A Strategy to Consider Before Filing a Mandamus/APA Lawsuit for Unreasonable Delays or Denials:
Prior to filing suit, tee up a Freedom of Information Act (FOIA) request to ask for documents relevant to the processing of your petition. If, after appeal, the government does not properly or timely comply, include a FOIA count in your lawsuit. Discovery is notoriously difficult to get in Mandamus/APA claims. The FOIA claim can be used as a backdoor tool to pressure the government to provide some relevant documents regarding your case that would otherwise be very difficult to obtain through normal discovery channels. A bonus benefit is that "substantially prevailing" on the FOIA claim could result in the government paying attorney's fees.
* This strategy is not necessarily appropriate in every case and should be discussed with your attorney before implementing.
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source https://www.reddit.com/r/immigration/comments/rh14bs/a_strategy_to_consider_before_filing_a/