Answer to Complaint by Department of Homeland SECURITY.(Vaden, Andrew)

6–17. To the extent the allegations seek to provide background facts in support of allegations of public interest, Defendant admits there may be some public interest in the records sought but presently lacks knowledge or information sufficient to form a belief as to the existence

For ease of reference, Defendant replicates the Complaint’s headings. Although Defendant believes that no response is required to such headings, to the extent a response is deemed required and those headings could be construed to contain factual allegations, those allegations are denied.

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or extent of any public interest, including as compared to any countervailing interests. To the extent the allegations in this paragraph are alleged for other purposes, they do not set forth claims of relief or aver facts in support of a claim, and thus, the Court should strike them as immaterial and impertinent matters pursuant to Rule 12(f).

18.

Defendant restates and incorporates by reference the preceding paragraphs of this Answer as though fully stated herein.

19.

Defendant admits only that it received Plaintiff’s FOIA request dated February 17, 2026. As to the remaining allegations of this paragraph, Defendant respectfully refers the Court to the cited request for a complete and accurate statement of its contents and denies any allegations in this paragraph inconsistent therewith.

20.

Defendant admits only that Plaintiff sought expedited processing of the cited FOIA request. As to the remaining allegations of this paragraph, Defendant respectfully refers the Court to the cited request for a complete and accurate statement of its contents and denies any allegations in this paragraph inconsistent therewith.

21.

Defendant admits only that the ICE FOIA portal assigned Request No. 2026-ICFO- 17498 to Plaintiff’s request and denies the remaining allegations of this paragraph.

22.

The allegations contained in this paragraph consist of conclusions of law to which no response is required. To the extent that a response is deemed required, Defendant denies the allegations.

23.

Defendant restates and incorporates by reference the preceding paragraphs of this Answer as though fully stated herein.

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24.

Defendant admits only that Plaintiff sought a fee waiver in its February 17, 2026, communication, and respectfully refers the Court to the cited communication for a complete and accurate statement of its contents and denies any allegations in this paragraph inconsistent therewith.

25.

Defendant admits only that it received Plaintiff’s February 26, 2026, communication, and respectfully refers the Court to the cited communication for a complete and accurate statement of its contents and denies any allegations in this paragraph inconsistent therewith.

26.

Defendant admits only that it received Plaintiff’s February 26, 2026, communication, and respectfully refers the Court to the cited communication for a complete and accurate statement of its contents and denies any allegations in this paragraph inconsistent therewith.

27.

Defendant admits only that ICE FOIA portal assigned Request No. 2026-ICFO- 17498. Defendant denies the remaining allegations contained in this paragraph.

28.

The allegation contained in this paragraph is a legal conclusion to which no response is required.

29.

The allegations contained in this paragraph consist of legal conclusions to which no response is required. To the extent that a response is deemed required, Defendant denies the allegations.

30.

Defendant restates and incorporates by reference the preceding paragraphs of this Answer as though fully stated herein.

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31.

Defendant admits only that it received Plaintiff’s FOIA request dated January 21, 2026. As to the remaining allegations of this paragraph, Defendant respectfully refers the Court to the cited request for a complete and accurate statement of its contents and denies any allegations in this paragraph inconsistent therewith.

32.

Defendant admits only that it received Plaintiff’s FOIA request dated January 21, 2026. As to the remaining allegations of this paragraph, Defendant respectfully refers the Court to the cited request for a complete and accurate statement of its contents and denies any allegations in this paragraph inconsistent therewith.

33.

Defendant admits only that Plaintiff’s FOIA request dated January 21, 2026 requested expedited processing. As to the remaining allegations of this paragraph, Defendant respectfully refers the Court to the cited request for a complete and accurate statement of its contents and denies any allegations in this paragraph inconsistent therewith.

34.

Defendant respectfully refers the Court to the cited request for a complete and accurate statement of its contents and denies any allegations in this paragraph inconsistent therewith.

35.

Defendant denies the allegations of this paragraph. 36.

The allegations contained in this paragraph consist of legal conclusions to which no response is required. To the extent that a response is deemed required, Defendant denies the allegations.

37.

Defendant restates and incorporates by reference the preceding paragraphs of this Answer as though fully stated herein.