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Case TitleImmigrant Defense Project et al v. United States Department of Homeland Security et al
DistrictSouthern District of New York
CityFoley Square
Case Number1:2020cv10625
Date Filed2020-12-16
Date ClosedOpen
JudgeJudge Ronnie Abrams
PlaintiffImmigrant Defense Project
PlaintiffCenter for Constitutional Rights
Case DescriptionThe Immigrant Defense Project and the Center for Constitutional Rights submitted a FOIA request to the Department of Homeland Security for records concerning Operation Palladium. The agency acknowledged receipt of the request. IDP and CCR also requested expedited processing and a fee waiver. The agency acknowledged receipt of the request. The agency denied IDP and CRR's request for expedited processing. After hearing nothing further from the agencies, IDP and CRR filed suit.
Complaint issues: Failure to respond within statutory time limit, Adequacy - Search, Expedited processing, Public Interest Fee Waiver, Litigation - Attorney's fees

DefendantUnited States Department of Homeland Security
DefendantUnited States Immigration and Customs Enforcement
Documents
Docket
Complaint
Complaint attachment 1
Opinion/Order [17]
Opinion/Order [58]
User-contributed Documents
 
Docket Events (Hide)
Date FiledDoc #Docket Text

2020-12-161COMPLAINT against United States Department of Homeland Security, United States Immigration and Customs Enforcement. (Filing Fee $ 402.00, Receipt Number ANYSDC-23063514)Document filed by Center for Constitutional Rights, Immigrant Defense Project. (Attachments: # 1 Exhibit).(Wachtenheim, Andrew) (Entered: 12/16/2020)
2020-12-162CIVIL COVER SHEET filed..(Wachtenheim, Andrew) (Entered: 12/16/2020)
2020-12-163FILING ERROR - DEFICIENT PLEADING - SUMMONS REQUEST As To - REQUEST FOR ISSUANCE OF SUMMONS as to, re: 1 Complaint,. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) Modified on 12/17/2020 (dnh). (Entered: 12/16/2020)
2020-12-164FILING ERROR - DEFICIENT PLEADING - SUMMONS REQUEST As To - REQUEST FOR ISSUANCE OF SUMMONS as to, re: 1 Complaint,. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) Modified on 12/17/2020 (dnh). (Entered: 12/16/2020)
2020-12-17***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Andrew Brian Wachtenheim. The following case opening statistical information was erroneously selected/entered: Fee Status code due (due). The following correction(s) have been made to your case entry: the Fee Status code has been modified to pd (paid). (dnh) (Entered: 12/17/2020)
2020-12-17CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Ronnie Abrams. Please download and review the Individual Practices of the assigned District Judge, located at https://nysd.uscourts.gov/judges/district-judges . Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at https://nysd.uscourts.gov/rules/ecf-related-instructions . .(dnh) (Entered: 12/17/2020)
2020-12-17Magistrate Judge Debra C. Freeman is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf . (dnh) (Entered: 12/17/2020)
2020-12-17Case Designated ECF. (dnh) (Entered: 12/17/2020)
2020-12-17***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Andrew Brian Wachtenheim to RE-FILE Document No. 3 Request for Issuance of Summons, 4 Request for Issuance of Summons. The filing is deficient for the following reason(s): 'As to' Error; the name of the party as to whom the summons is being requested must be listed in the as to docket entry text. Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (dnh) (Entered: 12/17/2020)
2020-12-175REQUEST FOR ISSUANCE OF SUMMONS as to United States Department of Homeland Security, re: 1 Complaint,. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 12/17/2020)
2020-12-176REQUEST FOR ISSUANCE OF SUMMONS as to United States Immigration and Customs Enforcement, re: 1 Complaint,. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 12/17/2020)
2020-12-177MOTION for Leila Kang to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-23083749. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Center for Constitutional Rights, Immigrant Defense Project. (Attachments: # 1 Affidavit Affidavit In Support of Motion for Admission Pro Hac Vice, # 2 Exhibit Certificate of Good Standing for Leila Kang, # 3 Text of Proposed Order Proposed Order Granting Admission Pro Hac Vice).(Kang, Leila) (Entered: 12/17/2020)
2020-12-17>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 7 MOTION for Leila Kang to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-23083749. Motion and supporting papers to be reviewed by Clerk's Office staff. The document has been reviewed and there are no deficiencies. (aea) (Entered: 12/17/2020)
2020-12-188ORDER granting 7 Motion for Leila Kang to Appear Pro Hac Vice (HEREBY ORDERED by Judge Ronnie Abrams)(Text Only Order) (arc) (Entered: 12/18/2020)
2020-12-189ORDER AND NOTICE OF INITIAL CONFERENCE: This case has been assigned to me for all purposes. It is hereby: ORDERED that counsel for all parties appear for an initial status conference on March 5, 2021 at 10:00 a.m. This conference will be held via telephone. The parties shall use the following dial-in information to call in to the conference: Call-in Number: (888) 363-4749; Access Code: 1015508. This conference line is open to the public. IT IS FURTHER ORDERED that, no later than February 26, 2021, the parties submit a joint letter, not to exceed five (5) pages, providing the following information in separate paragraphs: as set forth herein. Plaintiffs are ordered to serve Defendants with a copy of this Order and to file an affidavit on ECF certifying that such service has been effectuated. SO ORDERED. Initial Conference set for 3/5/2021 at 10:00 AM before Judge Ronnie Abrams. (Signed by Judge Ronnie Abrams on 12/18/2020) (ama) (Entered: 12/18/2020)
2020-12-1810ELECTRONIC SUMMONS ISSUED as to United States Department of Homeland Security..(dnh) (Entered: 12/18/2020)
2020-12-1811ELECTRONIC SUMMONS ISSUED as to United States Immigration and Customs Enforcement..(dnh) (Entered: 12/18/2020)
2020-12-2112AFFIDAVIT OF SERVICE (FOIA CASE) of Summons and Complaint, served. United States Department of Homeland Security served on 12/21/2020, answer due 1/20/2021; United States Immigration and Customs Enforcement served on 12/21/2020, answer due 1/20/2021. Service was made by MAIL. Document filed by Center for Constitutional Rights; Immigrant Defense Project..(Kang, Leila) (Entered: 12/21/2020)
2021-01-0513NOTICE OF APPEARANCE by Ghita Schwarz on behalf of Center for Constitutional Rights, Immigrant Defense Project..(Schwarz, Ghita) (Entered: 01/05/2021)
2021-01-2014NOTICE OF APPEARANCE by Anthony Jan-Huan Sun on behalf of United States Department of Homeland Security, United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 01/20/2021)
2021-01-2015ANSWER to 1 Complaint,. Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 01/20/2021)
2021-02-2616JOINT LETTER addressed to Judge Ronnie Abrams from Ghita Schwarz, Leila Kang, and Anthony Sun dated 2/26/21 re: Case Status. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Kang, Leila) (Entered: 02/26/2021)
2021-03-05Minute Entry for proceedings held before Judge Ronnie Abrams: Initial Pretrial Conference held on 3/5/2021. (arc) (Entered: 03/05/2021)
2021-03-0517ORDER: As discussed at today's conference, no later than April 1, 2021, Defendants shall (1) reprocess the First Interim release to determine whether there is any additional segregable, nonexempt material that may be released to Plaintiffs; and (2) conduct the additional Homeland Security Investigations (HSI) search mentioned at the conference. The parties shall then meet and confer and, no later than April 8, 2021, file a joint letter proposing next steps in this litigation, including a schedule for additional productions. SO ORDERED. (Signed by Judge Ronnie Abrams on 3/5/2021) (jca) (Entered: 03/05/2021)
2021-04-0818JOINT LETTER addressed to Judge Ronnie Abrams from Leila Kang, Ghita Schwarz, and Anthony Sun dated 4/8/21 re: Case Status. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Kang, Leila) (Entered: 04/08/2021)
2021-04-0919MEMO ENDORSEMENT on re: 18 Letter filed by Center for Constitutional Rights, Immigrant Defense Project. ENDORSEMENT: The parties shall file another joint status update no later than May 21, 2021, including proposed briefing schedules. If Defendants continue to take the position that a briefing schedule is premature at that time, they shall so state in the joint submission. SO ORDERED. (Signed by Judge Ronnie Abrams on 4/9/2021) (kv) (Entered: 04/09/2021)
2021-05-2120STATUS REPORT. Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 05/21/2021)
2021-05-2521MEMO ENDORSEMENT on re: 20 Status Report filed by United States Immigration and Customs Enforcement, United States Department of Homeland Security ENDORSEMENT: Application granted. SO ORDERED. (Signed by Judge Ronnie Abrams on 5/25/2021) (ks) (Entered: 05/25/2021)
2021-06-0422LETTER addressed to Judge Ronnie Abrams from AUSA Anthony J. Sun dated 6/4/2021 re: status update. Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 06/04/2021)
2021-06-0423MOTION for Leila Kang to Withdraw as Attorney for Plaintiffs . Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Kang, Leila) (Entered: 06/04/2021)
2021-06-0724MEMO ENDORSEMENT on re: 22 Letter filed by United States Immigration and Customs Enforcement, United States Department of Homeland Security.ENDORSEMENT: Application granted. The parties are directed to submit an additional status report on or before July 6, 2021. (Signed by Judge Ronnie Abrams on 6/7/2021) (mro) (Entered: 06/08/2021)
2021-06-0825MEMO ENDORSEMENT granting 23 Motion to Withdraw as Attorney. ENDORSEMENT: Application granted. The Clerk of Court is respectfully directed to terminate Ms. Kang from the docket sheet. Attorney Leila Kang terminated. (Signed by Judge Ronnie Abrams on 6/7/2021) (mro) (Entered: 06/08/2021)
2021-07-0226CONSENT LETTER MOTION for Extension of Time to submit status report addressed to Judge Ronnie Abrams from AUSA Anthony J. Sun dated 7/2/2021. Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 07/02/2021)
2021-07-0627ORDER granting 26 Letter Motion for Extension of Time. Application granted. SO ORDERED. (Signed by Judge Ronnie Abrams on 7/6/2021) (vfr) (Entered: 07/06/2021)
2021-07-0828LETTER addressed to Judge Ronnie Abrams from AUSA Anthony J. Sun dated 7/8/2021 re: status update. Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 07/08/2021)
2021-07-0929MEMO ENDORSEMENT on re: 28 Letter re: status update filed by United States Immigration and Customs Enforcement, United States Department of Homeland Security. ENDORSEMENT: Application granted. The parties are directed to submit an additional status report on or before August 20, 2021. So ORDERED. (Signed by Judge Ronnie Abrams on 7/9/2021) (rj) (Entered: 07/09/2021)
2021-08-2030LETTER addressed to Judge Ronnie Abrams from AUSA Anthony J. Sun dated 8/20/2021 re: status update. Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 08/20/2021)
2021-08-2331MEMO ENDORSEMENT on re: 30 Letter filed by United States Immigration and Customs Enforcement, United States Department of Homeland Security: ENDORSEMENT: Application granted. The parties are directed to provide an additional status update on September 27, 2021. SO ORDERED. (Signed by Judge Ronnie Abrams on 8/23/2021) (tg) (Entered: 08/23/2021)
2021-09-2832STATUS REPORT. Joint letter of the Parties Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 09/28/2021)
2021-09-2933MEMO ENDORSEMENT on re: 32 Status Report filed by Center for Constitutional Rights, Immigrant Defense Project. ENDORSEMENT: Application granted. The parties are directed to submit another status report on or before November 2, 2021. (Signed by Judge Ronnie Abrams on 9/29/2021) (ate) (Entered: 09/29/2021)
2021-11-0334FIRST LETTER MOTION for Extension of Time addressed to Judge Ronnie Abrams from Andrew Wachtenheim dated 11/02/2021. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 11/03/2021)
2021-11-0335ORDER granting 34 Letter Motion for Extension of Time. Application granted. SO ORDERED. (Signed by Judge Ronnie Abrams on 11/3/2021) (tg) (Entered: 11/03/2021)
2021-11-1636STATUS REPORT. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 11/16/2021)
2021-11-1737MEMO ENDORSEMENT on re: 36 Status Report filed by Center for Constitutional Rights, Immigrant Defense Project. ENDORSEMENT: Application granted. SO ORDERED. (Signed by Judge Ronnie Abrams on 11/17/2021) (tg) (Entered: 11/17/2021)
2021-11-1938STATUS REPORT. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 11/19/2021)
2021-11-2239MEMO ENDORSEMENT on re: 38 Status Report filed by Center for Constitutional Rights, Immigrant Defense Project. ENDORSEMENT: Defendants shall produce the Vaughn indices for the agreed-upon categories by January 31, 2022. The parties are further directed to submit another status report on or before February 4, 2022. SO ORDERED. (Signed by Judge Ronnie Abrams on 11/22/2021) (mml) (Entered: 11/22/2021)
2021-12-0340NOTICE OF APPEARANCE by Maria Couri LaHood on behalf of Center for Constitutional Rights, Immigrant Defense Project..(LaHood, Maria) (Entered: 12/03/2021)
2022-02-0541STATUS REPORT. Joint letter of the Parties Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 02/05/2022)
2022-02-0742MEMO ENDORSEMENT: on re: 41 Status Report filed by Center for Constitutional Rights, Immigrant Defense Project. ENDORSEMENT: Application Granted. SO ORDERED. (Signed by Judge Ronnie Abrams on 2/07/2022) (ama) (Entered: 02/07/2022)
2022-02-1243STATUS REPORT. Joint letter of the Parties Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 02/12/2022)
2022-02-1444MEMO ENDORSEMENT on re: 43 Status Report filed by Center for Constitutional Rights, Immigrant Defense Project. ENDORSEMENT: The parties shall adhere to the following briefing schedule: Defendants' brief and materials in support of motion shall be filed on or before March 31, 2022; Plaintiffs' brief in opposition to Defendants' motion and in support of Plaintiffs' cross-motion shall be due May 2, 2022; Defendants' brief in opposition to Plaintiff's cross-motion and reply in further support of Defendants' motion shall be due May 16, 2022; and Plaintiffs' reply brief shall be due May 30, 2022. ( Motions due by 3/31/2022., Responses due by 5/16/2022, Replies due by 5/30/2022.) (Signed by Judge Ronnie Abrams on 2/14/2022) (ate) (Entered: 02/14/2022)
2022-03-3145MOTION for Summary Judgment . Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement. Responses due by 5/2/2022.(Sun, Anthony) (Entered: 03/31/2022)
2022-03-3146DECLARATION of Lynnea Schurkamp in Support re: 45 MOTION for Summary Judgment .. Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement. (Attachments: # 1 Exhibit A - Vaughn index, # 2 Exhibit B - FOIA Request, # 3 Exhibit C - Acknowledgement, # 4 Exhibit D - Admin. Appeal, # 5 Exhibit E - Appeal Acknowledgement, # 6 Exhibit F - Appeal decision).(Sun, Anthony) (Entered: 03/31/2022)
2022-03-3147MEMORANDUM OF LAW in Support re: 45 MOTION for Summary Judgment . . Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 03/31/2022)
2022-04-28NOTICE OF REDESIGNATION TO ANOTHER MAGISTRATE JUDGE. The above entitled action has been redesignated to Magistrate Judge Valerie Figueredo. Please note that this is a reassignment of the designation only. (nb) (Entered: 04/28/2022)
2022-05-0248FIRST MOTION for Summary Judgment . Document filed by Center for Constitutional Rights, Immigrant Defense Project. Responses due by 5/16/2022.(Wachtenheim, Andrew) (Entered: 05/02/2022)
2022-05-0249DECLARATION of Mizue Aizeki in Support re: 48 FIRST MOTION for Summary Judgment .. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 05/02/2022)
2022-05-0350DECLARATION of Andrew Wachtenheim in Support re: 48 FIRST MOTION for Summary Judgment .. Document filed by Center for Constitutional Rights, Immigrant Defense Project. (Attachments: # 1 Exhibit Bates 305-308, 506-509, 868, # 2 Exhibit Bates 468-488, 833-834, 941, # 3 Exhibit Bates 207-208, # 4 Exhibit Bates 491-493, # 5 Exhibit Emails, # 6 Exhibit Bates 502-508, # 7 Exhibit Bates 119-133, # 8 Exhibit Bates 612-613, # 9 Exhibit Emails, # 10 Exhibit Bates 489, 757, 788, # 11 Exhibit Bates 194-195, # 12 Exhibit memos, # 13 Exhibit Bates 1127-1274, # 14 Exhibit training, # 15 Exhibit handbook, # 16 Exhibit handbook, # 17 Exhibit Bates 370-401).(Wachtenheim, Andrew) (Entered: 05/03/2022)
2022-05-0351FIRST MEMORANDUM OF LAW in Support re: 48 FIRST MOTION for Summary Judgment . . Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 05/03/2022)
2022-05-1352CONSENT LETTER MOTION for Extension of Time and status update addressed to Judge Ronnie Abrams from AUSA Anthony J. Sun dated 5/13/2022. Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 05/13/2022)
2022-05-1753ORDER granting 52 Letter Motion for Extension of Time. Application granted. SO ORDERED. (Signed by Judge Ronnie Abrams on 5/17/2022) (rro) (Entered: 05/17/2022)
2022-05-17Set/Reset Deadlines: Responses due by 5/27/2022 Replies due by 6/13/2022. (rro) (Entered: 05/17/2022)
2022-05-2754REPLY AFFIDAVIT of Catrina Pavlik-Keenan in Support re: 45 MOTION for Summary Judgment .. Document filed by United States Department of Homeland Security..(Sun, Anthony) (Entered: 05/27/2022)
2022-05-2755REPLY AFFIDAVIT of Michele Welch in Support re: 45 MOTION for Summary Judgment .. Document filed by United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 05/27/2022)
2022-05-2756REPLY MEMORANDUM OF LAW in Support re: 45 MOTION for Summary Judgment . . Document filed by United States Department of Homeland Security, United States Immigration and Customs Enforcement..(Sun, Anthony) (Entered: 05/27/2022)
2022-06-1357BRIEF Reply . Document filed by Center for Constitutional Rights, Immigrant Defense Project. (Attachments: # 1 Affidavit Andrew Wachtenheim, # 2 Exhibit Ex. 18, # 3 Exhibit Ex. 19, # 4 Exhibit Ex. 20, # 5 Exhibit Ex. 21, # 6 Exhibit Ex. 22).(Wachtenheim, Andrew) (Entered: 06/13/2022)
2022-12-1958ORDER: The parties shall appear for a conference on January 4, 2023 at 12:00 p.m. to discuss the extent of the overlap between the underlying FOIA requests in these two cases, and the effect, if any, that Immigrant Defense Project II has on the pending cross-motions for summary judgment in the instant case. The parties shall file a letter advising the Court whether they would like to appear in person or telephonically for this conference. If the scheduled date and time is inconvenient for the parties, the parties shall confer and propose an alternate date. ( Status Conference set for 1/4/2023 at 12:00 PM before Judge Ronnie Abrams.) (Signed by Judge Ronnie Abrams on 12/19/2022) (ate) (Main Document 58 replaced on 12/21/2022) (tro). Modified on 12/21/2022 (tro). (Entered: 12/20/2022)
2022-12-2259JOINT LETTER addressed to Judge Ronnie Abrams from Joint letter of the parties dated 12/22/2022 re: Telephonic appearances. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 12/22/2022)
2022-12-2360MEMO ENDORSEMENT on re: 59 Letter filed by Center for Constitutional Rights, Immigrant Defense Project. ENDORSEMENT: Application granted. The parties shall use the following dial-in information to call in to the conference: Call-in Number: (888) 363-4749; Access Code: 1015508. This conference line is open to the public. (Signed by Judge Ronnie Abrams on 12/23/2022) (ate) (Entered: 12/23/2022)
2023-01-04Minute Entry for proceedings held before Judge Ronnie Abrams: Status Conference held on 1/4/2023. (Court Reporter Sadie Herbert) (arc) (Entered: 01/04/2023)
2023-01-0661JOINT LETTER MOTION for Extension of Time addressed to Judge Ronnie Abrams from Ghita Schwarz dated January 6, 2023. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Schwarz, Ghita) (Entered: 01/06/2023)
2023-01-0962ORDER granting 61 JOINT LETTER MOTION for Extension of Time. The Court grants the application for an extension of time to submit an update on IDP II and thanks the parties for articulating their positions regarding the pending summary judgment motions in IDP I. SO ORDERED. (Signed by Judge Ronnie Abrams on 1/9/2023) (jca) (Entered: 01/09/2023)
2023-01-1363LETTER addressed to Judge Ronnie Abrams from Joint letter of the parties dated 01/13/2023 re: joint letter of the parties. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 01/13/2023)
2023-01-2064FIRST LETTER addressed to Judge Ronnie Abrams from Plaintiffs dated 01/20/2023 re: Request for leave to file response to Defendant's declaration. Document filed by Center for Constitutional Rights, Immigrant Defense Project..(Wachtenheim, Andrew) (Entered: 01/20/2023)
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