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Judicial Watch • JW v DHS Criminal Illegal Aliens 01237

JW v DHS Criminal Illegal Aliens 01237

JW v DHS Criminal Illegal Aliens 01237

Page 1: JW v DHS Criminal Illegal Aliens 01237


Number of Pages:4

Date Created:July 21, 2014

Date Uploaded to the Library:October 01, 2014

Tags:01237, Illegal Immigration, DHS

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425 Third Street, W., Suite 800 
Washington, 20024, 
Plaintiff, Civil Action No. UNITED STATES DEPARTMENT HOMELAND SECURITY, Office the General Counsel 245 Murray Lane Washington, 20528-0485 
Plaintiff, Judicial Watch, Inc., through its attorneys, brings this action against Defendant 
United States Department Homeland Security ("DHS") compel compliance with the 
Freedom oflnformation Act, U.S.C.  552 ("FOIA"). grounds therefor, Plaintiff alleges 
JURISDICTION AND VENUE The Court has jurisdiction over this action pursuant U.S.C.  552(a)(4)(B) 
and U.S.C.  1331. Venue proper this district pursuant U.S.C.  1391(e). 
PARTIES Plaintiff Judicial Watch, Inc. not-for-profit educational foundation, organized under the laws the District Columbia and has its principal place business 425 Third Street, S.W., Suite 800, Washington, 20024. Plaintiff seeks promote transparency, 
accountability, and integrity government, politics, and the law. part its educational 
mission, Plaintiff regularly requests access the public records federal, state and local 
government agencies, entities and offices under FOIA shed light the operations the 
federal government and educate the public about these operations. Plaintiff then analyzes the 
agency records and disseminates its findings and the agency records the public. Defendant DHS agency the United States Government and 
headquartered 601 South 12th Street, Arlington, 22202. Defendant has possession, May 15, 2014, Plaintiff submitted FOIA request U.S. Immigration and 
Customs Enforcement ("ICE"), component Defendant, certified mail, seeking access to: 
Any and all records communication including, but not limited to, emails and memoranda, from personnel the office the Principal Deputy Assistant Secretary Immigration and Customs Enforcement (including its component offices, such the Office Public Affairs), from May May 15, 2014, concerning, regarding, related the report published the Center for Immigration Studies concerning the release 36,000 criminal aliens. May 22, 2014, Defendant acknowledged receipt mail Plaintiffs 
FOIA request May 21, 2014 and assigned the request case number 2014FOIA18227. 
Defendant also informed Plaintiff that due the request for numerous documents, 
Defendant would invoke 10-day extension process Plaintiffs FOIA request, 
allowed Title U.S.C.  552(a)(6)(B). Pursuant U.S.C.  552(a)(6)(A)(i), the Defendant was required 
determine whether comply with Plaintiffs request within thirty (30) working days after its receipt the request and notify Plaintiff immediately its determination, the 
reasons therefor, and the right appeal any adverse determination. Defendant's 
determination was due July 2014. the date this complaint, Defendant has failed to: (i) determine 
whether comply with Plaintiffs request; (ii) notify Plaintiff any such determination the reasons therefor; (iii) advise Plaintiff the right appeal any adverse 
determination; and/or (iv) produce the requested records otherwise demonstrate that 
the requested records are exempt from production. 
Because Defendant has failed comply with the time limit set forth 
U.S.C.  552(a)(6)(A), Plaintiff deemed have exhausted any and all administrative 
remedies with respect its request, pursuant U.S.C.  552(a)(6)(C). 
COUNTl (Violation FOIA, U.S.C.  552) 
Plaintiff realleges paragraphs through fully stated herein. 

Defendant unlawfully withholding records requested Plaintiff 

pursuant U.S.C.  552. 
12. Plaintiff being irreparably harmed reason Defendant's unlawful 
withholding records responsive Plaintiffs FOIA request, and will continue 
irreparably harmed unless Defendant compelled conform its conduct the 
requirements the law. 
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant 
conduct searches for any and all records responsive Plaintiffs FOIA requests and demonstrate 
that employed search methods reasonably likely lead the discovery records responsive Plaintiffs FOIA requests; (2) order Defendant produce, date certain, any and all non
exempt records responsive FOIA requests and Vaughn index any responsive records 
withheld under claim exemption; (3) enjoin Defendant from continuing withhold any and 
all non-exempt records responsive Plaintiffs FOIA requests; grant Plaintiff award 
attorney's fees and other litigation costs reasonably incurred this action pursuant U.S.C.  
552(a)(4)(E); and (5) grant Plaintiff such other relief the Court deems just and proper. 
Dated: July 21, 2014 	Respectfully submitted, JUDICIAL WATCH, INC. 
Isl Paul Orfanedes 
Paul-J; Orfanedes
D.C. Bat No.429716 
425 Third Street Suite 800 Washington, 20024 
(202) 646-5172 

Counsel for Plaintiff