!

' THE The Legal Aid Society

Community Justice Unit
199 Water Street 6 Floor

"i liSo'
F:ri
New York, NY I0038
T (212) 577-3385

!!:l socrery
allirldaiLLsill:lr!
www.legal-aid.org
!B

Blainc (Fin) V. Fogg

November 3, 201 7 Se]mour W. James. Jr

Attornefin-Chief

Tina M. Luongo
U.S. Immigration and Customs Enforcement Atomey in Charge
Criminal Practice
Freedom of Information Act Office
500 l2th Street, S.W., Stop 5009
Washington, D.C. 20536-5009
Via electronic mail: ICll:-[OIA'lidhs.oor

Re: Freedom of Information Request

Dear Freedom ol Information Officer:

The following request is submitted pursuant to the Freedom of Information Act, 5

U.S.C. $ 552. The request is made by a group of concemed citizens whose communities are
being affected by gang raids, immigration sweeps, surveillance, databases and collection ol
secret dossiers on suspected gang members and individuals alleged to be associated with
gang members. I request that a copy of the following documents be provided to me:

All records, documents, regulations, and guidelines pertaining to how ICE and the
National Gang Unit (NGU) track and maintain data on individuals.

2. All records, documents, regulations,and guidelines describing and/or defining

"gang," "gang member," "association," and "gang-related criminal activity."

3. Total number of employees assigned to the NGU, by year lrom January 2006 to
present.

4. Total number of employees assigned to Operation Community Shield, by year from

January 2006 to present.

5. The names of all domestic and foreign law enforcement agencies with which
Homeland Security Investigations' (HSI) NGU partners through Operation
Community Shield.

6. The names of all agencies with which HSI shares information regarding criminal
gang investigations.

7. Total number olindividuals whose personal information appears in ICE's gang

database, by year, from January 2006 to present.
Page 2

a Total number ofthe individuals whose personal information appears in the

NGIC database, by year, lrom January 2006 to present, broken down by race
(Black, Hispanic, White, Other).

b. Total number of the individuals whose personal information appears in the

NGIC database, by year, lrom January 2006 to present, broken down by
country of origin.

c Total number ofthe individuals whose personal information appears in the

NGIC database, by year, from January 2006 to present, broken down by age.

8. Copies of all documents, records, and forms used by ICE, HSI, NGU, and Operation
Community Shield to track gang intelligence.

Please lurnish records to

Anthony Posada, The Legal Aid Society: Community Justice Unit, 199 Water Street 6
Floor New York, NY 10038

Pursuant to 5 U.S.C. $ 5 52(a)(6)(e)(i), I expect a response within the twenty (20) day
statutory time limit.

IlthisRequest is denied in whole or in part, I ask that youjustify all deletions by reference
to specific exemptions ofthe FOIA. I expect release olall segregable portions of otherwise
exempt material. Further, recognizing that it may take longer to provide certain documents
than others, I request that you provide us with documents as they become available rather
than waiting for the complete set.

Ifyou have any questions in processing this request, I can be contacted at the address
above, via e-mail at aposada@legal-aid.org, or by telephone al (212) 577-3385.

Sincerely,

Anthony Po
Supervising Attomey
The Legal Aid Society
Community Justice Unit
(212) s77-338s
alrosada,nl lc sal-aid. orc
on behalfofa coalition consisting of:
Family members ofpeople impacted by "gang" policing, Brooklyn Defender Services,
Black Alliance for Just Immigration (BAJI), Coalition to End Broken Windows, Critical
Page 3

Resistance NYC, ICE-Free NYC, Just Leadership USA, Legal Aid Society, Mi Casa No Es
Tu Casa, Policing and Social Justice Proj ect at Brooklyn College, PROP, Reform RICO,
Queens Neighborhoods United, Unlocal, Voices of Community Activists & Leaders
(VOCAL-NY), We Care, Why Accountability, and Youth Represent.