We intend to give the govt. the following notice:
THIS NOTICE NAMES AS THE DEPONENT A GOVERNMENTAL ENTITY. Under the provisions of Rule 30(b)(6), United States Citizenship & Immigration Services (“CIS”) within the United States Department of Homeland Security is required to identity and produce for deposition one or more officers, agents, or employees to testify in its behalf on the following matters:
1. Claim of CIS that adjudication times for Employment-Based I-485 are not unreasonable;
2. Employment-Based I-485 related law and policy including procedures and practice related to processing and tracking at the present time, the time prior to July 2002 going back to and including the year 1989, and future plans for improvements or modifications in the policy, procedure and practice;
3. Adjudication criteria and methods for Employment-Based I-485 AOS used by CIS adjudicators, qualifications possessed by CIS adjudicators and related training and guidance given by CIS to adjudicators;
4. Current backlog reduction plans for Employment-Based I-485 applications, including, related documents, internal memoranda, data and reports, and including problems, issues and proposed solutions;
5. Policies, procedures and practice regarding allocation of funds and resources for adjudication of Employment-Based I-485 applications;
6. Policies and discussions leading to the issuance of an Interoffice Memorandum dated March 31, 2004, regarding “Procedural Instructions for Concurrent Adjudication of Concurrently Filed Form I-140 Immigrant Petition for Alien Worker & Form I-485 Application for Adjustment of Status,” issued by Fujie Ohata, Director of Service Center Operations, and application and implementation of directives contained in this Memorandum;
7. Policies and discussions leading to the issuance of an Interoffice Memorandum dated May 4, 2004, regarding “Requests for Evidence,” issued by William R. Yates, Associate Director, Operations, and application and implementation of directives contained in this Memorandum;
8. Policies and discussions leading to the issuance of an Interoffice Memorandum dated May 16, 2000, regarding “AFM Update: Revision of March 14, 2000 Dual Intent Memorandum,” issued by Michael D. Cronin, Acting Associate Commissioner, Office of Programs, and application and implementation of directives contained in this Memorandum;
9. Procedures and practices relating to Security Clearance and Name Checks of Employment-Based I-485 applicants;
10. Procedures and practices relating to Fingerprinting of I-485 applicants;
11. Procedures and practices relating to the issuance of Employment Authorization Documents to I-485 applicants;
12. Procedures and practice relating to the issuance of Advance Parole to Employment-Based I-485 applicants;
13. CIS Rule-making procedures and policies;
14. Instant litigation (ImmigrationPortal.Com, et al. v. Tom Ridge et al.); and
15. Information possessed by Defendant CIS about existence, identity and custody of documents and records related to the matters stated in the preceding numbered items.
THIS NOTICE NAMES AS THE DEPONENT A GOVERNMENTAL ENTITY. Under the provisions of Rule 30(b)(6), United States Citizenship & Immigration Services (“CIS”) within the United States Department of Homeland Security is required to identity and produce for deposition one or more officers, agents, or employees to testify in its behalf on the following matters:
1. Claim of CIS that adjudication times for Employment-Based I-485 are not unreasonable;
2. Employment-Based I-485 related law and policy including procedures and practice related to processing and tracking at the present time, the time prior to July 2002 going back to and including the year 1989, and future plans for improvements or modifications in the policy, procedure and practice;
3. Adjudication criteria and methods for Employment-Based I-485 AOS used by CIS adjudicators, qualifications possessed by CIS adjudicators and related training and guidance given by CIS to adjudicators;
4. Current backlog reduction plans for Employment-Based I-485 applications, including, related documents, internal memoranda, data and reports, and including problems, issues and proposed solutions;
5. Policies, procedures and practice regarding allocation of funds and resources for adjudication of Employment-Based I-485 applications;
6. Policies and discussions leading to the issuance of an Interoffice Memorandum dated March 31, 2004, regarding “Procedural Instructions for Concurrent Adjudication of Concurrently Filed Form I-140 Immigrant Petition for Alien Worker & Form I-485 Application for Adjustment of Status,” issued by Fujie Ohata, Director of Service Center Operations, and application and implementation of directives contained in this Memorandum;
7. Policies and discussions leading to the issuance of an Interoffice Memorandum dated May 4, 2004, regarding “Requests for Evidence,” issued by William R. Yates, Associate Director, Operations, and application and implementation of directives contained in this Memorandum;
8. Policies and discussions leading to the issuance of an Interoffice Memorandum dated May 16, 2000, regarding “AFM Update: Revision of March 14, 2000 Dual Intent Memorandum,” issued by Michael D. Cronin, Acting Associate Commissioner, Office of Programs, and application and implementation of directives contained in this Memorandum;
9. Procedures and practices relating to Security Clearance and Name Checks of Employment-Based I-485 applicants;
10. Procedures and practices relating to Fingerprinting of I-485 applicants;
11. Procedures and practices relating to the issuance of Employment Authorization Documents to I-485 applicants;
12. Procedures and practice relating to the issuance of Advance Parole to Employment-Based I-485 applicants;
13. CIS Rule-making procedures and policies;
14. Instant litigation (ImmigrationPortal.Com, et al. v. Tom Ridge et al.); and
15. Information possessed by Defendant CIS about existence, identity and custody of documents and records related to the matters stated in the preceding numbered items.