New York Office Washington, D.C.

Office
40 Rector Street, 5th Floor 1444 Eye Street, NW, 10th Floor
New York, NY 10006-1738 Washington, D.C. 20005

T 212.965.2200 T 202.682.1300
F 212.226.7592 F 202.682.1312

www.naacpldf.org

February 14, 2017

Via Regular and Electronic Mail (foia@hq.dhs.gov and ice-foia@dhs.gov)

Jonathan Cantor
Acting Chief Privacy Officer/Chief FOIA Officer
The Privacy Office
U.S. Department of Homeland Security
245 Murray Lane, SW
STOP-0655
Washington, DC 20528-0655

Catrina Pavlik-Keenan, FOIA Officer

Freedom of Information Act Office
500 12th Street, SW, Stop 5009
Washington, DC 20536-5009

Dear Mr. Cantor and Ms. Pavlik-Keenan:

On behalf of the NAACP Legal Defense and Educational Fund, Inc.(LDF), and in
response to recent immigration enforcement raids conducted by the Department of
Homeland Security (DHS), I request copies of the following documents pursuant to the
Freedom of Information Act, 5 U.S.C. 552:

Any and all policies, memoranda, and notices regarding immigration enforcement
priorities of DHS, including but not limited to the type of criminal activities targeted
by immigration officers and officials from January 1, 2016 to the present.

Any and all statistical information concerning routine enforcement actions or raids,
including any roadway checkpoints, conducted by the Immigration and Customs
Enforcement (ICE) agency nationwide, including in states such as Georgia, Illinois,
Florida, North Carolina, South Carolina, New York, and Texas from January 1, 2017
to the present. Kindly disaggregate this information by city and state of action, date
of action, reason for action, and number, gender, age, criminal background, and race,
ethnicity and national origin of persons detained.

Any and all documents, training protocols, and directives to DHS immigration
officers and officials on how to conduct raids or targeted enforcement actions at
homes, workplaces and schools, including, but not limited to the treatment of minor
children of persons ICE or other DHS officers have detained between January 1,
2016 to the present.

NAACP LEGAL DEFENSE AND EDUCATIONAL FUND, INC.

 Any and all documents, policies, and directives regarding the appropriate use of
race, ethnicity or national origin in immigration enforcement actions.

If possible, please provide copies of these documents in an electronic format no later

than 20 business days after receipt of this request. 5 U.S.C. 552 (a)(3) and (6). If DHS
provides photocopies only, then LDF respectfully requests a waiver of copying and other
fees, as it is 501(c)(3), non-profit organization seeking these documents in the public
interest because the information is likely to contribute significantly to the publics
understanding of immigration enforcement activities of DHS. Id. 552(a)(4)(A)(iii). The
information requested will not be used for commercial purposes. If the Division declines
LDFs request for a waiver, then please provide an invoice, detailing reasonable standard
charges, prior to fulfilling this request. Id. 552(a)(4)(A)(ii).

If this request is denied in whole or in part, then please state in writing the specific
statutory exemption upon which you have relied.

Thank you for considering this request. Please do not hesitate to contact Monique
Dixon, Deputy Director of Policy and Senior Counsel, or me at 202-682-1300 with any
questions or concerns.

Sincerely yours,

Sherrilyn A. Ifill
President & Director Counsel