Falcon, Denver

To Whom It May Concern:

Pursuant to the Colorado Public Records Law, I hereby request the following records:

U.S. Immigration and Customs Enforcement is conducting raids in several cities, including Denver. (https://www.cnn.com/2019/07/14/politics/ice-raids-undocumented-immigrants/index.html) Authorities are reportedly using a Palantir app called FALCON to assist in these raids (https://www.wnyc.org/story/palantir-directly-powers-ice-workplace-raids-emails-show/).

Therefore, I hereby request the following records from ICE's Denver Field Office:
- All emails from ICE's Denver Field Office from January 1, 2017 to present that mention Palantir's "FALCON" mobile app.
- All instructional materials, presentations and presentation materials (including recorded video and audio, PowerPoint files, prepared remarks, and slides formats), and other guidance materials on the use of Palantir's "FALCON" mobile app from ICE's Denver Field Office.
- A copy of any use policies, standard operating procedures, data retention policies, legal opinions, warranties, non-disclosure agreements, liability waivers, insurance agreements, Memorandums of Understanding, or informal agreements owned by ICE's Denver Field Office that reference Palantir's "FALCON" mobile app or otherwise guide its use.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes. It will be used in the course of reporting for Motherboard, VICE’s science and technology website (www.motherboard.vice.com).

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 3 business days, as the statute requires.

Sincerely,

Caroline Haskins