1. Records related to any past, current, or planned policy, guidance, or recommendations regarding the separation of families who arrive at the border, including ports of entry.
2. Systems for tracking children and adult family members who are separated.
3. Policies and protocols related to efforts to reunite separated family members.
4. Training of ICE and CBP officers regarding screening of adult family members for referral for criminal prosecution for immigration violations.
5. Training regarding treatment of family members and minor children in ICE or CBP custody who have been separated.
6. Practices and protocols for coordinating communication (telephonic, video, or in-person) between a detained adult family member and a related minor child, following separation.
7. Coordination among CBP, ICE, DHS, Health and Human Services, and the Department of Justice regarding the processing and handling of the separation of adult family members from related minor children.
8. Practices or protocols for verifying a family relationship prior to or after separation.
9. Data regarding the number of minor children separated from adult family members; the number of referrals of adult family members for criminal prosecution where families were separated; the number of referrals for credible fear interviews after separation; and the number of children and parents who departed the United States after separation.
10. Complaints received by the agencies regarding the separation of families.“The government has taken thousands of immigrant children—including infants—from their parents yet there is no known system for how this vulnerable population is being managed and when the parents can expect to be reunited with their children—if ever,” said Emily Creighton, the Council’s deputy legal director. “This lawsuit intends to uncover documents supporting the policies that the government would rather remain hidden from view. Among them are justifications for family separation, communication among agencies detailing coordinated efforts to separate families, and comprehensive data showing the systemic implementation of family separation and removal.”