant to exemption (W5) eftne Freedom of Information and Privacy Act DHS-001-1153-02117