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Dear EOIR: Don’t Knowingly Make False Statements About Me.

One would think the that senior level officials in the Department of Justice would not knowingly make false statements, especially when they knew that the object of their false statements–me–had evidence dispel even the most flimsy veil of plausible deniability.

Here is EOIR’s statement in full

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I will reveal to the readers the exact process (by showing the EOIR documents that were the sole source that I used to identify 6o Immigration Judges with their respective complaints). By the end, readers will be able to see, without a shred of doubt, that EOIR knowingly made several false statements to the public about my actions.

First, EOIR claims that “A private attorney then took the time to manipulate some of these documents in order to uncover data not accessible on the face of the documents themselves…”

I did not manipulate any documents. Instead, I inadvertently discovered that many of the documents were improperly redacted when I saved the .pdf version as .jpeg version. Specifically, the following set of files all had most or some pages that were not in fact redacted:

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The documents above include several hundred pages. As I was going through each file, I realized that the “Non-responsive Vaughn Index” could be used to identify most of the immigration judges who are referenced in the 8 non-responsive releases. Here are the 5 steps I took to identify the vast majority of the judges in my modified key:

Here it is:

Step 1: Look at the “Vaughn” Index.

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Step 2:  Open the applicable file referenced in the Vaughn index. Here, that  is the  12-20-14 file.

Step 3:  Choose a page number, which for our purposes is Page 2.

Step 4: Read Page 2 and identify Immigration Judge Steve Sholomson.

Step 5: Search EOIR’s original key for the complaint number associated with Page 2, which is complaint # 104.

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Step 6: Conclude that Judge Solomson’s three letter code is NMS

Thus, we can conclude with certainty Jugde Solomson is the subject of all complaint numbers matched to NMS.

Furthermore, at least three Immigration Judges could be identified simply through the fact that EOIR forgot to even use a black highlighter to cover their name: The three Judges who could be identified in this manner are Judge Nugent, Abrams, and Rogers. Here is a step by step example of how Judge Nugent was identified:

Judge James Nugent:

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Opening 619-R-F-pdf and searching for Nugent revealed the following:

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In EOIR’s own key , which assigning random three letter codes to each immigration judge, one can then ascertain the three letter code for the Immigration Judge that is the subject of complaint number 619

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As such, ANY=Judge Nugent.

For some of the Judges identified, none of the complaints were included in the “Vaughn Index.” However, emails officially identified with other Immigration Judges, EOIR explicitly mentioned the complaint number with the Judge.

For example, in this following document, one can identify several immigration judges at once:

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Therefore, we can conclude that IJ Houser’s code is TAD:

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After EOIR alleged that “some members of the…immigration judge corps have been…falsely named in the private attorney’s action” I wanted to add an extra layer of verification to ensure beyond any doubt whatsoever that I had made no mistakes.

To do so, I created 3-4 page files for each Immigration Judge. Each Immigration Judge file has tracks the precise way in which the Judge was identified. Furthermore, each file includes a copy of the summary page for the complaint that the Judge was identified to so that the substance of each document is matched with the actual complaint that the judge is identified with.

For example, here is are final pages from (the first two are immediately are above:

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As one can see, the summary of the complaint for 709 references that basis relating to a motion to reopen. In the email identifying houser, a motion to reopen is mentioned as the basis for the complaint. As such, it is indisputable that IJ Houser’s code is TAD .

Here are the 60 “verifications” for each Immigration Judge identified in my original key.

One caveat: several days prior to EOIR’s false press release, I did notice one IJ was initially misidentified. Originally, I identified FRW as belonging to IJ Dowell. However, when I went through the verification process, I realized that FRW is former IJ Holliday.*

 

Nevertheless, on the day that EOIR published its press release, all 60 Judges were correctly identified, as one can see for themselves by looking at each judge’s verification file.

Therefore, EOIR’s statement that I “falsely named…some members” of the Immigration Judge Corps is itself false.

Additional False Statements Made By EOIR: 

“EOIR has determined that the “key” is inaccurate…”

As you can see above, the key is 100 % accurate. EOIR’s statement is false. And lest one think that EOIR can claim it didn’t thoroughly investigate the veracity of the key,  a report I compiled that tracks the IP addresses of individuals who click on links I created with through my dropbox account shows that the several individuals at the Department of Justice viewed documents related to my IJ key a total of 980 times in a span of only 3 days. 

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From the counter on our firm’s website, where the dropbox links were posted, one can see that the IP addresses that start with 149.101.1.115, etc. are from the DOJ:

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Here EOIR makes another reckless lie:

It is instead a representation of one person’s assumptions based on his own manipulations of the text, which resulted in the errors.”

EOIR represented that I made assumptions to identify each immigration judge even though it knew or should have known that I did not make any assumptions. Instead,  I simply read their own documents that identified each of the 60 immigration judges named.

Also, one can’t conclude that another made assumptions without actually speaking to that person about what the alleged assumptions made were.

Lastly, this:

“… he chose to publish his erroneous findings without any way of verifying his information.”

EOIR knew I could verify the information I published because it knew that the key was 100% accurate. Thus, this statement is false given that it claims I did not have any way of verifying my information.

What EOIR did not foresee was that I would release the documentary evidence to do so.

 

 

 

 

 

*However, the error was only possible because of the sloppy way in which EOIR references the complaint in the first place. In the  Vaughn index for Complaint number 337, two pages were identified, specifically 27 and 28 of the 3-25-14 file.

On page 27, at first glance it appears that the document is related to IJ Dowell. However, upon a closer reading of page 27 and page 28, it was clear that the document was actually referencing former IJ Holliday.

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