United States of America v. State of California et al

Filing 171

REPLY by United States of America to RESPONSE to 2 Motion for Preliminary Injunction. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X, # 25 Exhibit Y)(Reuveni, Erez)

EXHIBIT I

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XAVIER BECERRA
Attorney General of California
THOMAS S. PATTERSON
Senior Assistant Attorney General
MICHAEL NEWMAN
SATOSHI YANAI
ANTHONY HAKL
Supervising Deputy Attorneys General
CHRISTINE CHUANG
CHEROKEE DM MELTON
MAUREEN C. ONYEAGBAKO
LEE I. SHERMAN
Deputy Attorneys General
State Bar No. 272271
300 S. Spring Street
Los Angeles, CA 90013
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants

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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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Plaintiff, DEFENDANTS’ RESPONSES AND
OBJECTIONS TO PLAINTIFF’S FIRST
SET OF INTERROGATORIES

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Case No. 2:18-cv-00490-JAM-KJN

THE UNITED STATES OF AMERICA,

v.

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THE STATE OF CALIFORNIA; EDMUND
GERALD BROWN JR., Governor of
California, in his official capacity; and
XAVIER BECERRA, Attorney General of
California, in his official capacity,

Hearing Date:
Time:
Courtroom:
Judge:
Trial Date:
Action Filed:

June 20, 2018
10:00 a.m.
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Honorable John A. Mendez
None Set
March 6, 2018

Defendants.

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PROPOUNDING PARTY:

Plaintiff UNITED STATES OF AMERICA

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RESPONDING PARTY:

Defendants STATE OF CALIFORNIA, EDMUND
G. BROWN JR., XAVIER BECERRA

SET NUMBER:

ONE

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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

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Under Rules 26 and 33 of the Federal Rules of Civil Procedure, Eastern District of

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California Civil Local Rule 250.2, and the Court Order dated May 24, 2018, ECF No. 158

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(May 24 Court Order), Defendants State of California, Edmund G. Brown Jr., Governor of

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California in his official capacity, and Xavier Becerra, Attorney General of California in his

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official capacity (collectively, “California”), by and through their attorneys of record, hereby

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responds and objects to Plaintiff’s First Set of Interrogatories.

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PRELIMINARY STATEMENT AND OBJECTIONS TO INSTRUCTIONS AND

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DEFINITIONS

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1.

Defendants State of California, Edmund G. Brown Jr., and Xavier Becerra

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(collectively, “California”) object to the United States’ First Set of Interrogatories

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(“Interrogatories”), sent to California following the May 24 Court Order, to the extent that the

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Interrogatories are different from the interrogatories that the Court considered when issuing the

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Court Order.

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2.

California’s objections and responses to the Interrogatories are made on the basis of

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facts and circumstances as they presently are known to California. California’s attorneys of

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record have not yet completed their investigation, discovery, or analysis of the matters raised by

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this action. Accordingly, all of the following responses are provided without prejudice to

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California’s right to introduce at the hearing on the motion for preliminary injunction or at trial

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any evidence that is subsequently discovered relating to proof of presently known facts, and to

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produce and introduce all evidence, whenever discovered, relating to proof of subsequently

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discovered facts. The responses are all based upon information and documents that have been

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found after reasonable search and diligent inquiry. California reserves the right to amend or

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supplement these responses.

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3.

California’s objections and responses are based on its understanding and

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interpretation of the Interrogatories. If Plaintiff understands or interprets the Interrogatories

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differently, California reserves the right to supplement any of its objections or responses.

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4.

California objects that these Interrogatories purportedly are propounded under Rule

34 of the Federal Rule of Civil Procedure which governs the production of documents, and not
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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

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interrogatories. The May 24 Court Order did not require California to produce any documents in

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connection with these Interrogatories. California will respond to these Interrogatories consistent

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with Rule 33 of the Federal Rules of Civil Procedure.

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5.

California objects to Instruction No. 2 on the grounds that the request for

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“information” that “was created” or “has been used or has been in effect” between January 1,

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2018 and the present is vague, overbroad, and unduly burdensome, and is not proportional to the

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needs of the case or the issue of Plaintiff’s purported basis for asserting irreparable harm in its

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motion for a preliminary injunction. California further objects to the extent that the “information”

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that “was created” or “has been used or has been in effect,” which the United States seeks in

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response to each Interrogatory, is information protected by the attorney-client privilege, the

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attorney work-product doctrine, the deliberative process privilege, or any other applicable

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privilege. California also objects to Instruction No. 2 on the grounds that it seeks “information”

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from before the effective date of Senate Bill 54 (SB 54), which was January 4, 2018. Subject to

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and without waiving any of its foregoing objections, California will limit its response to its

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interpretation of California Government Code section 7284.6(a)(1)(C), which has been in effect

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since January 4, 2018.

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6.

California objects to the definition of the term “Document” on the grounds that it is

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overbroad and unduly burdensome. California further objects that it seeks documents that are not

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relevant to the subject matter of the case. In addition, it seeks documents that are not proportional

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to the needs of this case, Plaintiff’s purported basis for asserting irreparable harm in its motion for

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preliminary injunction, or the abbreviated expedited discovery period. To the extent that the

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definition of the term “Document” is broader than provided in the Federal Rules of Civil

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Procedure, California will incorporate the term “Document” in accordance with the Federal Rules

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of Civil Procedure. California further objects to the definition of the term “Document” as

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inconsistent with the May 24 Court Order, which did not require California to produce any

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documents. To the extent the definition incorporates the overbroad and unduly burdensome

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definition of “California Law Enforcement Agency,” California’s below objections to that

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definition are incorporated here as well. Moreover, California does not have possession, custody,
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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

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or control of documents as those terms are used in the Federal Rules of Civil Procedure, for all

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California law enforcement agencies due only to the supervision and authority provisions set out

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in the California Constitution article V, section 13 and California Penal Code section 13020.

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Those provisions are unconnected to the requirements of the Federal Rules of Civil Procedure and

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its purposes, and they do not take into account any of the requirements of those rules, including

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that all discovery be relevant, not unduly burdensome or overbroad, and proportional.

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7.

California objects to the definition of the term “Communication” as vague,

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ambiguous, overly broad, unduly burdensome, and not relevant. In addition, the definition is not

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proportional to the needs of the case, Plaintiff’s purported basis for asserting irreparable harm in

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its motion for preliminary injunction, or the abbreviated expedited discovery period. Further, it is

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beyond the scope of the requirements of the Federal Rules of Civil Procedure and the Local Rules

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of this Court.

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8.

California objects to the definition of “California” or “State” on the grounds that it is

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overbroad and unduly burdensome, includes matters not relevant to any party’s claim or defense.

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In addition, it is not proportional to the needs of the case, Plaintiff’s purported basis for asserting

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irreparable harm in its motion for preliminary injunction, or the abbreviated expedited discovery

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period. California further objects to the definition of “California” or “State” as encompassing

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state entities that are not parties to this litigation. See People ex. rel. Lockyer v. Superior Court,

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122 Cal. App. 4th 1060, 1078 (Cal. Ct. App. 2004) (holding that by bringing an action on behalf

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of the People, the People are not deemed to have possession, custody, or control of documents or

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information from any state agency).

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9.

California objects to the definition of “California Law Enforcement Agency” to the

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extent that Plaintiff requests California to produce information and documents that are not in its

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possession, custody, or control. California also objects to the extent that the definition includes

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matters not relevant to any party’s claim or defense and not proportional to the needs of the case,

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Plaintiff’s purported basis for asserting irreparable harm in its motion for preliminary injunction,

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or the abbreviated expedited discovery period. This definition purports to encompass hundreds of

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California law enforcement agencies that exist in the State, irrespective of whether they are state
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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

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or local law enforcement. Information and documents pertaining to every California law

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enforcement agency are not in Defendants’ possession, custody, or control. Requesting

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information from every state and local law enforcement agency in the entire state is not

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proportional to the needs of the case or Plaintiff’s purported basis for asserting irreparable harm

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in its motion for preliminary injunction. Nor does it include matters relevant to any claims, and it

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is extraordinarily overbroad and unduly burdensome.

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10.

California objects to the definition of “Detainer Request” on the grounds that it is

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overbroad and unduly burdensome. It also includes matters not relevant to any party’s claim or

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defense or Plaintiff’s purported basis for asserting irreparable harm in its motion for preliminary

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injunction. And it is not proportional to the needs of the case and the abbreviated expedited

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discovery period. The definition is unduly burdensome and overbroad in that it implies a vague

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and ambiguous time period, which is also irrelevant to the claims and defenses in this litigation.

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SB 54 was not effective until January 4, 2018, and therefore, the relevant and proportional time

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period does not encompass the time period before the effective date of SB 54, and cannot

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encompass the predecessor Department of Homeland Security (DHS) forms, including DHS

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Form 1-247D, DHS Form I-247N, and DHS Form I-247X, which were used before the current

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DHS Form I-247A. Moreover, Plaintiff has not challenged the provision in SB 54 that prohibits

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detaining an individual on the basis of a hold request (“detainer request”), which California

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understands are or were requested in DHS Forms I-247A or I-247D, and thus is not at issue in this

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litigation. Further, Plaintiff’s Interrogatories concern California Government Code section

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7284.6(a)(1)(C), which does not involve a request to transfer a person to immigration authorities

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(“transfer request”). California understands transfer requests are or were made in DHS Forms I-

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247A or I-247X, and are not relevant for purposes of responding to these Interrogatories. Subject

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to and without waiving any of its foregoing objections, California will limit its response to its

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interpretation of “Detainer Request” to encompass the request made on DHS Form I-247A to

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“[n]otify DHS as early as practicable (at least 48 hours if possible)” before a person is released

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from custody, and the request to law enforcement agencies to provide information at the bottom

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of said form.
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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

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11.

These objections to the definitions are applicable to each and every one of the

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following answers and objections, and failure to repeat an objection in response to a specific

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Interrogatory shall not be deemed a waiver of the objection. Repetition of one or more of these

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objections in response to a specific Interrogatory shall not be a waiver of other applicable

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objections.

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INTERROGATORIES
INTERROGATORY NO. 1:
State whether, in Defendants’ view, California Law Enforcement Agency may establish a
policy of sharing an individual’s release date, as soon as it becomes available, with federal

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immigration authorities, consistent with Section 7284.6(a)(1)(C) of the California Government

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Code and Parts III.1.C and III.2.B.i of Information Bulletin 2018-DLE-01. If your answer would

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vary depending on the circumstances, please explain.

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RESPONSE TO INTERROGATORY NO. 1:

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In addition to the foregoing objections, California objects to this Interrogatory because the

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terms and phrases “policy” and “as soon as it becomes available,” are vague, ambiguous, or

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otherwise undefined, and require California to speculate about the intended meaning of those

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terms and phrases. California also objects to the Interrogatory to the extent it seeks or purports to

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place a burden on the State greater than that imposed by applicable laws and rules, including but

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not limited to the Federal Rules of Civil Procedure, the Local Rules of this Court, and the May 24

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Court Order. Further, to the extent the Interrogatory seeks California’s contention regarding the

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scope of the statute in the abstract, it poses a question of pure law, and California is not required

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to respond to interrogatories raising questions of pure law, and objects on that basis. See

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AngioScore, Inc. v. TriReme Med., Inc., No. 12-cv-03393, 2014 WL 7188779, at *5 (N.D. Cal.

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Dec. 16, 2014) (“[I]nterrogatories directed to issues of ‘pure law’—i.e., abstract legal issues not

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dependent on the facts of the case are not permitted”) (citation and some internal punctuation

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omitted); see also Everest Nat’l Ins. Co. v. Santa Cruz Cty. Bank, No. 15-cv-02085, 2016 WL

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6311876, *4 (N.D. Cal. Oct. 28, 2016) (denying motion to compel interrogatory response where

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“party asking for legal argument without a direct connection to the facts of th[e] case”).
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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

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California also objects to the extent that the Interrogatory seeks additional information regarding

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Information Bulletin 2018-DLE-01, which speaks for itself and is the best evidence of its

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contents.

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Subject to and without waiving any of its foregoing objections, California responds that

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California Government Code section 7284.6(a)(1)(C) states that: “California law enforcement

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agencies shall not: [u]se agency or department moneys or personnel to investigate, interrogate,

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detain, detect, or arrest persons for immigration enforcement purposes, including . . . [p]roviding

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information regarding a person’s release date or responding to requests for notification by

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providing release dates or other information unless that information is available to the public, or

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is in response to a notification request from immigration authorities in accordance with Section

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7282.5” (emphasis added). California Department of Justice’s Division of Law Enforcement

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Information Bulletin No. DLE-2018-01 (Law Enforcement Bulletin), issued March 28, 2018,

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states: “the phrase ‘available to the public’ refers to information where a law enforcement agency

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has a practice of making such information public, such as disclosing the information on its

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website or if it has a practice or policy of providing the information to individuals in response to

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specific requests. Law enforcement agencies should, in addition to ensuring compliance with the

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Values Act, take care to ensure that they comply with applicable state or federal privacy laws.”

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California also responds that the California Public Records Act, California Government Code

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section 6254(f)(1) generally authorizes the public disclosure of “the time and manner of release”

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so long as the disclosure would not “endanger the safety of a person involved in an investigation

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or would endanger the successful completion of the investigation or a related investigation.”

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Further responding, consistent with California Government Code section 7284.6(a)(1)(C)

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and the Information Bulletin, if a California Law Enforcement Agency has a practice of

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disclosing release dates to the public as soon as release dates become available, and the law

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enforcement agency is satisfied that the public disclosure of the information would not “endanger

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the safety of a person involved in an investigation or would endanger the successful completion

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of the investigation or a related investigation,” then the law enforcement agency’s disclosure of

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release dates to immigration authorities would not violate SB 54. For example, if the California
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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

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Law Enforcement Agency has a practice of posting release dates on a website as soon as they

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become available, that law enforcement agency may then share a person’s release dates with

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immigration authorities after posting the release date on a website without violating SB 54.

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However, a California Law Enforcement Agency may not disclose release dates to immigration

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authorities as soon as that information becomes available if the information is not available to the

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public or the circumstances described in California Government Code section 7282.5 do not

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apply.

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INTERROGATORY NO. 2:

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State whether, in Defendants’ view, the phrase “or other information,” as used in Section

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7284.6(a)(1)(C) of the California Government Code, includes information other than “release

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dates,” such as information concerning an individual’s identity or home address information

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requested at the bottom of a Detainer Request in the section titled “To Be Completed by the Law

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Enforcement Agency,” or specific information regarding where and how that individual will be

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exiting a California Law Enforcement’s premises, including specific points of egress and whether

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the point of egress if open to the public or a secure location. If your answer would vary

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depending on the circumstances, please explain.

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RESPONSE TO INTERROGATORY NO. 2:

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In addition to the foregoing objections, California objects to this Interrogatory because the

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terms and phrases “specific information regarding where and how that individual will be exiting a

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California Law Enforcement’s premises,” “point[s] of egress,” “open to the public,” and “secure

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location” are vague, ambiguous, or otherwise undefined, and require California to speculate about

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the intended meaning of those terms and phrases. California further objects to the Interrogatory

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to the extent it seeks or purports to place a burden on the State greater than that imposed by

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applicable laws and rules, including but not limited to the Federal Rules of Civil Procedure, the

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Local Rules of this Court, and the May 24 Court Order. California also objects to the

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Interrogatory to the extent it seeks, during this expedited period, information concerning matters

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unrelated to (i) Plaintiff’s assertions of irreparable harm made in its Motion for Preliminary

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Injunction and Memorandum of Law in Support filed on March 6, 2018 (ECF No. 2-1), and (ii)
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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

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arguments that Defendants made to rebut Plaintiff’s claims of irreparable harm in Defendants’

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Opposition to Plaintiff’s Motion for Preliminary Injunction (ECF No. 74) where California did

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not use the term “other information.” In that manner, the interrogatory is overbroad and unduly

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burdensome. And it is not proportional to the needs of this case, Plaintiff’s purported basis for

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asserting irreparable harm in its motion for preliminary injunction, or the abbreviated expedited

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discovery period.

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Further, to the extent the Interrogatory seeks California’s contention regarding the scope of

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the statute in the abstract, it poses a question of pure law, and California is not required to

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respond to interrogatories raising questions of pure law, and objects on that basis. See

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AngioScore, Inc. v. TriReme Med., Inc., No. 12-cv-03393, 2014 WL 7188779, at *5 (N.D. Cal.

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Dec. 16, 2014) (“[I]nterrogatories directed to issues of ‘pure law’—i.e., abstract legal issues not

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dependent on the facts of the case are not permitted”) (citation and some internal punctuation

13

omitted); see also Everest Nat’l Ins. Co. v. Santa Cruz Cty. Bank, No. 15-cv-02085, 2016 WL

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6311876, *4 (N.D. Cal. Oct. 28, 2016) (denying motion to compel interrogatory response where

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“party asking for legal argument without a direct connection to the facts of th[e] case”).

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California further objects to this Interrogatory on the grounds that it is not consistent with

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the May 24 Court Order. The Court Order expressly provided “at this juncture” that “California

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need not provide a further definition of ‘or other information,’” as used in California Government

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Code section 7284.6(a)(1)(C), beyond as outlined in the Court Order and limited at the May 24

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conference with the Court. Therefore, California will limit its response to address the information

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identified in the May 24 Court Order, but will not respond to whether “information concerning an

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individual’s identity,” as that term is defined in the Interrogatories and “home address

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information” is “other information” as used in California Government Code section

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7284.6(a)(1)(C). California also objects to Plaintiff’s characterization that “information

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concerning an individual’s identity,” as that term is defined in the Interrogatories and “home

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address information” is “information requested at the bottom of a Detainer Request in the section

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titled ‘To Be Completed by the Law Enforcement Agency.’” A person’s home address, home

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telephone number, present or last known employer, and date or place of birth are not requested on
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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

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the DHS Form I-247A. See https://www.ice.gov/sites/default/files/documents/Document/2017/I-

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247A.pdf.

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California further objects to the Interrogatory on the grounds that Plaintiff modified this

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Interrogatory after the Court issued the May 24 Order, so Plaintiff is seeking to require California

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to respond to an Interrogatory that did not form the basis of the Court’s Order. California will

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limit its response to address the information identified in the May 24 Court Order. California

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further objects to Plaintiff’s attempt to dictate the language of California’s response to the

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Interrogatory. California will furnish an appropriate and relevant answer subject to these

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objections that complies with the Federal Rules of Civil Procedure.

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Subject to and without waiving any of its foregoing objections, California responds that

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“other information” as that term is used in California Government Code section 7284.6(a)(1)(C)

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includes the information requested on the DHS Form I-247A, consisting of the “Local

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Booking/Inmate #,” “Estimated release date/time,” “Date of latest criminal charge/conviction,”

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and “Last offense charged/conviction.” Further responding, “other information” as that term is

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used in California Government Code section 7284.6(a)(1)(C) includes “the specific location of

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release at the jail or facility (such as the front door, back door, holding area, etc.), including

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whether the location is inside or outside the jail/facility and whether the location is open to the

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public.” See May 24 Court Order at 2.

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INTERROGATORY NO. 3:

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State whether, in Defendants’ view, Section 7284.6(a)(1)(C) of the California Government

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Code, as further defined by Parts III.1.C and III.2.B.i of Information Bulletin 2018-DLE-01,

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would permit an a [sic] California Law Enforcement Agency to establish a practice or policy of

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providing information concerning “release dates” or “other information” as described in response

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to Interrogatory 2 to federal immigration authorities in response to specific requests for such

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information from individuals.

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RESPONSE TO INTERROGATORY NO. 3:

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In addition to the foregoing objections, California objects to this Interrogatory because the
terms and phrases “an a [sic] California Law Enforcement Agency,” “practice or policy,” and
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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

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“concerning ‘release dates’ or ‘other information’” are vague, ambiguous, or otherwise

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undefined, and require California to speculate about the intended meaning of those terms and

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phrases. California further objects to the Interrogatory to the extent it seeks or purports to place a

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burden on the State greater than that imposed by applicable laws and rules, including but not

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limited to the Federal Rules of Civil Procedure, the Local Rules of this Court, and the May 24

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Court Order. California also objects to the Interrogatory to the extent it seeks, during this

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expedited period, information concerning matters unrelated to (i) Plaintiff’s assertions of

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irreparable harm made in its Motion for Preliminary Injunction and Memorandum of Law in

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Support filed on March 6, 2018 (ECF No. 2-1), and (ii) arguments that Defendants made to rebut

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Plaintiff’s claims of irreparable harm in Defendants’ Opposition to Plaintiff’s Motion for

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Preliminary Injunction (ECF No. 74), where California did not use the term “other information.”

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In that manner, the Interrogatory is overbroad and unduly burdensome. And it is not proportional

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to the needs of this case, Plaintiff’s purported basis for asserting irreparable harm in its motion for

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preliminary injunction, or the abbreviated expedited discovery period.

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Further, to the extent the Interrogatory seeks California’s contention regarding the scope of

16

the statute in the abstract, it poses a question of pure law, and California is not required to

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respond to interrogatories raising questions of pure law, and objects on that basis. See

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AngioScore, Inc. v. TriReme Med., Inc., No. 12-cv-03393, 2014 WL 7188779, at *5 (N.D. Cal.

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Dec. 16, 2014) (“[I]nterrogatories directed to issues of ‘pure law’—i.e., abstract legal issues not

20

dependent on the facts of the case are not permitted”) (citation and some internal punctuation

21

omitted); see also Everest Nat’l Ins. Co. v. Santa Cruz Cty. Bank, No. 15-cv-02085, 2016 WL

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6311876, *4 (N.D. Cal. Oct. 28, 2016) (denying motion to compel interrogatory response where

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“party asking for legal argument without a direct connection to the facts of th[e] case”).

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California also objects to the extent that the Interrogatory seeks additional information regarding

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Information Bulletin 2018-DLE-01, which speaks for itself and is the best evidence of its

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contents. California also objects to the Interrogatory on the grounds that it seeks duplicative

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information sought in Interrogatory No. 1, and thus, California incorporates its response and

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objections to that Interrogatory here.
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Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

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California further objects to this Interrogatory on the grounds that it incorporates

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information sought in Interrogatory No. 2, which as discussed above, is an Interrogatory that is

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inconsistent with the May 24 Court Order. The Court Order expressly provided “at this juncture”

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that “California need not provide a further definition of ‘or other information,’” as used in

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California Government Code section 7284.6(a)(1)(C), beyond as outlined in the Court Order and

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limited at the May 24 conference with the Court. Therefore, California will limit its response to

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address only the information identified in the May 24 Court Order, but will not respond to this

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Interrogatory to the extent it seeks whether “information concerning an individual’s identity,” as

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that term is defined in the Interrogatories, and “home address information” is “other information”

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as used in California Government Code section 7284.6(a)(1)(C). Moreover, to the extent that this

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Interrogatory incorporates Interrogatory No. 2, California objects to Plaintiff’s characterization

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that “information concerning an individual’s identity,” as that term is defined in the

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Interrogatories and “home address information” is “Information requested at the bottom of a

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Detainer Request in the section titled “To Be Completed by the Law Enforcement Agency.” A

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person’s home address, home telephone number, present or last known employer, and date or

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place of birth are not requested on the DHS Form I-247A. See

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https://www.ice.gov/sites/default/files/documents/Document/2017/I-247A.pdf. California also

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objects to the Interrogatory on the grounds that it incorporates Interrogatory No. 2, and Plaintiff

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modified that Interrogatory after the Court issued the May 24 Order, so Plaintiff is seeking to

20

require California to respond to an Interrogatory that did not form the basis of the Court’s Order.

21

California will limit its response to address the information identified in the May 24 Court Order.

22

Subject to and without waiving any of its foregoing objections, California responds that

23

California Government Code section 7284.6(a)(1)(C) states that: “California law enforcement

24

agencies shall not [u]se agency or department moneys or personnel to investigate, interrogate,

25

detain, detect, or arrest persons for immigration enforcement purposes, including . . . [p]roviding

26

information regarding a person’s release date or responding to requests for notification by

27

providing release dates or other information unless that information is available to the public, or

28

is in response to a notification request from immigration authorities in accordance with Section
11
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

7282.5” (emphasis added). California Department of Justice’s Division of Law Enforcement

2

Information Bulletin No. DLE-2018-01 (Law Enforcement Bulletin), issued March 28, 2018,

3

states: “the phrase ‘available to the public’ refers to information where a law enforcement agency

4

has a practice of making such information public, such as disclosing the information on its

5

website or if it has a practice or policy of providing the information to individuals in response to

6

specific requests. Law enforcement agencies should, in addition to ensuring compliance with the

7

Values Act, take care to ensure that they comply with applicable state or federal privacy laws.”

8

California also responds that the California Public Records Act, California Government Code

9

section 6254(f)(1) generally authorizes the public disclosure of “the time and date of arrest,” “the

10

time and date of booking,” “the factual circumstances surrounding the arrest,” “the time and

11

manner of release or the location where the individual is currently being held,” and “all charges

12

the individual is being held upon, including any outstanding warrants from other jurisdictions and

13

parole or probation holds,” so long as the public disclosure would not “endanger the safety of a

14

person involved in an investigation or would endanger the successful completion of the

15

investigation or a related investigation.”

16

Further responding, consistent with California Government Code section 7284.6(a)(1)(C)

17

and the Information Bulletin, if a California Law Enforcement Agency has a practice of

18

disclosing release dates or “other information,” as limited in California’s response to

19

Interrogatory No. 2, in response to specific requests from members of the public, and the law

20

enforcement agency is satisfied that the public disclosure of the information would not “endanger

21

the safety of a person involved in an investigation or would endanger the successful completion

22

of the investigation or a related investigation,” then the law enforcement agency may similarly

23

disclose release dates or “other information,” in compliance with SB 54, as limited in California’s

24

response to Interrogatory No. 2, to federal immigration authorities. Moreover, California Law

25

Enforcement Agencies are permitted to provide criminal history information to federal

26

immigration authorities regardless of whether the information is available to the public, California

27

Government Code section 7284.6(b)(2), so a California Law Enforcement Agency is not

28

restricted, in any way, from providing to federal immigration authorities the “Date of latest
12
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

criminal charge/conviction” and “Last offense charged/conviction” information requested on a

2

DHS Form I-247A. However, a California Law Enforcement Agency may not disclose release

3

dates or “other information” to immigration authorities in response to specific requests from

4

federal immigration authorities, if the information is not available to the public, the California

5

Law Enforcement Agency does not have a policy or practice of providing such information in

6

response to specific requests made by members of the public, the information is not criminal

7

history information, or the circumstances described in California Government Code

8

section 7282.5 do not apply.

9

INTERROGATORY NO. 4:

10

State whether, in Defendants’ view, providing federal immigration authorities information

11

in response to a Notification Request contained in a Detainer Request constitutes “providing the

12

information to individuals in response to specific requests,” as that phrase is used in Information

13

Bulletin 2018-DLE-01.

14

RESPONSE TO INTERROGATORY NO. 4:

15

In addition to the foregoing objections, California objects to the Interrogatory to the extent it

16

seeks or purports to place a burden on the State greater than that imposed by applicable laws and

17

rules, including but not limited to the Federal Rules of Civil Procedure, the Local Rules of this

18

Court, and the May 24 Court Order. Further, to the extent the Interrogatory seeks California’s

19

contention regarding the scope of the statute in the abstract, it poses a question of pure law, and

20

California is not required to respond to interrogatories raising questions of pure law, and objects

21

on that basis. See AngioScore, Inc. v. TriReme Med., Inc., No. 12-cv-03393, 2014 WL 7188779,

22

at *5 (N.D. Cal. Dec. 16, 2014) (“[I]nterrogatories directed to issues of ‘pure law’—i.e., abstract

23

legal issues not dependent on the facts of the case are not permitted”) (citation and some internal

24

punctuation omitted); see also Everest Nat’l Ins. Co. v. Santa Cruz Cty. Bank, No. 15-cv-02085,

25

2016 WL 6311876, *4 (N.D. Cal. Oct. 28, 2016) (denying motion to compel interrogatory

26

response where “party asking for legal argument without a direct connection to the facts of th[e]

27

case”). California also objects to the extent that the Interrogatory seeks California to provide

28

additional information regarding Information Bulletin 2018-DLE-01, which speaks for itself and
13
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

is the best evidence of its contents. California also objects to the Interrogatory on the grounds

2

that it seeks duplicative information sought in Interrogatory No. 3, and thus, California

3

incorporates its response and objections to that Interrogatory here.

4

Subject to and without waiving any of its foregoing, California responds that consistent with

5

California Government Code section 7284.6(a)(1)(C) and the Information Bulletin, if a California

6

Law Enforcement Agency has a practice of disclosing information requested in the current DHS

7

Form I-247A, in response to specific requests by members of the public, as described in response

8

to Interrogatory Nos. 2 and 3, then SB 54 would not bar the law enforcement agency from

9

similarly disclosing that same information to federal immigration authorities in response to the

10

currently existing DHS Form I-247A (i.e., Notification Request). However, a California Law

11

Enforcement Agency may not respond to requests for information on the DHS Form I-247A if the

12

information is not available to the public, the California Law Enforcement Agency does not have

13

a policy or practice of providing such information in response to specific requests made by

14

members of the public, the information is not criminal history information, or the circumstances

15

described in California Government Code section 7282.5 do not apply.

16

INTERROGATORY NO. 5:

17

State whether, in Defendants’ view, California Law Enforcement Agency that did not

18

previously, prior to January 1, 2018 have a practice or policy of disclosing information

19

concerning an individual’s release date or other information concerning such individuals on its

20

website or providing the information to individuals in response to specific requests, could

21

implement such a practice or policy after January 1, 2018.

22

RESPONSE TO INTERROGATORY NO. 5:

23

In addition to the foregoing objections, California objects to this Interrogatory because the

24

terms and phrases “practice or policy,” “concerning an individual’s release date or other

25

information concerning such individuals,” and “implement” are vague, ambiguous, or otherwise

26

undefined, and require California to speculate about the intended meaning of those terms and

27

phrases. California also objects to the Interrogatory to the extent it seeks or purports to place a

28

burden on the State greater than that imposed by applicable laws and rules, including but not
14
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

limited to the Federal Rules of Civil Procedure, the Local Rules of this Court, and the May 24

2

Court Order. Further, to the extent the Interrogatory seeks California’s contention regarding the

3

scope of the statute in the abstract, it poses a question of pure law, and California is not required

4

to respond to interrogatories raising questions of pure law, and objects on that basis. See

5

AngioScore, Inc. v. TriReme Med., Inc., No. 12-cv-03393, 2014 WL 7188779, at *5 (N.D. Cal.

6

Dec. 16, 2014) (“[I]nterrogatories directed to issues of ‘pure law’—i.e., abstract legal issues not

7

dependent on the facts of the case are not permitted”) (citation and some internal punctuation

8

omitted); see also Everest Nat’l Ins. Co. v. Santa Cruz Cty. Bank, No. 15-cv-02085, 2016 WL

9

6311876, *4 (N.D. Cal. Oct. 28, 2016) (denying motion to compel interrogatory response where

10

“party asking for legal argument without a direct connection to the facts of th[e] case”).

11

California also objects to the Interrogatory to the extent it implies that the effective date of

12

California Government Code section 7284.6(a)(1)(C) is January 1, 2018. California will limit its

13

response to whether a California Law Enforcement Agency changed its policy or practice after

14

January 4, 2018, which was the effective date of California Government Code section

15

7284.6(a)(1)(c). California also objects to the Interrogatory on the grounds that it seeks

16

duplicative information sought in Interrogatory Nos. 3 and 4, and thus, California incorporates its

17

response and objections to those Interrogatories here.

18

Subject to and without waiving any of its foregoing objections, California responds that

19

consistent with California Government Code section 7284.6(a)(1)(C) and the Information

20

Bulletin, a California Law Enforcement Agency that did not have a practice or policy of

21

disclosing release dates or other information to the public may implement a policy or practice

22

after January 4, 2018 of disclosing release date information or “other information,” as limited in

23

California’s response to Interrogatory No. 2, to the public on its website or in response to specific

24

requests by members of the public.

25

INTERROGATORY NO. 6:

26

State whether, in Defendants’ view, Section 7284.6(a)(1)(C) of the California Government

27

Code, as further defined by Parts III.1.C and III.2.B.i of Information Bulletin 2018-DLE-01,

28

would permit an a California Law Enforcement Agency to establish a practice or policy of
15
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

notifying federal immigration authorities that an individual subject to a Notification Request

2

contained in a Detainer Request is scheduled for release, and to inform federal immigration

3

authorities of the specific time and location an individual will exit a California Law Enforcement

4

Agency’s premises.

5

RESPONSE TO INTERROGATORY NO. 6:

6

In addition to the foregoing objections, California objects to this Interrogatory because the

7

terms and phrases “an a California Law Enforcement Agency,” “practice or policy,” “scheduled

8

for release” and “California Law Enforcement Agency’s premises” are vague, ambiguous, or

9

otherwise undefined, and require California to speculate about the intended meaning of those

10

terms and phrases. California also objects to the Interrogatory to the extent it seeks or purports to

11

place a burden on the State greater than that imposed by applicable laws and rules, including but

12

not limited to the Federal Rules of Civil Procedure, the Local Rules of this Court, and the May 24

13

Court Order. Further, to the extent the Interrogatory seeks California’s contention regarding the

14

scope of the statute in the abstract, it poses a question of pure law, and California is not required

15

to respond to interrogatories raising questions of pure law, and objects on that basis. See

16

AngioScore, Inc. v. TriReme Med., Inc., No. 12-cv-03393, 2014 WL 7188779, at *5 (N.D. Cal.

17

Dec. 16, 2014) (“[I]nterrogatories directed to issues of ‘pure law’—i.e., abstract legal issues not

18

dependent on the facts of the case are not permitted”) (citation and some internal punctuation

19

omitted); see also Everest Nat’l Ins. Co. v. Santa Cruz Cty. Bank, No. 15-cv-02085, 2016 WL

20

6311876, *4 (N.D. Cal. Oct. 28, 2016) (denying motion to compel interrogatory response where

21

“party asking for legal argument without a direct connection to the facts of th[e] case”).

22

California also objects to the extent that the Interrogatory seeks California to provide additional

23

information regarding Information Bulletin 2018-DLE-01, which speaks for itself and is the best

24

evidence of its contents. California also objects to the Interrogatory on the grounds that it seeks

25

duplicative information sought in Interrogatory Nos. 1, 3 and 4, and thus, California incorporates

26

its response and objections to those Interrogatories here.

27
28

Subject to and without waiving any of its foregoing objections, consistent with California
Government Code section 7284.6(a)(1)(C) and the Information Bulletin, if a California Law
16
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

Enforcement Agency has a practice of disclosing specific release dates, time, and location to the

2

public in response to specific requests, then the law enforcement agency may similarly disclose

3

such information to federal immigration authorities, whether in response to a DHS Form I-247A

4

(i.e. Notification Request) or other specific requests. For example, if the California Law

5

Enforcement Agency has a practice of posting release dates, times, and location, SB 54 does not

6

preclude that California Law Enforcement Agency from then sharing a person’s release date,

7

time, and location with federal immigration authorities after posting such information on a

8

website. However, a California Law Enforcement Agency may not disclose release dates, times,

9

and location to immigration authorities if the information is not available to the public or the

10

circumstances described in California Government Code section 7282.5 do not apply.

11

INTERROGATORY NO. 7:

12

State whether, in Defendants’ view, Section 7284.6(a)(1)(C) of the California Government

13

Code, as further defined by Parts III.1.C and III.2.B.i of Information Bulletin 2018-DLE-01,

14

would permit a California Law Enforcement Agency to establish a practice or policy of notifying

15

federal immigration authorities that an individual subject to a Notification Request contained in a

16

Detainer Request is scheduled for release, and to permit federal immigration authorities to take

17

custody of the individual anywhere on the California Law Enforcement Agency’s premises.

18

RESPONSE TO INTERROGATORY NO. 7:

19

In addition to the foregoing objections, California objects to this Interrogatory because the

20

terms and phrases “practice or policy” and “scheduled for release” are vague, ambiguous, or

21

otherwise undefined, and require California to speculate about the intended meaning of those

22

terms and phrases. California further objects to the Interrogatory to the extent it seeks or purports

23

to place a burden on the State greater than that imposed by applicable laws and rules, including

24

but not limited to the Federal Rules of Civil Procedure, the Local Rules of this Court, and the

25

May 24 Court Order. California also objects to the Interrogatory to the extent it seeks, during this

26

expedited period, information concerning matters unrelated to (i) Plaintiff’s assertions of

27

irreparable harm made in its Motion for Preliminary Injunction and Memorandum of Law in

28

Support filed on March 6, 2018 (ECF No. 2-1), and (ii) arguments that Defendants made to rebut
17
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

Plaintiff’s claims of irreparable harm in Defendants’ Opposition to Plaintiff’s Motion for

2

Preliminary Injunction (ECF No. 74). In that manner, the Interrogatory is overbroad and unduly

3

burdensome. And it is not proportional to the needs of this case, Plaintiff’s purported basis for

4

asserting irreparable harm in its motion for preliminary injunction, or the abbreviated expedited

5

discovery period.

6

Further, to the extent the Interrogatory seeks California’s contention regarding the scope of

7

the statute in the abstract, it poses a question of pure law, and California is not required to

8

respond to interrogatories raising questions of pure law, and objects on that basis. See

9

AngioScore, Inc. v. TriReme Med., Inc., No. 12-cv-03393, 2014 WL 7188779, at *5 (N.D. Cal.

10

Dec. 16, 2014) (“[I]nterrogatories directed to issues of ‘pure law’—i.e., abstract legal issues not

11

dependent on the facts of the case are not permitted”) (citation and some internal punctuation

12

omitted); see also Everest Nat’l Ins. Co. v. Santa Cruz Cty. Bank, No. 15-cv-02085, 2016 WL

13

6311876, *4 (N.D. Cal. Oct. 28, 2016) (denying motion to compel interrogatory response where

14

“party asking for legal argument without a direct connection to the facts of th[e] case”).

15

California also objects to the extent that the Interrogatory seeks California to provide additional

16

information regarding Information Bulletin 2018-DLE-01, which speaks for itself and is the best

17

evidence of its contents. California also objects to the Interrogatory on the grounds that it seeks

18

duplicative information sought in Interrogatory Nos. 1, 3, 4, and 6, and thus, California

19

incorporates its response and objections to those Interrogatories here. California further objects

20

to this Interrogatory as compound and containing multiple discrete subparts, and therefore counts

21

this “Interrogatory” as two toward the number of Interrogatories that Plaintiff is allowed under

22

Federal Rule of Civil Procedure 33(a)(1).

23

Subject to and without waiving any of its foregoing objections, consistent with California

24

Government Code section 7284.6(a)(1)(C) and the Information Bulletin, California responds that

25

if a California Law Enforcement Agency has a practice of disclosing a person’s release date to

26

members of the public in response to specific requests, then the law enforcement agency may

27

similarly disclose such information to federal immigration authorities, whether in response to a

28

DHS Form I-247A (i.e. Notification Request) or other specific requests. However, a California
18
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

Law Enforcement Agency may not disclose a person’s release date to immigration authorities if

2

the information is not available to the public or the circumstances described in California

3

Government Code section 7282.5 do not apply.

4

Further responding, California states that SB 54, which amended Section 7282 and 7282.5

5

of, and added Chapter 17.25 (commencing with Section 7284) to Division 7 of Title 1 of, the

6

California Government Code, which was chaptered on October 5, 2017, and which became

7

effective January 4, 2018, regulates California Law Enforcement Agencies, not federal

8

immigration authorities. No provision of SB 54 regulates federal immigration authorities in how

9

they may take custody of a person. However, California Government Code section 7284.6(a)(4)

10

requires California Law Enforcement Agencies not to “[u]se agency or department moneys or

11

personnel to investigate, interrogate, detain, or arrest persons for immigration enforcement

12

purposes, including . . . [t]ransfer[ing] an individual to immigration authorities unless authorized

13

by a judicial warrant or judicial probable cause determination, or in accordance with Section

14

7282.5.” Therefore, while SB 54 may not preclude a California Law Enforcement Agency from

15

disclosing a person’s release date to immigration authorities, if that information is available to the

16

public, the California Law Enforcement Agency shall not otherwise use its resources to assist in

17

transferring a person into the custody of immigration authorities unless the immigration authority

18

presents a judicial warrant or judicial probable cause determination, as those terms are defined in

19

Government Code sections 7284.4(h) and (i), or California Government Code section 7282.5(a)

20

applies.

21

INTERROGATORY NO. 8:

22

State whether, in Defendants’ view, if a California Law Enforcement Agency has a practice

23

or policy pursuant to Section 7284.6(a)(1)(C) of the California Government Code, as further

24

defined by Parts III.1.C and III.2.B.i of Information Bulletin 2018-DLE-01, of making

25

information concerning an individual’s release date public, such as disclosing the information on

26

its website or by providing the information in response to specific requests, federal immigration

27

authorities may take custody of such an individual on a California Law Enforcement Agency’s

28
19
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

premises. If your answer would vary depending on the circumstances, including whether the area

2

in question is open to the public, please explain.

3

RESPONSE TO INTERROGATORY NO. 8:

4

In addition to the foregoing objections, California objects to this Interrogatory because the

5

terms and phrases “practice or policy,” “making information concerning an individual’s release

6

date public,” and “California Law Enforcement Agency’s premises” are vague, ambiguous, or

7

otherwise undefined, and require California to speculate as to the intended meaning of those

8

terms and phrases. California further objects to the Interrogatory to the extent it seeks or purports

9

to place a burden on the State greater than that imposed by applicable laws and rules, including

10

but not limited to the Federal Rules of Civil Procedure, the Local Rules of this Court, and the

11

May 24 Court Order. California also objects to the Interrogatory to the extent it seeks, during this

12

expedited period, information concerning matters unrelated to (i) Plaintiff’s assertions of

13

irreparable harm made in its Motion for Preliminary Injunction and Memorandum of Law in

14

Support filed on March 6, 2018 (ECF No. 2-1), and (ii) arguments that Defendants made to rebut

15

Plaintiff’s claims of irreparable harm in Defendants’ Opposition to Plaintiff’s Motion for

16

Preliminary Injunction (ECF No. 74). In that manner, the interrogatory is overbroad and unduly

17

burdensome. And it is not proportional to the needs of this case, Plaintiff’s purported basis for

18

asserting irreparable harm in its motion for preliminary injunction, or the abbreviated expedited

19

discovery period.

20

Further, to the extent the Interrogatory seeks California’s contention regarding the scope of

21

the statute in the abstract, it poses a question of pure law, and California is not required to

22

respond to interrogatories raising questions of pure law, and objects on that basis. See

23

AngioScore, Inc. v. TriReme Med., Inc., No. 12-cv-03393, 2014 WL 7188779, at *5 (N.D. Cal.

24

Dec. 16, 2014) (“[I]nterrogatories directed to issues of ‘pure law’—i.e., abstract legal issues not

25

dependent on the facts of the case are not permitted”) (citation and some internal punctuation

26

omitted); see also Everest Nat’l Ins. Co. v. Santa Cruz Cty. Bank, No. 15-cv-02085, 2016 WL

27

6311876, *4 (N.D. Cal. Oct. 28, 2016) (denying motion to compel interrogatory response where

28

“party asking for legal argument without a direct connection to the facts of th[e] case”).
20
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

California also objects to the extent that the Interrogatory seeks California to provide additional

2

information regarding Information Bulletin 2018-DLE-01, which speaks for itself and is the best

3

evidence of its contents. California also objects to the Interrogatory on the grounds that it seeks

4

duplicative information sought in Interrogatory No 7, and thus, California incorporates its

5

response and objections to those Interrogatories here.

6

Subject to and without waiving any of its foregoing objections, consistent with California

7

Government Code section 7284.6(a)(1)(C) and the Information Bulletin, California responds that

8

Senate Bill No. 54 regulates California Law Enforcement Agencies, not federal immigration

9

authorities. No provision of SB 54 regulates federal immigration authorities in how they may

10

take custody of a person. However, under California Government code section 7284.6(a)(4), a

11

“California law enforcement agenc[y] shall not: [u]se agency or department moneys or personnel

12

to investigate, interrogate, detain, or arrest persons for immigration enforcement purposes,

13

including . . . [t]ransfer[ing] an individual to immigration authorities unless authorized by a

14

judicial warrant or judicial probable cause determination, or in accordance with Section 7282.5.”

15

Therefore, while SB 54 may not prevent a California Law Enforcement Agency from disclosing a

16

person’s release date to immigration authorities, if that information is available to the public, the

17

California Law Enforcement Agency shall not otherwise use its resources to transfer the person

18

into the custody of immigration authorities unless the immigration authority presents a judicial

19

warrant or judicial probable cause determination, as those terms are defined in California

20

Government Code section 7284.4(h) and (i), or California Government Code section 7282.5(a)

21

applies.

22
23
24
25
26
27
28
21
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)

1

Dated: June 1, 2018

Respectfully Submitted,

2

XAVIER BECERRA
Attorney General of California
THOMAS S. PATTERSON
Senior Assistant Attorney General
MICHAEL NEWMAN
SATOSHI YANAI
ANTHONY HAKL
Supervising Deputy Attorneys General
CHRISTINE CHUANG
CHEROKEE DM MELTON
MAUREEN C. ONYEAGBAKO

3
4
5
6
7
8

/s/ Lee I. Sherman
LEE I. SHERMAN
Deputy Attorneys General
Attorneys for the State of California

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
22
Defs’ Resps. & Objs. Pl.’s First Set Interrogs.

(18-cv-00490-JAM-KJN)