New York Immigration Coalition v. United States Immigration and Customs Enforcement et al

Filing 31

ORDER granting 30 JOINT LETTER MOTION for Extension of Time to File Status Letter. SO ORDERED. (Signed by Judge Paul G. Gardephe on 3/3/2020) (jca)

Case 1:18-cv-04376-PGG

Document 30

Filed 02/28/20

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U.S. Department of Justice
United States Attorney
Southern District of New York

86 Chambers Street, 3rd Floor
New York, New York 10007

February 28, 2020

BYECF
Hon. Paul G. Gardephe
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re:

New York Immigration Coalition v. U.S. Immigration & Customs
Enforcement, et al., No. 18 Civ. 4376 (PGG)

Dear Judge Gardephe:
I write on behalf of defendants U.S. Immigration and Customs Enforcement ("ICE") and
U.S. Customs and Border Protection ("CBP") (collectively, the "Government") and plaintiff
New York Immigration Coalition ("NYIC"), the parties in the above-referenced Freedom of
Information Act ("FOIA") case, to provide the joint letter due today under the schedule the
parties proposed in their letter dated January 31, 2020. Dkt. No. 29 (memo endorsed). In that
letter, the parties informed the Court that they were discussing a process by which the
Government would provide more detailed explanations of its claimed exemptions in an effort to
resolve all or part of this case consensually.1
The parties have since conferred and jointly propose the following next steps in this case.
By April 28, 2020, the Government will provide NYIC with a draft Vaughn index of 40 CBP
documents identified by NYIC, 15 ICE documents identified by NYIC, five documents that were
withheld in full by CBP (to be identified by the Government), and five documents that were
withheld in full by ICE (to be identified by the Government). To allow time for the Government
to complete this index, for NYIC to review it, and for the parties to confer as to its contents, the
parties respectfully propose that they submit a status letter to the Court by May 15, 2020.
The parties thank the Court for its consideration of this submission.

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! At this time, NYIC does not intend to challenge the adequacy of ICE's or CBP's searches for
records responsive to NYIC's FOIA requests.

Case 1:18-cv-04376-PGG

Document 30

Filed 02/28/20

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Respectfully,
GEOFFREY S. BERMAN
United States Attorney

By:

Isl Jennifer Jude
JENNIFER JUDE
Assistant United States Attorney
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Copy to {via ECF):
Terence Y. Leong, Esq.
Warren Haskel, Esq.

Counselfor Plaintiff