P-2010-00382 INITIAL REQUEST
Document Type:
Collection:
Document Number (FOIA) /ESDN (CREST):
05505927
Release Decision:
RIPPUB
Original Classification:
U
Document Page Count:
16
Document Creation Date:
March 9, 2023
Document Release Date:
December 8, 2021
Sequence Number:
Case Number:
F-2011-02160
Publication Date:
February 23, 2010
File:
Attachment | Size |
---|---|
P-2010-00382 INITIAL REQU[16011725].pdf | 688.91 KB |
Body:
Approved for Release: 2021/12/07 C05505927
Chair
Stephen Rohde
President
Douglas Minsk
Chairs Emeriti
Canny Goldberg
Allan K. Jonas
Burt Lancaster'
Irving Lichtenstein, MD.
Jart Morn
Laurie Ostrow'
Stanley K Sheinbaum
'deceased
Chlef Executive Officer
Ramona Ripston
Chief Counsel
Mark O. Rosenbaum
Chief Operating Officer
Heather Carrigan
Chief FinanciaL Officer
Brenda Mauti.
Communications Director
Gordon Smith
Development
Tracy Rice
Legal Director
Hector D. Vitiagra
Managing Attorney &
Manheim Family Attorney
for First Amendment Rights
Peter J. Washers
U
A
A CAN VI /3 SONIC
of U1-11E1134CM.1PQt4tI%
LIWERTY 1 JUSTICE I EQUALITY
By Facsimile, Certified Mail, Return Receipt Requested
January 29, 2009
Department of Justice
FO1A/PA Mail Aden al Unit
Department of Justice
Room 115, LOC Building
Washington, DC 20530-0001
Fax: (301) 341-0772
Federal Bureau of Investigation
David M. Hardy, Chief
Record/Information Dissemination Section
Records Management Division
170 Marcel Drive
Winchester, VA 22602-4843
(540) 868-4591
Federal Bureau of Investigation
Los Angeles Field Office
Attn: FOIA Office
Suite 1700, FOB
11000 Wilshire Blvd.
Los Angeles, CA 90024-3672
INTERPOL � United States National Central Bureau
Allison Tanaka
FOIA/PA Specialist
Office of General Counsel
Washington, DC 20530-0001
(202) 616-9000
National Security Division
Ametta James
FOLk Initiatives Coordinator
Room 6150, 950 Pennsylvania Avenue, N.W.
Washington, DC 20530-0001
(202) 307-3525
1313 WEST EIGHTH STREET LOS AN CA 90017 t 213.977.9500 1213.977.5299 ACLU�50.0N5
Approved for Release 2021/12/07 C05505927
Approved for Release: 2021/12/07 C05505927
Chair
Stephen Rohde
President
Douglas Mireil
Chairs Emeriti
Danny Goldberg
Allan K, Jonas
Burt Lancaster'
Irving Lichtenstein, MO'
Jari Mohn
Laurie Ostrow'
-Stanley K Sheinbaum
'deceased
thief Executive officer
Ramona Rioston
Chief Counsel
Mark D. Rosenbaum
Chief Operating Officer
Heather Carriyan
Chief Financial Officer
Brenda Well
Communications Director
Gordon Smith
Development Director
Tracy Rice
Legal. Director
Hector 0. Vitlagra
Manning Attorney &
Manheim Family Attorney
for First Atnendment RIghls
Peter J. Pliasberg
AC
LIBERTY I JUSTICE I EQUALITY
Department of State
Margaret P. Grafeld
Office of Information Programs and Services
A/ISS/IPS/RL
U. S. Department of State
Washington, D. C. 20522-6001
Fax: (202) 261-8579
Central Intelligence Agency
Adolfo Tarasiulc, Jr,
Chief Information Officer
Washington, D.C. 20505
Department of Defense
Jim Hogan
Defense Freedom of Mformation Policy Office
1155 Defense Pentagon
Washington, D.C. 20301-1155
Fax: (703) 696-4506
Defense Intelligence Agency
Alesia Y, Williams
ATTN: DIAC, DAN-1A
Bldg. 6000
Washington, D.C. 20340-5100
Fax: (301) 394-5356
E-mail; foia@diamil
Defense Security Service
Les Blake
Chief, Office of FOLA and Privacy, GCF
1340 Braddock Place
Alexandria, VA 22314-1651
Fax: (703) 325-5341
E-mail: leslie.blake@mail.dss.mil
National Security Agency
Marianne Stupar
FO1A Requester Servivce Center/DTP4
9800 Savage Road, Suite 6248
Ft. George a Meade, MD 20755-6248
Fax: (301) 688-4762
1313 WEST EIGHTH STREET LOS ANGELES CA 90017 1212.977.9500 f 213.977,5299 ACLU-SC.0R;
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Approved for Release: 2021/12/07 C05505927
Chair
Stephen Rohde
President
Douglas Mirell
Chairs Emeriti
Danny Goldberg
Alien K. Jonas
Burt Lancaster
�
Irving Lichtenstein, MD'
dart Hahn
Laurie Ostrow�
Stanley K. Sheinbaurn
'deceased
Chief Executive Off lea
Ramona Ripston
Chief Counsel
Mark 0, Rosenbaum
Chief Operating Officer
Heather Carrigan
Chief Financial Officer
Brenda Mauli
Communications Director
Gordon Smith
Development Director
Tracy Rice
Legal Director
Hector 0, Vinagre
Managing Attorney &
Manheen Family Attorney
for First Amendment Rights
Petard. Enasberg
ACLU
CA C: LI CR IcS
aumElrn CAL 0 NIA
LIBERTY I JUSTICE I EQUALITY
Office of the Inspector General
Dave Henshall
Senior Advisor, Information and Privacy
400 Army Navy Drive, Suite 1021
Arlington, VA 22202-4704
Fax: (703) 602-0294
Department of Homeland Security
Catherine M. Papal
Deputy Chief FOIA Officer
Director, Disclosure & FOIA
The Privacy Office
245 Murray Drive, S.W.
STOP-0550
Washington, DC 20528-0550
Fax: (703) 235-0443
E-mail: foia@dhs.gov
Bureau of Customs and Border Protection
Mark Hanson
Director
FOIA Division
799 9th Street, NW
Mint Annex
Washington, DC 20229
Fax: (202) 325-0154
United States Immigration and Customs Enforcement
Catnn' Pavlik-Keenan
800 N. Capitol Street
Fifth Floor, Suite 585
Washington, D.C. 20536
Fax: (202) 732-0310
Transportation Security A
Kevin J. Janet
FOIA Officer, TSA-20
601 South 12th Street
Arlington, VA 22202-4220
Fax: (571) 227-1406
'0
1313 WEST EIGHTH STREET LOS ANGELES CA 90017 t 213.977 9E00 f 213.977.5299 ACLU-SC,ORe
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Chair
Stephen Rohde
President
Douglas MireIt
Chairs Emeriti
Danny Goldberg
Anon K. Jones
Duct Lancaster'
lrving Lichtenstein, MO'
Jarl Mohn
Laurie Ostrow'
Stanley K. Sheinbaurn
'deceased
Chief Executive Officer
Ramona Ripston
Chief Counsel.
Mark 0, Rosenbaurn
Chief Operating Officer
Heather Carrigan
Chief Financial Officer
Brenda Maall.
Communications Director
Gard onSmIth
Development Director
Tracy Rice
Legal Director
Hector 0. ViLlegra
Managing Attorney &
Manheim Family Attorney
for First Amendment Rights
PeterJ. Eliasberg
LIBERTY I JUSTICE I EQUAL TV
Under Secretary Office of Intelligence and Analysis
U.S, Depaniment of Homeland Security
FOIA Officer / Requester Service Center- Quinton Mason
Washington, D.C. 20528
Fax: (202) 282-8191
Email� Ouintoninasondhs.gov
Office of the Director of National Intelligence
Washington, D.C. 20511
Fax: (703) 275-1299
Email: dni-foiaugov.gov
Re:
Request Under Freedom of Information Act and Privacy Act
Expedited Processing Requested
Dear FOIA Officer:
This letter constitutes a request for records made pursuant to the Freedom of
Information Act (FOIA), 5 U.S.C. � 552, and the Privacy Act, 5. U.S.C. � 552a, by the
American Civil Liberties � CLU/SC) on
behalf of aereinafter
"Request nvacy act au orizations or Requestors).
The ACLU/SC and Requesters make
information about the federal gov
investigation, and artici ation in the
equest for records to obtain
THE REQUESTORS
The ACLU/SC is a non-profit organization dedicated to defending and securing
the rights granted by the U.S. Constitution and Bill of Rights. ACLU/SC's work
focuses on the First Amendment, equal protection, due process, privacy, and furthering
civil rights for disadvantaged groups. As part of its work, ACLU/SC disseminates
information to the public through newsletters, news briefings, "Know Your Rights"
documents, and other educational and informational materials.
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(b)(6)
(b)(6)
Approved for Release 2021/12/07 C05505927
Chair
Stephen Rohde
President
Douglas Miran
Chairs Emeriti
Danny Goldberg
Allan K, Jonas
Burt Lancaster,
Irving Lichtenstein, 1.10�
Jed Mohn
Laurie Ostrow.
Stanley K. Sheinbaum
"deceased
Chief Executive Officer
Ramona Ripston
Chief Counsel
Mark O. Rosenbaum
Chief Operating Officer
Heather Carrigan
Chief Financial Officer
Brenda Maul(
Communications Director
Gordon Smith
Development Director
Tracy Rice
Legal Director
Hector 0. ViLlag ra
Managing Attorney &
Man helm Family Attorney
for First Amendment Rights
Peter .1. Eliasber
AMERICA /1 UtERI E n
SOUTHef CALIFoRNIA
LIBERTY I JUSTICE I EQUALITY
(b)(6)
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LIBERTY I JU TICE I EQUALLTY
Chair
Stephen Rohde
President
Dougl,as MireLI
Chairs Emeriti
Danny Goldberg
Allan K. Jonas
Burt Lancaster'
Vying Lichtenstein, Mir
Jarl Mahn
Laurie Ostrow'
Stanley K. Sheinbaum
*deceased
Chief Executive Officer
Ramona Ripston
Chief Counsel
Mark D. Rosenbaum
Chief Operating officer
Heather Carrigan
Cltlef Financial Officer
Brenda Maull.
Communications Director
Gordon Smitie
Development Directer
Tracy Rica
Legal Director
Hector O. Villegra
Managing Attorney &
Manheirn Family Attorney
for First Amendment Right
Peter.l. Eliasberg
(b)(6)
7 31 3 WEST EleliTH STREET LOS ANGELES CA 90017 t 21 77.9500 t 213,977.5294 ACLU-SC.0RO
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Chair
Stephen Rohde
President
Douglas Mire!"
cbeirs Emeriti
Danny Goldberg
Allan K Jonas
Burt Lancaster'
Irving Lichtenstein, MD"
Jan. Mahn
Laurie Ostraie
Starney K. Sheinda um
'deceased
Chief Executive Officer
Roman Ripston
Chief Counsel,
Mari( D. Rosenbaum
Chief Operating Officer
Heather Carrigan
Chief Financial Officer
Brenda Malin
Communications Director
Cordon Smith
Development Director
Tracy Rice
Legal Director
Hector O. Viltagra
Managing Attorney &
Manheim Family Attorney
for First Amendment Rights
FeterJ, Ellasberg
I AN CILJ_ *TI
DU CALI ORtliA
LIBERTY I JUSTIC I E UALITY
(b)(6)
THE REQUEST FOR RECORDS
We seek disclosure of any records' from January 1, 1998 to the present, which
were prepared, received, transmitted, collected and/or maintained by the Department of
Justice, the Department of State, the Central Intelligence Agency, the Department of
Homeland Security, the Department of Defense and any of their sub-agencies or
divisions relating to or concerning:'
(b)(6)
(4) Hapimotors (a.k.a Honda Acura Palace or HondAcura Palace). The business
is currently located at 1848 East 55th St, Los Angeles, CA 90058 and
maintains a. web site at wwwha imotors.com.
The term "records" as used herein includes but is not limited to all communications
preserved in electronic or hard copy form, including but not limited to correspondence,
documents, data, videotapes, audio tapes, CDs, DVDs, floppy disks, zip disks, faxes,
files, e-mails, notes (including handwritten notes), letters, summaries or records of
personal conversations, reports and/or summaries of interviews, reports and/or
summaries of investigations, guidelines, evaluations, instructions, analyses, memoranda,
agreements, orders, prescriptions, charts, expressions of statements of policy,
procedures, protocols, reports, rules, training manuals, or studies.
2 The term "concerning" means referring to, describing, evidencing, commenting on,
responding to, showing, analyzing, reflecting, or constituting.
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Chair
Stephen Rohde
President
Douglas Miren
Chairs Emeriti
Danny Goldberg
Altan it, Jonas
Burt Lancaster*
Irving Lichtenstein, MD's'
Jeri Mann
Laurie Ostrow.
Stanley K. Sheinbeum
itcieceased
Chief Executive Officer
Ramona Ripston
Chief Counsel
Mark 0, Rosenbaum
Chief Operating Officer
Heather Carrigan
Chief Financial Officer
Brenda Maua
Communications Director
Gordon Smith
Development bireclQr
Tracy Rice
Legal. Director
Rector 0. Video re
Managing Attorney &
Manheim Family Attorney
for First Amendment Rights
Feter J. Eliasberg
LIBERTY I JUSTICE I EQUALITY
As is apparent from the plain language of this request, we seek not only the contents of
any primary or main files on the Requestors and Hapimotors, but also any records
relating to or concerning any of the Rcques' tors or Hapimotors that may be cross-listed,
cross-referenced or contained in the main file pertaining to another individual or entity.
The request is also meant to include, but not be limited to the entirety of any document
that includes the name of any of the requestors.
SUGGESTED SEARCH TERMS FOR ELECTRONIC SE CHES
To enable an adequate search of all electronic databases, we suggest that you use
the following search terms, among others, to locate responsive records:
(b)(6)
23. Honda Acura Palace
24. HondAcura Palace
25. Hapimotors
26. Hapimotors.com
27, Authentic auto parts
1312 WEST EIGHTH STREET LOS ANGELES CA 90017 t 213.977.9500 f 213.977,5299 ACLLI-SC.OR0
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Approved for Release: 2021/12/07 C05505927
Chair
Stephen Rohde
President
Douglas. MirelL
Chairs Emeriti
Danny Goldberg
Alton K, Jonas
Burt Lancaster'
Irving Lichtenstein, MD�
Jarl Mohn
Laurie Ostrow'
Stanley K. SheinbaUM
'deceased
Chief Executive Office
Ramona Ripston
Chief Counsel
Mark D. Rosenbaum
Chief Operating Officer
Heather Carrigan
Chief Financial Officer
Brenda Maud
Communications Director
Gordon Smith
Development Director
Tracy Rice
Legal Director
Hector 0, \integre
Managing Attorney
Manheim Family Attorney
for First Amendment Rights
Peter J. Eliasberg
A CA IL LISERTIES Ujall
of K. CA I OR IA
LIBERTY I JUSTICE P EQUALITY
REQUEST FOR EXPEDITED PROCESSING
Expedited processing is warranted when there is a "compelling need" for the
information. 5 U.S,C, � 552(a)(6)(E). For requests made by organizations "primarily
engaged in disseminating information," "an urgency to inform the public about actual or
alleged federal government activity" constitutes a "compelling need." 5 U.S.C, �
552(a)(6)(E)(v)(LI),3
This request implicates a matter of urgent public concern: namely, the nature and
extent of the federal government's surveillance and detention of American citizens in
the name of national security. Information regarding the federal government's handling
(b)(6)
mformation is of urgent public concern as the federal government seeks to improve its
surveillance and investigative techniques in the face of new terrorism threats, while
balancing concerns for civil liberties.
This request is also made by an organization, the ACLU/SC, "primarily e ged
in disseminating information." 5 U.S.C. � 552(a)(6)(E)(v)(E); 6 CIR. � 5.5(d)(1)(ii).
3 See also Amer. Civil Liberties Union v U,S. Dept of Defense, 2006 WL 1469418
(ND. Cal. 2006) (ordering expedited processing of a request for records under the FOIA
statute where plaintiffs had alleged a compelling need to know about the Department of
Defense's practice of gathering information on political protests in the United States);
Washington Post v. Dept of Homeland Sec., 459 F. Supp. 2d 61, 66 (D.C.C. 2006)
(holding that expedited processing of a request for information from the Secret Service
about who visited Vice-President Cheney during CIA-leak investigation was proper
under the statute where plaintiff had asserted "statutory entitlement to expedited review
of the FOIA request, based on the statutory predicate that the plaintiff has a 'compelling
need' for the information."); Elec. Privacy Info. Cm v. Dep 't opustice, 416 F. Supp, 2d
30 (D.D.C.2006) (ranting a preliminary injunction and ordering expedited processing
and disclosure of documents concerning the Bush Administration's policy of conducting
surveillance of domestic communications).
1313 WEST EIGHTH STREET LOS ANGELES CA 90017 t 213,977.9500 f 213.977,5299 ACLU�SC.ORG
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Chalr
Stephen Rohde
President
Douglas Mire1.1.
Chairs Emeriti
Danny SolCberg
Allan K. Jonas
Burt Lancaster'
Irving Lichtenstein, Mu`
JarL Mohn
Laurie Ostrow'
Stanley K. Sheinbaurn
'deceased
Chief Executive Office
Ramona Ripston
atiaf Counset
Mark D. Rosenbaum
Chief Operating Officer
Heather Carrigan
Chief Financial Officer
erenda Mau1.1
Communications Director
Gordon Smith
Development 13 tor
Tracy Rice
Legal Director
Hector 0. Vitlagra
Managing Attorney &
Man helm Family Attorney
For First Amendment Rights
PaterJ.E0asberg
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LIBERTY I JUSTICE I EQUALITY
See American Civil Liberties Union v. Dep't of Justice, 321 F. Supp, 2d 24, 30 n.5
(D.D,C. 2004) (non-profit public interest group that "gathers information of potential
interest to a segment of the public, uses its editorial skills to turn the raw material into a
distinct work, and distributes that work to an audience," is "primary engaged in
disseminating information"). Dissemination of information to the public is a critical and
substantial component of the ACLU/SC's mission and work. The ACLU/SC
disseminates information to the public through newsletters, news briefings, 'Know Your
Rights" documents, and other educational and informational materials. ACLU/SC also
disseminates information to individuals, tax-exempt organizations, not-for-profit groups,
and members through its website, http://www+aclu-sc,org, The ACLU/SC website
homepage includes a section for news, along with links to information about cm-rent
issues of public interest. The website also contains archives of press releases and other
documents demonstrating the thorough extent to which the ACLU/SC disseminates
information to the public on numerous issues. See www.aelu-sc.orginews stories.
The ACLU/SC also shares information with the national ACLU office, The
ACLU publishes information through multiple outlets including newsletters, action
alerts, videos, and other media. ACLU publications are disseminated across the county
to individuals and organizations. The ACLU also publishes an electronic newsletter,
which is distributed to subscribers by e-mail, and maintains a website of civil rights and
civil liberties information at http.//www.aclu.org.
Expedited processing is also warranted because the information sought relates to
"[a] matter of widespread and exceptional media interest in which there exist possible
questions about the government's integrity which affect nnblict rnnfiripnre," 28 CFR,
� 16.5(d)(1)(iv). The instant request relates to a matter of
exceptional media interest, which is reflected in the widessread news cove a e of his
ease in local national and international media owl
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their
Stephen Rohde
President
Douglas Miren
Chairs Emeriti
Danny Goldberg
Adtan K. Jonas
Burt Lancaster'
Licaitenstein, MD'
Jeri. Mohn
Laurie Ostrow'
Stanley K. Sheinbaum
'deceased
Chief Executive Officer
Ramona RipSton
Chief Counsel
Mark 0, Rosenbau
Chief Operating Officer
Heather Carrigan
Chief Financial Officer
Brenda Nlau[I.
Cenununications Dime-tor
Gordon Smith
Development Director
�racy Rice
Legal Director
Hector 0, Vildagra
Managing Attorney &
Manheim Family Attorney
for First Amendment Rights
Peter J. EtiasSere
LIBERTY I JUSTICE I EtUAI.iTY
(b)(6)
Accordingly, the Requesters are entitled to expedited processing of this request.
LIMITATION OR WAIVER OF SEARCH AND REVIEW FEES
We request a limitation of processing fees pursuant to 5 U.S.C. �
552(a)(4)(A)(ii)(11) ("fees shall be limited to reasonable standard charges for document
duplication when records are not sought for commercial use and the request is made by
... a representative of the news media ...") and 6 C.F.R. � 5.11(d)(1) (search fees shall
not be charged to "representatives of the news media"). The information sought in this
request is not sought for a commercial purpose. The Requestors include a non-profit
organization who intends to disseminate the information gathered by this request to the
public at no cost.
The "term 'a representative of the news media' means any person or entity that
gathers information of potential interest to a se cut of the public, uses its editorial
skills to turn the raw materials into a distinct work, and distributes that work to an
audience." 5 U.S.C. � 552(a)(4)(A)(ii). The statutory definition does not requite that
the requester is a member of the traditional media. As long as the requester meets the
definition in any aspect of its work, it qualifies for limitation of fees under this section
of the statute.
For the reasons stated above with respect to expedited processing, the ACLU/SC
qualifies as a "representative of the news media" under the statutory definition, because
the ACLU/SC routinely gathers information of interest to the public, uses editorial skills
to turn it into distinct work, and distributes that work to the public. See Electronic
Privacy Information Center v, Department of Defense, 241 F. Supp. 2d 5 (D.D.C. 2003)
(non-profit organization that gathered information and published it in newsletters and
otherwise for general distribution qualified as representative of news media for purpose
of limiting fees). Accordingly, any fees charged must be limited to duplication costs.
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LIBERTY I JUSTICE I EQUALITY
WAIVER OR REDUCTION OF ALL COSTS
Chair
Stephen Rohde
President
Douglas Mimi'.
Chairs Emeriti
Danny Goldberg
Adam K, Jonas
Sort Lancaster'
Irving Lichtenstein, MD'
Jarl Mahn
Laurie Ostrow'
Stanley K. Sheinbaum
'deceased
Chief Executive Officer
Ramona Rhoston
Chief Counsel
Mark D. Rosenbaum
Chief Operating Officer
Heather Carrigan
Chief Financial Officer
B rend a Maul;
Communications Director
Gordon Smith
Development Director
Tracy Rice
Legal Director
Hector O. Villagre
Managing Attorney St.
Manheim Family Attorney
for First Amendment Rights
Pete"J, Eliasberg
1313 WEST EIGHT
We request a waiver or reduction of all costs pursuant to 5 U.S.C. �
552(a)(4)(A)(iii) ("Documents shall be furnished without any charge . if disclosure of
the information is in the public interest because it is likely to contribute significantly to
public understanding of the operations or activities of the government and is not
primarily in the commercial interest of the requester"); see also 6 C.F.R. � 5.11(k).
The public interest fee waiver provision "is to be liberally construed in favor of
waivers for noncommercial requesters." McClellan Ecological Seepage Situation v,
Carlucci, 835 F.2d 1282, 1284,(9th Cir. 1987). The Requesters need not demonstrate
that the records would contain evidence of misconduct. Instead, the question is whether
the requested information is likely to contribute significantly to public understanding of
the operations or activities of the government, good or bad. See Judicial Watch, Inc, v.
Rossotti, 326 F.3d 1309, 1314 (D.C. Cir. 2003),
Disclosure of the information sought is in the public interest and will contribute
significantly to public understanding of the federal government's policies and practices
of monitoring, surveillance, questioning, and participation in overseas detention and
torture of American citizens. As shown by the news reporting cited above, these issues
are of intense public concern. The requested records relate directly to operations or
activities of the government that potentially impact or infringe fundamental rights and
freedoms. The records are not sought for commercial use, and the Requestors plan to
disseminate the information disclosed through print and other media to the public at no
cost, and through meetings with members and affected communities. As demonstrated
above, the Requestors have both the intent and ability to convey any information
obtained through this request to the public.
The Requestors state "with reasonable specificity that [their] request pertains to
operations of the government," and "the informative value of a request depends not on
there being certainty of what the documents will reveal, but rather on the requesting
party having explained with reasonable specificity how those documents would increase
public knowledge of the functions of the government." Citizens for Responsibility and
Ethics in Washington it US. Dept. of Health and Human Services, 481 F. Supp. 2d 99,
107-109 (D.D,C. 2006).
In the event a waiver or reduction of costs is denied, please notify me in advance
if the anticipated costs exceed $100.
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Chair
Stephen Rohde
President
Douglas MirelL
Chairs Emeriti
Danny Goldberg
ARan K. Jones
Burt Lancaster'
Ir../n 9 Lichtenstein, MD'
Jari Mohn
Laurie Ostrow'.
Stanley K. Sheinaum
"deceased
Chief Executive Officer
Ramona Ripston
Chief Counsel
Mark 0. Rosenlodu
Chief Operating Officer
Heather Carrigan
Chief Financial Officer
Brence Maul].
Communications Director
Gordon Smith
Development Director
Tracy Rice
Legal Director
Hector 0 � VILIagra
Managing Attorney &
Manheim Family Attorney
for First Amendment Rights
PeterJ, Ellasberg
?.i1I.RIL AN C IL I R
OtIT IThkti cAill ORLI
LIBERTY I JUSTICE I EQUALITY
CONCLUSION
If this request is denied in whole or part, please justify all deletions by reference
to specific FOIA exemptions. We expect you to release all segregable portions of
otherwise exempt material. For example, we expect you to redact names of individuals
for whom privacy waivers are not enclosed, if such redaction is required by the Privacy
Act or other law, and release any otherwise disclosable records as redacted, We also
expect that this FOIA request will be processed in accordance with the presumption of
disclosure and President Obama's directive to federal agencies on January 26, 2009.
Pres. �barna, Memo for the Heads of Exec. Offices and Agencies, Freedom of
Information Act, 74 Fed. Reg. 4683 (Jan. 26, 2009) ("The Freedom of Information Act
should be administered with a clear presumption: In the face of doubt, openness
prevails. The Government should not keep information confidential merely because
public officials might be embarrassed by disclosure, because errors and failures might
be revealed, or because of speculative or abstract fears,").
We reserve the right to appeal a decision to withhold any infoirnation, or to deny
expedited processing or a waiver of fees. We look forward to your reply to the request
for expedited processing within ten (10) calendar days, as required under $ �
552(a)(6)(E)(ii)(1). Notwithstanding your decision on the matter of expedited
processing, we look forward to your reply to the records request within twenty (20)
business days, as required under 5 U.S.C. � 552(a)(6)(A)(1').
If you have questions, please contact Jennie Pasquarella at 213-977-5236 or via
e-mail at ipasquarella@aclu-sc.orn. Thank you in advance for your timely consideration
of this request Please furnish records as soon as they are identified to the undersigned
at:
ACLU of Southern Califo
1313W. Eighth Street
Los Angeles, CA 90017
a
I certify that the information provided supporting the request for expedited
processing is true and correct to the best of our Imowledge and belief.
Sincere
(b)(6)
asquarella
Attorney
ACLU of Southern California
1313 WEST EIGHTH STREET LOS ANGELES CA 90017 t 213.977,9500 f 212.977.5299 ACLU-SC.0RO
Approved for Release: 2021/12/07 C05505927
Approved for Release: 2021/12/07 C05505927
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of SMAt3Wg 8th Street, LatAktgtids, CA 9Q026 n regnest udder
the Freedom of Wormatlitta Act and the PriNacy Act to .the f&le$,: gcernrnent and to-receive
responsive,doeuments :OD rny bdhalf
I declare d penalty of
forego is true and correct
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2021/12/07 C05505927
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(b)(6)
(b)(6)
Approved for Release: 2021/12/07 C05505927
AUTHORIZATION
hereby authorize attorneys from the ACLU
of Southern California, 1313 West 8th Street, Los Angeles, CA 90026, to submit a request under
the Freedom of Information Act and Privacy Act to the federal government and to receive
responsive documents on my behalf
I declare under penalty of perjury that the foregoing is true and correct
Executed on September 0 4",2009, in
Approved for Release
am (pnnt)
Address
City,
te Zip
Signature
2021/12/07 C05505927
T All KHAN
0182286a
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California
(b)(6)
(b)(6)
(b)(6)
(b)(6)
(b)(6)
(b)(6)
(b)(6)
Approved for Release: 2021/12/07 C05505927
AUTHORIZATION
hereby authorize attorneys from the ACLU
of Southern California, 1313 West 8th Street, Los Angeles, CA 90026, to submit a request under
the Freedom of Inforniation Act and Privacy Act to the federal government and to receive
responsive documents on my behalf.
declare under penalty of perjury that the foregoing is true and correct.
Executed on September 9 , 2009, in
'Nair (,prim)
Address
(b)(6)
flUSIIMET ALi KHAN
Commission 1822860
try Public � California
Los Angeles County
Comm.Expires Nov 16,20
(b)(6)
Approved for Release: 2021/12/07 C05505927