Case Information
*1 AUGUST FLENTJE
Acting Director
EREZ REUVENI
Assistant Director
ELISSA FUDIM
Counsel for Defendants
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS ) Civil Action No. 1:25-cv-10495 Svitlana Doe, et al. , )
)
Plaintiffs, )
) v. ) Response to Court’s
Order of April 17, 2025 )
Kristi Noem, in her official capacity as )
Secretary of Homeland Security, et al. , )
)
Defendants. )
)
Defendants respectfully submit the following response to the Court’s electronic Order of April 17, 2025, Doc. No. 99, ordering Defendants to: “notify the court by 2 p.m. on April 18, 2025, whether emails entitled ‘Notice of Termination of Parole,’ have been sent en masse to parolees who entered the United States under any other programs identified in Plaintiffs’ Second Amended *2 Complaint [], including the OAW program, and, if so, whether those parolees also were not intended to receive this message.”
Defendant Department of Homeland Security reports as follows: On April 3, 2025, U.S. Customs and Border Protection (CBP) directed issuance of termination of parole for all paroles granted in the month of April 2023, including paroles granted under Uniting for Ukraine (U4U) and Operation Allies Welcome (OAW); however, a subsequent message was sent to all the U4U and OAW parolees who received the initial notice saying they received the message in error. This consisted of 4,700 U4U parolees and two (2) OAW parolees. Everyone who received a retraction was not intended to have received the termination message.
After April 3, 2025, CBP has continued to send parole termination notices, but it has not sent those notices to parolees identified as having received parole under the programs identified in Plaintiff’s Second Amended Complaint, Doc. No. 68, that is, U4U, OAW, the CHNV parole programs, the Family Reunification Parole (FRP) processes, the Central American Minors (CAM) parole program, and Military Parole in Place (MPIP). If any individuals in these programs received the termination notice, it was not intended.
Dated: April 18, 2025 Respectfully submitted
/s/ Joseph A. Darrow JOSEPH A. DARROW ELISSA P. FUDIM U.S. Department of Justice, Civil Division Office of Immigration Litigation-GLA P.O. Box 868, Ben Franklin Station Washington, DC 20044 202-598-7537 Joseph.a.darrow@usdoj.gov Attorney for Defendants CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 18, 2025, I electronically filed the foregoing with the Clerk of the Court using CM/ECF, which provided an electronic notice and electronic link of the same to all attorneys of record.
/s/ Joseph A. Darrow Trial Attorney
United States Department of Justice Civil Division