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1 Complaint: Brennan Center for Justice at the New York University School of Law v. U.S. Department of Homeland Security 1 (2020)

handle is hein.brennan/cmpbcjus0001 and id is 1 raw text is: 
Case 1:20-cv-00427 Document 1 Filed 01/16/20 Page 1 of 17


                   IN THE UNITED STATES DISTRICT COURT
                 FOR THE SOUTHERN DISTRICT OF NEW YORK

                                                )
BRENNAN CENTER FOR JUSTICE                      )
AT THE NEW YORK UNIVERSITY SCHOOL OF LAW,)
                                                )
            Plaintiff,                          )
                                                )    No. 1:20-cv-00427
v.                                              )
                                                )
UNITED STATES DEPARTMENT OF HOMELAND            )
SECURITY, UNITED STATES CUSTOMS AND             )
BORDER PROTECTION, and UNITED STATES            )
IMMIGRATION AND CUSTOMS ENFORCEMENT,            )
                                                )
            Defendants.                         )
                                               )



                                 COMPLAINT

      Plaintiff Brennan Center for Justice at the New York University School of Law (the

Brennan Center) hereby complains as follows against Defendants the United States Department

of Homeland Security (DHS), United States Customs and Border Protection (CBP), and

United States Immigration and Customs Enforcement (ICE):

                               INTRODUCTION

      1.    This is an action for the production of public records and injunctive relief pursuant

to the Freedom of Information Act (FOIA), 5 U.S.C. § 552.

      2.    On November 5, 2018, the Brennan Center sent separate and substantively identical

FOIA requests to Defendants DHS and ICE seeking records related to the Data Analysis System

(DAS) in use by ICE and contributed to by DHS and at least two of its agency components (the

DAS Requests).

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