conduct has included the following: (1) President Biden’s Department of Homeland Security (hereinafter referred to as DHS ) has willfully refused to maintain operational control of the border as required by the Secure Fence Act of 2006. His actions have directly led to an increase in illegal aliens and illegal narcotics, including deadly fentanyl, entering the United States. (2) President Biden’s administration has willfully violated the Immigration and Nationality Act by releasing illegal aliens into the interior of the United States. The Act clearly requires DHS to detain aliens seeking admission to the United States while they are processed. By law, DHS does not have the option to simply release aliens into the interior of the United States. (3) President Biden has reinstituted the catch and release policies of the Obama administration and has released aliens into the interior of the United States without issuing the aliens notices to appear. (4) Under President Biden’s administration, the Department of Homeland Security terminated the Migrant Protection Protocols, which provided a pathway to process claims in compliance with the law, and served as a deterrent to illegal immigration and aliens making fraudulent asylum claims. (5) As a result of President Biden’s policies, Customs and Border Patrol (hereinafter referred to as CBP ) encounters have increased each month since he became President. Since January 2021, over 6,000,000 border crossers have been encountered by CBP personnel or evaded capture. (6) In addition to illegal aliens, President Biden’s policies have led to a significant increase in illegal drug smuggling across the southern border. Fentanyl now kills over 300 Americans every day. President Biden, by these actions, has made the border less secure and encouraged aliens to enter the United States illegally instead of taking actions to maintain operational control of the border. His actions have thwarted the will of Congress as set forth in duly enacted law and the core tenets of the