Mora-Villalpando v. US Immigration and Customs Enforcement et al

Filing 60

JOINT STATUS REPORT AND ORDER re 59 Joint Status Report. The parties will submit another joint status report within 60 days of the date of this order. Signed by Judge James L. Robart. (TH)

Case 2:18-cv-00655-JLR Document 59 Filed 04/03/20 Page 1 of 4

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The Honorable James L. Robart

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UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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Maria Mora-Villalpando,

CASE NO. C18-655-JLR

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Plaintiff,

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JOINT STATUS REPORT

v.

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U.S. Immigration and Customs Enforcement
16 and U.S. Customs and Border Protection,
and U.S. Citizenship and Immigration
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Services,
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Defendants.
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The parties hereby file this Joint Status Report as required by the Court’s Order on the

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parties’ previous joint status report (Dkt. #58). The Court ordered the parties to provide a joint

23 status report within sixty days concerning their progress with the Court’s rulings.
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With respect to the Second Request, U.S. Immigration and Customs Enforcement (“ICE”)

25 conducted a search of the Office of Principal Legal Advisor (“OPLA”) Case Management System
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(“OCMS PLAnet”) as ordered by the Court. The parties agreed to search terms on December 6,

28 2019. ICE has completed the searches in the OCMS PLAnet database using the keywords to which
JOINT STATUS REPORT
C18-655-JLR - 1

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
[phone]

Case 2:18-cv-00655-JLR Document 59 Filed 04/03/20 Page 2 of 4

1 the parties agreed and pulled records that fell within the relevant date range. ICE is currently
2 conducting a responsiveness review of the records. To the extent that any of the records are
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responsive, ICE will start processing and producing any responsive records on a rolling basis in

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April, with the first production being made by April 30, 2020.
In addition, U.S. Customs and Immigration Services (“USCIS”) will retrieve all files that

7 were ingested into the Enterprise Document Management System (“EDMS”) on or after January 20,
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2017 and contain at least one I-213 form. Once those files are retrieved, USCIS will search the I-

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213s that were created on or after January 20, 2017 for any of the search terms agreed upon by

11 plaintiff and USCIS. Once USCIS has conducted the search and determined what, if any, documents
12 are found and responsive to plaintiff’s request, then defense counsel will inform plaintiff’s counsel
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of when USCIS anticipates producing responsive records.

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To keep the Court apprised, the parties propose to provide the Court with another Joint Status

16 Report within 60 days of the Court’s order on this Joint Status Report, unless the Court orders
17 otherwise.
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Dated this 3rd day of April, 2020.

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/s/ Khaled Alrabe
.
Khaled Alrabe, NY Bar Reg. 5542311
(admitted pro hace vice)
National Immigration Project
of the National Lawyers Guild
89 South St. Suite 603
Boston, MA 02111
Ph.
[phone]
Em. [e-mail]

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/s/ Devin T. Theriot-Orr
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Devin T. Theriot-Orr, WSBA #33995
OPEN SKY LAW, PLLC

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JOINT STATUS REPORT
C18-655-JLR - 2

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
[phone]

Case 2:18-cv-00655-JLR Document 59 Filed 04/03/20 Page 3 of 4

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20415 72nd Ave. S., Ste. 110
Kent, WA 98032
Ph.
[phone]
Fax
[phone]
Em. [e-mail]

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BRIAN T. MORAN
United States Attorney

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s/ Brian C. Kipnis
BRIAN C. KIPNIS, CA SBA #105161

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s/ Sarah K. Morehead
SARAH K. MOREHEAD, WSBA #29680
Assistant United States Attorneys
Office of the United States Attorney
Suite 5220, United States Courthouse
700 Stewart Street
Seattle, Washington 98101-1271
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]

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JOINT STATUS REPORT
C18-655-JLR - 3

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
[phone]

Case 2:18-cv-00655-JLR Document 59 Filed 04/03/20 Page 4 of 4

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ORDER

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The parties will submit another joint status report within 60 days of the date of this
order.

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Dated this __7th__ day of ___April_________, 2020.

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A

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______________________

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James L. Robart
United States District Judge

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JOINT STATUS REPORT
C18-655-JLR - 4

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
[phone]