Office for Civil Rights and Civil Liberties
U.S. Department of Homeland Security
Washington, DC 20528

March 20, 2019
MEMORANDUM FOR:

Ronald Vitiello
Deputy Director and Senior Official
Performing the Duties of the Director
U.S. Immigration and Customs Enforcement
Michael P. Davis
Executive Deputy Principal Legal Advisor
Office of the Principal Legal Advisor
U.S. Immigration and Customs Enforcement

FROM:

Cameron P. Quinn ██████████████
Officer for Civil Rights and Civil Liberties
Marc Pachon ███████████
Attorney Advisor — Legal Counsel Division
Office of General Counsel

SUBJECT:

ICE Health Service Corps (IHSC) Medical/Mental Health Care
and Oversight
Complaint Nos. 17-06-ICE-0582, 18-09-ICE-0615
18-10-ICE-0613, 18-08-ICE-0614, 18-10-ICE-0623
18-10-ICE-0624, 18-10-ICE-0626, 18-10-ICE-0627
18-10-ICE-0628, 18-10-ICE-0629, 18-10-ICE-0630
18-10-ICE-0631, 18-10-ICE-0632, 18-10-ICE-0633
18-10-ICE-0634, 18-10-ICE-0635, 18-10-ICE-0636

The DHS Office for Civil Rights and Civil Liberties (CRCL) has received information from the DHS
Office of Inspector General (OIG) alleging that Immigration and Customs Enforcement’s (ICE) ICE
Health Service Corps (IHSC) has systematically provided inadequate medical and mental health care and
oversight to immigration detainees in facilities throughout the U.S. The purpose of this memorandum is
to notify you of the complaints and describe the allegations, and inform you that, consistent with its
authority described in the CRCL and Scope of Review sections below, CRCL will retain the complaints
for investigation and explain how CRCL will work with ICE during our investigation.
SUMMARY
On July 18, 2018, CRCL received information from the OIG regarding the quality of detainee medical
and mental health care provided directly by IHSC at IHSC-staffed detention facilities, as well as its

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 oversight of detainee medical and mental health care. OIG received the information and allegations
beginning in April 2018 from a complainant within IHSC who raised serious claims regarding the care
and oversight provided by IHSC at these facilities. The allegations involved both medical and mental
health care and include the following:
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●
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inadequate treatment and monitoring of detainees in severe withdrawal from alcohol and/or
substance abuse;
lack of psychiatric monitoring leading to mental health deterioration;
forcible medication injections as a means of behavior control;
misdiagnosis of medical and mental health conditions;
serious medication errors, and
inadequate care and/or oversight for four detainees who died while in custody.

Further, the complainant alleged that IHSC leadership failed to take appropriate action and/or implement
appropriate oversight measures upon notification of the specific medical or mental health concerns by
IHSC personnel.
In addition to the specific complaint allegations, CRCL will look at IHSC’s policies, procedures, and
operations more generally to determine if the individual allegations or findings are indicative of systemic
issues. While the complaints also contain allegations of retaliation against the complainant, CRCL will
not be investigating these claims and they will be handled directly by the OIG.1

ALLEGATIONS
1. Complaint No. 18-10-ICE-0623
CRCL received a referral from the DHS OIG regarding ████████████████, an ICE detainee at
the Eloy Federal Contract Facility in Eloy, Arizona. According to the complaint, IHSC Medical Quality
Management Unit ("MQMU") notified the facility psychiatrist several times about ██████████
worsening psychosis-related symptoms, but the psychiatrist failed to treat him. ██████████
allegedly became so unstable that he lacerated his penis, requiring hospitalization and surgery.
2. Complaint No. 18-10-ICE-0624
CRCL received a referral from the DHS OIG regarding ██████████████, an ICE detainee at the
Eloy Federal Contract Facility in Eloy, Arizona. Allegedly, ██████████ was not treated
appropriately for serious mental illness with psychotic-like symptoms. According to the complainant,
MQMU warned IHSC senior leadership on two occasions about ██████████ increased risk of
adverse outcomes due to his auditory hallucinations and suicidal ideations. This allegedly resulted in
██████████ not receiving anti-psychotic medication, despite the IHSC chief psychiatrist's
agreement with the MQMU's findings and recommendation that ██████████ receive anti-psychotic
1

The handling of these complaints differ from CRCL standard practice in that the OIG also has open 
complaints on these matters. While CRCL normally stands down through the entirety of an OIG 
investigation, the OIG has indicated that CRCL may move forward with its investigations into the 
aforementioned medical care issues irrespective of the OIG investigations on separate topics.
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 medication. Instead, ██████████ received an anti-depressant which likely worsened his psychosis.
The complainant further claimed that following MQMU's second notification of inadequate mental health
care and treatment, IHSC senior leadership allegedly advised MQMU to "hold off" on notifying IHSC
Clinical Services unless and until the detainee became psychotic and suicidal again.
3. Complaint No. 18-10-ICE-0626
CRCL received a referral from the DHS OIG regarding ████████████████████, an ICE
detainee at Florence Service Processing Center (SPC) in Florence, Arizona. Allegedly, facility medical
staff did not follow policies and procedures concerning withdrawal protocols for ██████████ opioid
withdrawal. According to the complainant, the detainee was not treated until MQMU staff called the
facility following a review of a significant event notification (SEN). The detainee was subsequently
found to be in severe benzodiazepine withdrawal and was admitted to the hospital. Further, the
complainant alleges that MQMU performed an analysis of the case and the findings included policy and
procedure violations, which were forwarded to IHSC leadership for review and action, yet IHSC
leadership failed to take appropriate action.2
4. Complaint No. 18-10-ICE-0627
CRCL received a referral from the DHS OIG regarding ████████████████████, an ICE
detainee at Florence Service Processing Center (SPC) in Florence, Arizona. Allegedly, facility medical
staff did not follow policies and procedures concerning withdrawal protocols for ██████████
benzodiazepines withdrawal. According to the complainant, medical staff did not address his withdrawal
at intake, despite his reporting high levels of daily consumption of benzodiazepines. ██████████
subsequently went into drug withdrawal seizures and was admitted to the hospital. Further, the
complainant alleges that MQMU performed an analysis of the case and the findings included policy and
procedure violations, which were forwarded to IHSC leadership for review and action, yet IHSC
leadership failed to take appropriate action.3
5. Complaint No. 18-10-ICE-0628
CRCL received a referral from the DHS OIG regarding ████████████████████, an ICE
detainee at Elizabeth Contract Detention Facility in Elizabeth, New Jersey. Allegedly, facility medical
staff did not follow policies and procedures concerning withdrawal protocols for ██████████
alcohol withdrawal. ██████████ stated during his intake screening that he consumed one bottle of
vodka and two bottles of beer daily. ██████████ subsequently went into severe alcohol withdrawal
and delirium and was admitted to the hospital in the intensive care unit (ICU). Further, according to the
complainant, MQMU performed an analysis of the case and the findings included policy and procedure

2

1) Directive by Deputy Assistant Director Dr. Rivera dates 11/3/2017 regarding physician supervision of 
detoxifications and transfer of detainees experiencing a severe or progressive intoxication (overdose) or 
severe alcohol/sedative withdrawal to a licensed acute care facility and 2) IHSC Directive: 03-13 section
4-7: Monitoring of Detainees in Withdrawal
3
1) IHSC Directive: 03-13 Section 4-7: Monitoring of Detainees in Withdrawal, 2) Directive by Deputy 
Assistant Director Dr. Rivera dates 11/3/2017 regarding physician supervision of detoxifications and 
transfer of detainees experiencing a severe or progressive intoxication (overdose) or severe 
alcohol/sedative withdrawal to a licensed acute care facility, and 3) IHSC Directive: 03-10: Intake
Screening and Intake Reviews Section 4-4(a)
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 violations, which were forwarded to IHSC leadership for review and action, yet IHSC leadership failed to
take appropriate action.4
6. Complaint No. 18-10-ICE-0629
CRCL received a referral from the DHS OIG regarding ██████████████████, an ICE detainee
at Florence Service Processing Center (SPC) in Florence, Arizona. Allegedly, facility medical staff did
not follow policies and procedures concerning withdrawal protocols for ██████████ opioid
withdrawal, and a medication error occurred during the course of his treatment. Further, according to the
complainant, MQMU performed an analysis of the case and the findings included policy and procedure
violations, which were forwarded to the IHSC leadership for review and action, yet IHSC leadership
failed to take appropriate action.5
7. Complaint No. 18-10-ICE-30
CRCL received a referral from the DHS OIG regarding ███████████████████████████,
an 8-year old resident at South Texas Family Residential Center (STFRC) in Dilley, Texas. Allegedly,
delayed medical care and misdiagnosis led to an infection that spread from the child's ear to his facial
bone, requiring a partial bone resection. According to the information provided, on December 5, 2017,
the child's mother first reported that her child had a progressively worsening earache for the past two
weeks. The child was subsequently treated using nursing guidelines for Allergies/Fever/Pain, diagnosed
with Swimmer's Ear, and given ear drops. However, on December 23, 2017, the child was noted to have
seizure activity and was transferred to the hospital where he was diagnosed with Pott's Puffy Tumor with
epidural and subdural abscess resulting in partial frontal bone resection. Further, the complainant alleged
that MQMU performed an analysis of the case and found that the inadequate medical care provided by
STFRC was a contributory factor resulting in harm. MQMU's report was forwarded to IHSC leadership
and MQMU requested findings and/or interventions from Clinical Services, yet IHSC leadership failed to
take appropriate action.
8. Complaint No. 18-10-ICE-0631
CRCL received a referral from the DHS OIG regarding ███████████████████████████,
an ICE detainee at Stewart Detention Center in Lumpkin, Georgia. Allegedly, a delay in care occurred
after medical staff were notified of the detainee's critical lab result that should have resulted in immediate
medical intervention. ████████████ was reportedly bleeding through his skin and having vision
changes. Despite having extremely thin blood, the physician allegedly kept him on aspirin regimen for
six days, resulting in his coughing up large amounts of blood. ████████████████ was taken to
the hospital in critical condition and not expected to survive. MQMU performed an analysis of the case
4

MQMU reportedly found that: 1) Nursing staff did not specify the frequency of use of alcohol on intake, 
2) Physician oversight was not initiated, 3) the CIWA-A score was not obtained at intervals recommended 
by the Federal Bureau of Prisons withdrawal guidelines, 4) the detainee was housed in the dormitory and 
not in a MHU setting, and 5) initiation of a benzodiazepine was not considered even though the detainee 
has a history of alcohol use.
5
1) IHSC Directive 03-13: Detainee with Substance Dependence or Abuse: Section 4-7: Monitoring of
Detainees in Withdrawal, 2) IHSC Directive 03-13: Detainees with Substance Dependence or Abuse:
Section 4-3: Behavioral Health Evaluation, 3) IHSC Guide 09-02-G-01: Pharmaceutical Services and
Medication Management Guide Section C: Verbal Orders and 4) IHSC Directive 03-13: Detainees with
Substance Dependance or Abuse: Section 4-6: Housing
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 and determined that that Asprin therapy may have caused harm that could have resulted in a fatality. The
findings were forwarded to IHSC leadership for consideration of a root cause analysis, yet IHSC
leadership failed to take appropriate action.
9. Complaint No. 18-10-ICE-0632
CRCL received a referral from the DHS OIG regarding ███████████████, an ICE detainee at
Jena/LaSalle Detention Facility in Jena, Louisiana. ██████ was sent to the hospital Emergency Room
due to erratic behavior and convulsions. When she returned to the facility, she was observed eating toilet
paper and styrofoam in the Medical Housing Unit (MHU). According to the complainant, ███████
was placed at higher than normal risk for mental status deterioration and given forced intramuscular
injection of Ativan. Further, the complainant alleged that MQMU performed an analysis of the case and
the findings included policy and procedure violations, which were forwarded to IHSC leadership for
review and action, yet IHSC leadership failed to take appropriate action.6
10. Complaint No. 18-10-ICE-0633
CRCL received a referral from the DHS OIG regarding ███████████████████, an ICE
detainee at Jena/LaSalle Detention Facility in Jena, Louisiana. Allegedly, ███████████ was
forcibly medicated with multiple Ativan injections for repeated behavioral issues. Further, MQMU
performed an analysis of the case and the findings included policy and procedure violations, which were
forwarded to IHSC leadership for review and action, yet IHSC leadership dialed to take appropriate
action.7
11. Complaint No. 18-10-ICE-0634
CRCL received a referral from the DHS OIG regarding ████████████████████████████,
an ICE detainee at El Paso Service Processing Center (SPC) in El Paso, Texas. According to the
information provided, ██████████████████ was observed with a sweatshirt around his neck
and four correctional officers held him down while medical staff administered a haloperidol
intramuscularly by force. According to the complainant, MQMU performed an analysis of the case and

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1) IHSC OM 19-025: Forced Emergency Psychotropic Medication, 2) IHSC OM Section 4-1
Consideration of Alternatives to Forced Emergency Psychotropic Medication, 3) IHSC OM Section 4-2:
Ordering of Forced Emergency Psychotropic Medication, 4) IHSC OM Section 4-3: Direct Observation of
Detainees given Forced Emergency Psychotropic Medication, subsection (a), 5) IHSC OM Section 4-5: 
Maximum use of Forced Emergency Psychotropic Medication, 6) IHSC OM Section 5-7: Forced
Emergency Psychotropic Medication Debriefing, and 7) IHSC Directive: 07-05: Serious Mental
Disorders or Conditions
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1) IHSC OM 19-025: Forced Emergency Psychotropic Medication, 2) IHSC OM Section 4-1
Consideration of Alternatives to Forced Emergency Psychotropic Medication, 3) IHSC OM Section 4-2:
Ordering of Forced Emergency Psychotropic Medication, 4) IHSC OM Section 4-3: Direct Observation of
Detainees given Forced Emergency Psychotropic Medication, subsection (a), 5) IHSC OM Section 4-5:
Maximum use of Forced Emergency Psychotropic Medication, 6) IHSC OM Section 5-7: Forced
Emergency Psychotropic Medication Debriefing, and 7) IHSC Directive: 07-05: Serious Mental
Disorders or Conditions
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 the findings included policy and procedure violations, which were forwarded to IHSC leadership for
review and action, yet, IHSC leadership failed to take appropriate action.8
12. Complaint No. 18-10-ICE-0635
CRCL received a referral from the DHS OIG regarding ███████████████████████████,
an ICE detainee at El Paso Service Processing Center (SPC) in El Paso, Texas. Allegedly,
███████████ was forcibly medicated for reported behavioral issues. MQMU performed an analysis
of the case and the findings included policy and procedure violations, which were forwarded to IHSC
leadership for review and action, yet IHSC leadership failed to take appropriate action.9
13. Complaint No. 18-10-ICE-0636
CRCL received a referral from the DHS OIG regarding ███████████████████, an ICE
detainee at Northwest Detention Facility in Tacoma, Washington. According to the complainant, MQMU
noted that despite ███████████ having a significant psychiatric history and medication
non-compliance, he was not being monitored by facility mental health staff. MQMU notified IHSC
senior leadership in the Behavorial Health Unit (BHU) that based on their review, ██████████ was
at high risk for suicide. Allegedly, BHU leadership was unable to appropriately identify him as seriously
mentally ill (SMI). This resulted in facility mental health staff not being notified that the detainee should
be flagged for possible treatment, close monitoring, and tracking.10
14. Complaint No. 17-06-ICE-0582
CRCL received a referral from the DHS OIG regarding the death of Roger Rayson (A206 839 071), an
ICE detainee at Jena/LaSalle Detention Facility in Jena, Louisiana. According to the complainant, Mr.
Rayson's healthcare was "deplorable." Mr. Rayson's preliminary cause of death was ruled as subdural
hemorrhages resulting in a traumatic brain injury. The complainant claimed that multiple requests for the
Uniform Corrective Action Plan (UCAP) and Root Cause Analysis (RCA) were made to IHSC
leadership, but IHSC did not respond.

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1) IHSC OM 19-025: Forced Emergency Psychotropic Medication, 2) IHSC OM Section 4-1:
Consideration of Alternatives to Forced Emergency Psychotropic Medication, 3) IHSC OM Section 4-2:
Ordering of Forced Emergency Psychotropic Medication, 4) IHSC OM Section 4-3: Direct Observation
of Detainees given Forced Emergency Psychotropic Medication, subsection (a) IHSC OM Section 4-5:
Maximum use of Forced Emergency Psychotropic Medication, 6) IHSC OM Section 5-7: Forced
Emergency Psychotropic Medication Debriefing, and 7) IHSC Directive 07-05: Serious Mental Disorders
or Conditions
9
1) IHSC OM 19-025: Forced Emergency Psychotropic Medication, 2) IHSC OM Section 4-1:
Consideration of Alternatives to Forced Emergency Psychotropic Medication, 3) IHSC OM Section 4-2:
Ordering of Forced Emergency Psychotropic Medication, 4) IHSC OM Section 4-3: Direct Observation
of Detainees given Forced Emergency Psychotropic Medication, subsection (a) IHSC OM Section 4-5:
Maximum use of Forced Emergency Psychotropic Medication, 6) IHSC OM Section 5-7: Forced
Emergency Psychotropic Medication Debriefing, and 7) IHSC Directive 07-05: Serious Mental Disorders
or Conditions
10
Note: IHSC BHU staff are responsible for supervising BHU field staff and review their charts daily to 
determine if appropriate care and follow-up is provided. In this case, IHSC leadership did not know key 
identifiers to designate SMI status.
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 15. Complaint No. 18-09-ICE-0615
CRCL received a referral from the DHS OIG regarding the death of ██████████████████, an
ICE detainee at Eloy Federal Contract Facility in Eloy, Arizona. According to the complainant, IHSC
leadership was informed of multiple concerns regarding the care provided at the facility, particularly the
facility's psychiatrist misdiagnosing, failing to treat detainees appropriately, and the lack of readily
available emergency medications. ██████ preliminary cause of death was ruled as coronary artery
disease. The complainant alleged that during a briefing with ERO on the preliminary cause of death,
IHSC leadership's report was "very misleading," and the more likely causes of death given the detainee's
medication and symptoms (neuroleptic malignant syndrome and/or serotonin syndrome) were not raised.
16. Complaint No. 18-10-ICE-0613
CRCL received a referral from the DHS OIG regarding the death of Efrain De La Rosa (A209 910 301),
an ICE detainee at Stewart Detention Facility in Lumpkin, Georgia. Mr. De La Rosa's preliminary cause
of death was ruled a suicide. According to the complainant, IHSC leadership was notified of Mr. De La
Rosa's deteriorating mental health condition via SEN report on several occasions between April 25, 2018
and May 6, 2018. On April 26, 2018, a SEN report indicated that while on suicide watch, Mr. De La
Rosa had stated to staff that he would be dead in three days. The complainant noted that several months
earlier, IHSC leadership directed MQMU to cease reviewing SEN and segregation reports, despite
concerns raised to IHSC leadership that this restriction could negatively impact detainee safety.
17. Complaint No. 18-08-ICE-0614
CRCL received a referral from the DHS OIG regarding the death of Ronald Cruz (A078 963 293), an ICE
detainee at Port Isabel Detention Center in Los Fresnos, Texas. According to the complainant, the
medical care rendered to Mr. Cruz was "grossly negligent." Mr. Cruz's preliminary cause of death on
May 16, 2018 was ruled as meningitis. The complainant alleged that the mortality review committee was
erroneous in concluding that the care rendered to Mr. Cruz was appropriate.
CRCL
CRCL mission. CRCL supports the Department’s mission to secure the Nation while preserving individual
liberty, fairness, and equality under the law. CRCL integrates civil rights and civil liberties into all the
Department’s activities:
●

Promoting respect for civil rights and civil liberties in policy creation and implementation by
advising Department leadership and personnel, and state and local partners;

●

Communicating with individuals and communities whose civil rights and civil liberties may be
affected by Department activities, informing them about policies and avenues of redress, and
prompting appropriate attention within the Department to their experiences and concerns;

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 ●

Investigating and resolving civil rights and civil liberties complaints filed by the public regarding
Department policies or activities, or actions taken by Department personnel;

●

Leading the Department’s equal employment opportunity programs and promoting workforce
diversity and merit system principles.

CRCL authorities. Under 6 U.S.C. § 345 and 42 U.S.C. § 2000ee-1, CRCL is charged with investigating
and assessing complaints against DHS employees and officials of abuses of civil rights, civil liberties, and
profiling on the basis of race, ethnicity, or religion. In investigating complaints, if CRCL believes that the
complaints raise similar issues, CRCL may look into whether there are systemic problems that justify a
broader investigation. Pursuant to its authority under 6 U.S.C. § 345(a)(3), CRCL shall assist
components to “periodically review Department policies and procedures to ensure that the protection of
civil rights and civil liberties is appropriately incorporated into Department programs and activities” 11
Additionally, pursuant to DHS Delegation Number 19003, issued October 26, 2012, the Secretary has
delegated to the Officer of CRCL the authority to “assess new and existing policies throughout the
Department for the policies’ impact on civil rights and civil liberties” and “review . . . programs within
any Component to ensure compliance with standards established by the Officer for CRCL to protect civil
rights and civil liberties.” Issues such as appropriate treatment by ICE officials, access to medical care,
lack of arbitrary punishment, and religious accommodations for ICE detainees are examples of issues that
raise civil rights and liberties concerns. The procedures for CRCL investigations and the
recommendations those investigations may generate are outlined in DHS management Directive 3500,
DHS Instruction 046-01-001, and DHS Instruction 046-01-002.
Access to information. 42 U.S.C. § 2000ee-1(d) grants CRCL access to the “information, material, and
resources necessary to fulfill the functions” of the office, including the complaint investigation function.
Management Directive 3500 further authorizes CRCL to:
●

“Notify[] the relevant DHS component(s) involved of the matter and its acceptance by CRCL and
whether the matter will be handled by CRCL or by the component organization”.

●

“Interview {] persons and obtain[] other information deemed by CRCL to be relevant and
require[e] cooperation by all agency employees”; and

●

“Access {] documents and files that may have information deemed by CRCL to be relevant.”

Further guidance is contained in DHS Instruction 046-01-002, and, pursuant to § 3.3 of ICE Directive
8010.1, “Administration and Management of Inquiries from the Office for Civil Rights and Civil
Liberties,” this is a request for information or assistance. Under § 3.3 of Directive 8010.1. ICE will
provide the requested information and materials to CRCL within the timeframe indicated below, and not
In addition, pursuant to 42 U.S.C. § 200ee-1(a)(2), CRCL has the authority to “periodically investigate
and review department, agency, or element actions, policies, procedures, guidelines, and related laws and
their implementation to ensure that such department, agency, or element is adequately considering privacy
and civil liberties in its actions” (emphasis added)
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 edit or otherwise limit review of the information that is responsive to CRCL’s request. Pursuant to § 2 of
Directive 8010.1, CRCL understands that this request will be handled by the appropriate ICE program
office or ICE’s Office of Diversity and Civil Rights (ODCR).
Reprisals forbidden. In addition, 42 U.S.C. § 2000ee-1(e) forbids any Federal employee to subject a
complainant or witness to any “action constituting a reprisal, or threat of reprisal, for making a complaint
or for disclosing information to” CRCL in the course of this investigation.
This memorandum and the accompanying request for documents and information are issued pursuant to
these authorities.
Privilege and required transparency. Our communications with ICE personnel and documents generated
during the review, particularly the final report, will be protected to the maximum extent possible by
attorney-client and deliberative process privileges. Under 6 U.S.C. § 345(b), however, we submit an
annual report to Congress—also posted on the CRCL’s Web site—that is required to detail “any
allegations of [civil rights/civil liberties] abuses . . . and any actions taken by the Department in response
to such allegations.”
We look forward to working with your staff on this matter and will report back to you our findings and
any recommendations.
SCOPE OF REVIEW
The purpose of our review is to: determine if the allegations in the complaints can be verified or
disproven; determine whether the facts we find suggest that the Constitution, a federal statute, or a
Departmental policy has been violated; and to determine what steps, if any, should be taken to address the
complaints, both individually (if the problem is ongoing) and as a matter of policy. It is our goal to
produce a report that will assist you in making ICE the best agency possible.
QUESTION PRESENTED
Did IHSC employees or officials conform to ICE standards, policies and procedures, and to civil rights
requirements, in the provision and oversight of medical and mental health care in immigration detention?
It is possible that our investigation will reveal other matters of concern; if this occurs, we will inform you.
INITIATING THE INVESTIGATION
CRCL will be in contact with ICE ERO staff about this complaint and CRCL’s plans for reviewing the
matter, which is assigned to █████████. We look forward to working together to determine all the
facts surrounding these matters and if appropriate, the best way forward. If you have any questions, please
do not hesitate to contact ████████████████████████████████████.

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 Copies to:
Ronald D. Vitiello
Deputy Director and Senior Official Performing the Duties of Director
U.S. Immigration and Customs Enforcement
Michael P. Davis
Executive Deputy Principal Legal Advisor
Office of the Principal Legal Advisor
U.S. Immigration and Customs Enforcement
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U.S. Immigration and Customs Enforcement
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██████████████████████
U.S. Immigration and Customs Enforcement
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U.S. Immigration and Customs Enforcement
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U.S. Immigration and Customs Enforcement
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██████████████████████
U.S. Immigration and Customs Enforcement
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