Case 1:14-cv-00119 Document 71 Filed in TXSD on 09/11/15 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF TEXAS
BROWNSVILLE DIVISION
Orly TAITZ,

)
)
Plaintiff,
)
) Civil Action No. 1:14-cv-00119
)
v.
)
)
Jeh JOHNSON, et al.,
)
)
Defendants.
)
___________________________________ )

DEFENDANTS NOTICE TO THE COURT REGARDING IDENTIFICATION

OF DR. TAITZS PATIENTS

Case 1:14-cv-00119 Document 71 Filed in TXSD on 09/11/15 Page 2 of 4

NOTICE
On July 7, 2015, this Court ordered Dr. Taitz to provide a list of the illegal
immigrant children she treated from June 6, 2014 to August 22, 2014 and include the
name (or other identifier) of the patient, date of each treatment, and the reason for each
visit. (ECF No. 70.) Dr. Taitz complied, and provided the Government a list
containing thirty-nine names.
Agencies within DHS and HHS attempted to locate any medical records for Dr.
Taitzs patients, but were unsuccessful in identifying records for any of her patients
because Dr. Taitz did not provide a date of birth (or other identifier) along with the
names. (See Declarations, Contained in the Appendix to this Notice.) For example, the
name of one of Dr. Taitzs patients is so common that DHS had records for at least 184
people with that name. In another instance where there was only one match, that person
came to the United States over 20 years ago and is not a child. Some names yielded no
exact matches.
Defendants attempted to resolve this issue via phone and email with Dr. Taitz,
asking her to provide, at minimum, dates of birth for her patients, which might have
narrowed the database searches and yielded more conclusive information. Ultimately,
undersigned counsel explained the problem to Dr. Taitz in a letter. (See letter from Colin
Kisor to Dr. Taitz dated September 1, 2015, contained in the Appendix to this Notice.)
Dr. Taitz has thus far not provided any amplifying information to her original list, and so
the Governments diligent efforts to determine whether it has any medical records for her
patients have proven fruitless. The Government, consequently, has not turned over any
medical records to Dr. Taitz.

Case 1:14-cv-00119 Document 71 Filed in TXSD on 09/11/15 Page 3 of 4

Should this Court decide to issue a further Order to Dr. Taitz, to re-submit her
patient list to Defendants and include a date of birth (or other conclusive identifier) for
each patient, Defendants could re-run the various database searches in a further effort to
identify whether there are any medical records for any of Dr. Taitzs patients in
Defendants possession.

Respectfully submitted,
/s/ Colin A. Kisor
COLIN A. KISOR
Deputy Director
District Court Section
Office of Immigration Litigation
Civil Division,
U.S. Department of Justice
450 Fifth Street NW
Washington, DC 20001
Telephone: (202) 532-4331
Fax: (202) 305-7000
E-mail: colin.kisor@usdoj.gov
Counsel for Defendants

Case 1:14-cv-00119 Document 71 Filed in TXSD on 09/11/15 Page 4 of 4

CERTIFICATE OF SERVICE

I, Colin Kisor, do hereby certify that on September 11, 2015, I electronically filed
the foregoing with the Clerk of the Court by using the CM/ECF system.

/s/ Colin A. Kisor

COLIN A. KISOR
Deputy Director
District Court Section
Office of Immigration Litigation
Civil Division,
U.S. Department of Justice
450 Fifth Street NW
Washington, DC 20001
Telephone: (202) 532-4331
Fax: (202) 305-7000
E-mail: colin.kisor@usdoj.gov
Counsel for Defendants

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