Answer to Amended Complaint

12345678910111213141516171819202122232425262728INTRODUCTION1. Paragraph 1 contains Plaintiffs’ characterization of this lawsuit and not allegationsof fact, and thus no response is required. To the extent a response is deemed necessary, Defendantsdeny the allegations in Paragraph 1 except to admit that Plaintiffs raise claims for injunctive reliefunder the Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”).2. Paragraph 2 contains Plaintiffs’ characterization of this lawsuit and not allegationsof fact, and thus no response is required. To the extent a response is deemed necessary, Defendantsdeny the allegations in Paragraph 2 except to admit that the Immigration Committee for the SanFrancisco Bay Area Chapter of the National Lawyers’ Guild filed a FOIA request with ICE datedDecember 15, 2005, and that Plaintiffs filed a FOIA request with DHS, ICE, CBP, DHS-OIG, andEOIR dated February 27, 2008.JURISDICTION3. Paragraph 3 contains conclusions of law, not allegations of fact, and thus no responseis required. To the extent a response is deemed necessary, Defendants deny any characterization ofthe cited statutory provisions, which speak for themselves, and respectfully refer the Court to thecited provisions for a complete and accurate statement of their contents.VENUE AND INTRADISTRICT ASSIGNMENT4. Paragraph 4 contains conclusions of law, not allegations of fact, and thus no responseis required. To the extent a response is deemed necessary, Defendants deny any characterization ofthe cited statutory provisions, which speak for themselves, and respectfully refer the Court to thecited provisions for a complete and accurate statement of their contents.5. Paragraph 5 contains conclusions of law, not allegations of fact, and thus no responseis required. To the extent a response is deemed necessary, Defendants deny any characterization ofthe cited local rule, which speaks for itself, and respectfully refer the Court to the cited rule for acomplete and accurate statement of its contents.PARTIES6. Defendants lack sufficient knowledge or information to form a belief as to the truthof the allegations in Paragraph 6.NO. C 08-5137 CRBANSWER TO COMPLAINT FOR INJUNCTIVE RELIEF 2