Records pertaining to contracts and arrangements involving airplane companies and private security firms for deportation operations

Jordan Lassiter
Investigative Journalist
March 12, 2025

U.S. Immigration and Customs Enforcement
Enforcement and Removal Operations (ERO) FOIA Office
500 12th Street SW
Washington, DC 20536
Email: ICE-FOIA@dhs.gov
Fax: (202) 732-4265

CRITICAL NOTICE – READ CAREFULLY – COMPREHENSIVE COMPLIANCE REQUIRED

This FOIA request contains legally binding instructions that must be followed in their entirety. Failure to comply with any portion—including the detailed search methodology, records preservation directives, or production requirements—will be construed as noncompliance under 5 U.S.C. § 552 and may result in immediate legal action.

SUBJECT:
REQUEST FOR ALL Records pertaining to contracts and arrangements involving airplane companies and private security firms for deportation operations
(Focus: Records from January 1, 2018 to Present, with particular emphasis on documents generated during Trump’s first and current presidencies.)

I. INTRODUCTION & SCOPE

Pursuant to the Freedom of Information Act, 5 U.S.C. § 552, and applicable agency regulations, I hereby request access to and copies of all records, contracts, memoranda, agreements, proposals, directives, and communications regarding ICE’s engagements with:

AIRPLANE COMPANIES

All records (contracts, amendments, proposals, and related communications) between ICE (and its subordinate components) and airplane companies utilized to charter deportation flights.
Context: Investigative reports, such as the University of Washington article “ICE, Air, and Deportation: The King County Case” (https://jsis.washington.edu/humanrights/2019/04/23/ice-air-king-county/), detail ICE’s use of charter flights in deportation efforts.
Legal Precedents:
• Department of Justice v. Reporters Committee for Freedom of the Press, 489 U.S. 749 (1989)
• Milner v. Department of Navy, 562 U.S. 562 (2011)
PRIVATE SECURITY FIRMS

All records involving contracts, agreements, and related communications between ICE (and its sub-offices) and private security companies that provide operational support (e.g., ground escorts, logistical services) during deportation operations.
Legal Precedents:
• Electronic Privacy Information Center v. Department of Justice, 416 F. Supp. 2d 30 (D.D.C. 2006)
• Judicial Watch, Inc. v. U.S. Department of Defense, 857 F. Supp. 2d 44 (D.D.C. 2012)
Additional Reporting: See “ICE contractor flight to Seattle may signal Washington state detention center will fill up” (The Spokesman-Review, Feb. 5, 2025).
Time Frame & Focus on Trump’s Presidencies:
This request covers all responsive records from January 1, 2018 through the present. For the purposes of this request:

"Trump’s first presidency" refers to his time in office from January 20, 2017 through January 20, 2021. Since the requested records begin on January 1, 2018, this period will cover records generated during the majority of his first term.
"Trump’s current presidency" refers to his second term, which began on January 20, 2025, and continues to the present.
II. DETAILED DESCRIPTION OF RECORDS REQUESTED

To ensure full compliance and eliminate ambiguity, please produce all responsive documents, including but not limited to:

A. Contracts & Agreements

All executed contracts, amendments, proposals, and related communications between ICE (and its sub-offices) and:
Airplane companies used to operate deportation flights.
Private security firms providing additional operational support services.
B. Communications & Internal Directives

All internal communications (emails, instant messages, memos, briefing documents, meeting minutes, and draft versions) among ICE officials regarding:
The contracting process and oversight of deportation flight arrangements.
Evaluation, modifications, and performance assessments of such contracts.
C. Policy Documents & Operational Guidelines

All finalized or draft policy documents, guidelines, or standard operating procedures that authorize or regulate:
The engagement of external contractors (both airplane companies and private security firms) for deportation operations.
Oversight and performance evaluation of these contracted services.
D. Search Methodology Documentation

A detailed account of the search strategies used to identify responsive records, including:
• The systems and databases searched (e.g., ICE’s electronic records management systems, contract databases, email servers).
• Search terms, date ranges, custodians, and personnel involved.
• Complete search logs and documentation verifying that all relevant systems were thoroughly searched.
III. CUSTODIANS & SYSTEMS

Please search all relevant ICE components and sub-offices, including but not limited to:
• ICE Headquarters and Regional Offices
• ICE’s Office of Detention and Removal
• ICE’s Contracting, Procurement, and related administrative divisions

Systems to be searched include:
• Electronic records management and email systems
• Contract and document management platforms
• Digital repositories or archives where such contracts and communications are stored

IV. LEGAL AUTHORITIES & PRECEDENTS

This request is substantiated by established FOIA precedent and the public’s right to know, including:
• Department of Justice v. Reporters Committee for Freedom of the Press, 489 U.S. 749 (1989)
• Milner v. Department of Navy, 562 U.S. 562 (2011)
• Electronic Privacy Information Center v. Department of Justice, 416 F. Supp. 2d 30 (D.D.C. 2006)
• Judicial Watch, Inc. v. U.S. Department of Defense, 857 F. Supp. 2d 44 (D.D.C. 2012)

V. EXPEDITED PROCESSING & FEE WAIVER

Due to the significant public interest in ensuring transparency regarding ICE’s contracting practices related to deportation operations—and in light of the policies enacted during both of Trump’s presidencies—I request expedited processing pursuant to 5 U.S.C. § 552(a)(6)(E)(v)(II). Furthermore, I request a complete waiver of fees under 5 U.S.C. § 552(a)(4)(A)(iii) on the basis that disclosure of these records will substantially contribute to public understanding of ICE operations and accountability in government contracting.

VI. FORMAT OF PRODUCTION

Please produce all responsive records in their native electronic formats with full metadata intact. This includes:
• Emails and documents in their native file formats (e.g., .MSG, .EML, .DOCX, .PDF, etc.).
• Structured data in searchable electronic formats (e.g., .CSV, .XML) along with any accompanying data dictionaries.
• Search documentation provided in a verifiable electronic format.

For any records that exist solely in paper form, please provide high-resolution scanned copies (minimum 300 dpi) in PDF format.

VII. PRESERVATION & ADMINISTRATIVE TRACKING

Until a final determination on this request is rendered, please ensure that all responsive records are preserved in their entirety, including all associated metadata. In addition, please provide:
• The tracking number assigned to this request.
• The names and titles of the FOIA officers handling this request.
• Detailed documentation of the search methodologies employed.

VIII. RIGHT TO APPEAL & STATUTORY DEADLINES

I expressly reserve the right to appeal any adverse determination, including denials of expedited processing, fee waiver, or inadequacies in the search. I expect a determination on this request within 20 working days (or 10 calendar days if expedited processing applies) as mandated by 5 U.S.C. § 552(a)(6)(A)(i).

IX. FINAL WARNING & DISCLAIMER

YOU ARE HEREBY NOTIFIED:
Any failure to comply with these detailed instructions—including conducting a comprehensive search across all relevant systems and custodians—will be deemed noncompliance with FOIA obligations and may serve as grounds for immediate judicial review and legal action pursuant to 5 U.S.C. § 552(a)(4)(B) and related case law.

Please acknowledge receipt of this request and provide the assigned tracking number within five (5) working days. For any clarifications, contact me immediately rather than resorting to delay tactics.

Thank you for your prompt attention to this matter.

Sincerely,

Jordan Lassiter
Investigative Journalist