REQUEST TOM PRODUCE DOCUMENTS IN THE ENVIRONMENTAL SUIT PERTAINING TO ISLAND OF VIEQUES, PUERTO RICO, ENTITLED CARLOS ROMERO-BARCELO, CT AL., V. HAROLD BROWN, ET AL, (CARLOS ROMERO-BARCELLO IS IDENTIFIED AS THE GOVERNOR OF PUERTO RICO

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP81M00980R001400080032-4
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 11
• Document Creation Date: December 16, 2016
• Document Release Date: October 1, 2004
• Sequence Number: 32
• Publication Date: September 20, 1978
• Content Type: MF

OGC 78-6227
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MEMORANDUM FOR : Assoc. Deputy Director for Administration
Assoc. Deputy Director for Operations
Assoc. Deputy Director for National
Foreign Assessment Center
Assoc. Deputy Director for. Science &
Technology
Executive Secretary/DCI
Inspector General
.,/Legislative Counsel
General Counsel
Attn:
25X1
STAT
Office of General Counsel.
SUBJECT Request to Produce Documents in the
Environmental Suit Pertaining to Island
of Vieques, Puerto Rico, Entitled Carlos
Romero-Barcelo, et al. v. Harold Brown,
et al. (Carlos Romero--Barcelo-~is Identified
as the Governor of Puerto Rico in the
Interrogatories.)
Attached is a copy of a self-explanatory letter dated
September. 5, 1978 from the Department of Navy, the first three
pages of the Interrogatories (enclosure 1), the first page
and other pertinent pages in the Supplemental Request to
Produce Documents (enclosure 2) and the one page constituting
the list (enclosure 3).
Item Nos. identify the documents specifi-
cally requested of CIA. See definition number 3 on page two
of the Interrogatories for a description of "document."
Would you please conduct a search and advise me as
soon as possible if your office has any documents responsive
to this request. If you have - ns recrarding this
request, please contact me on
Attachments, a/s
STAT
STAT
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STAT
DEPARTMENT OF THE NAVY
OFFICE OF THE JUDGE ADVOCATE GENERAL
WASHINGTON, D. C. 20370
Office ox the General Counsel
Central Intelligence Agency
Washington, D.C. 20505
IN REPLY REFER TO
JA.G:140:GPL:evb
14/16038
SEP 19Th ,/
. , 7 .
lb~~ ~.1
Re: Interrogatories and Supplemental Request. to
Produce Documents-Environmental. Suit Pertaining
to Island. of Vieques, Puerto Rico
Dear Sir:
Pursuant to Rules 33 and 34 of the Federal. Rules. of Civil
Procedure,-enclosures (1) and (2) are forwarded for response
as to those matters. which arc. under your cognizance. Enclosure
(3) provides specific guidance as-to those interrogatories
and, production requests to which it is requested you provide
answers.
Although the United States and, in particular,..your agency
are not parties to the, instant suit and arc therefore not
legally compelled to. respond to plaintiffs' interrogatories.
and production requests,it.is suggested that you:. respond
inasmuch as plaintiffs are likely to amend their complaint
tb"include your agency as a named party should they meet
with any resistance.
Draft responses should include the number of the interrogatory/
production request, the exact language of the interrogatory/
production request, and the appropr.iateresponse. A sample
format would appear as follows:
a) Interrogatory #43
Answer:.
b) Production Request #21
Answer:
Draft responses should be forwarded to this Office no
later than September 29, 1978. Further inquiries may be
directed to Captain G. P. Lyon, USMCR, of this Office who
may be contacted at: .
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Autovon: 224-4028/32
Commercial: (202) 694--4028/32
Sincerely,
j" X
C:r.i.f)i,11S: J , U-S. Navy
/ifli',--:'r:' (lAiga ion)
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IN THE UNi.TED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO
CARLOS ROMERO--BAItCELO, et al.,
Plaintiffs,
HAROLD BROWN, et al.,
Defendants.
T,UIS MEDINA, et al.,-
Plaintiffs,
Civil Action No. 78-323
V. ) Civil. Action No. 78-377
)
HAROLD BROWN, et al., )
Defendants. )
FIRST SET OF INTERROGATORIES SUBMITTED BY
PLAINTIFFS CARLOS ROF?sERO--BARCELO
GOVERNOR OF PUERTO RICO, ET AL.
TO: HAROLD BROWN, INDIVIDUALLY AND IN HIS CAPACITY AS
SECRETARY OF DEFENSE
W. GRAHAM CLAYTCR, JR., INDIVIDUALLY AND IN HIS
CAPACITY .AS SECRETARY OF Tom' i4AV1.1r
JAMES L. hOLLOWAY, INDIVIDUALLY AND IN HIS: CAPACITY AS
CHIEF O.F.NAVAL OPERATIONS
I I. C. K IDD , JR., INDIVIDUALLY AND IN HIS 'CAPACITY
AS COMMANDER-IN-CHIEF, ATLANTIC FLEET
LOUIS. H. WILSON, INDIVIDUALLY AND IN HIS CAPACITY
AS COMMANDANT, UNITED STATES MARINE CORPS
Plaintiffs Carlos Romero--Bar?celo., et al., request that
each -of you answer, under oath the following interrogatories
in the manner and within the time required by Rule 33 of the
Federal Rules of Civil Procedure or when the Court may
otherwise order.
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its present location, and its present custodian.
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het "-.in, the following definitions and :i_nstruc-
in !?;1ddition to the definitions contained in
lumber.
..The singular shall be deemed to include the plural
in all applicable cases.
2. A7isjunctive/Conjunctive.
The disjunctive shall be deemed to include the
corjurnctive in all applicable cases.
3. ]Document.
The word "document" means the original or a copy
thereof, regardless of origin or location, of any book,
pamphlet, periodical, letter, memorandum, telegram, report,
record, study, handwritten note, . working, paper, chart,
paper, graph, index, tape, data sheet or data processing
card, or any other written, recorded, transcribed, punched,
taped, filmed, or graphic matter, however produced, or
reproduced, which-is in defendants' possession, or to which
defendants' have or have had access, or of which they have
knowledge.. For any "document" identified in response to the
attached interrogatories, indicate whether any such document(s)
has been altered, modified, revised or changed-in any way
whatsoever by any person or entity.
4. Identify.
The word "identify," when used. with respect to a
"document," means to state the name-or title of the "document,"
the type of "document," its date, the person(s) who authorized
it, the person(s) who signed or made it, the person(s) to
whom it was addressed,-the person(s) to whom. it was sent,
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5. Deartment of Defense
The term "Department of Defense" includes the Depart--
ment of Defense, and any entity or entities or person or
persons within the. Department of Defense, or its agents,
including defendants.
j 1.
End of Definitions
Specify the kinds of weapons range activities con-
ducted on Vieques for each year 1968 through the current
month,
a. State the number of hours, rounds fired, live
rounds fired, troops participating in, and the number of
days of artillery practice on Vieques for each year 1968
through the current month;
b. State the number of hours, rounds fired, live
rounds fired, ' ships participating in, and the number of days
of Naval Gunfire Support f 11NGFS'1) on Vieques for each year
1968 through the current month;
c. State the number of hours, rounds fired, live
rounds fired, sorties flown, j et, aircraft participating in,
and the number of days of air-to-ground target practice on
Vieques for each year :1,968 through the current month;
d. State the total number of hours for each year
1968 through the ,current month, during which military
target practice on Viegues occurred after 8:00 p.m..or
before 8:00 a.rn.; .
e. State the number of air-to-ground and ship
missiles fired on-Vieques for each year 1968 through the cur-
rent month.
2. a. Answer Interrogatory No. 1 in.respect of
weapons range activities conducted on Culebra;
'b. Answer Interrogatory No. 1 in respect of wea-
pons range activities conducted at all ranges used by the
Atlantic Fleet;
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IN TI1E UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO
C?1RLOS 1Z01',1LRO-BARCELO, et al.,
Plaintiffs,
v. ) Civil Action No. 78--323
HAROLD BROWN, et al.,
Defendants.
LUIS MEDINA, et al., )
Plaintiffs,
V.
HAROLD BROWN, et al.,
Defendants.
Civil Action No. 78-377
SUPPLEMENTAL REQUEST TO PRODUCE DOCUMENTS
UNDER RULE 34 OF THE -
FEDERAL RULES OF CIVIL PROCEDURE
said interrogatories plaintiffs request copies of memoranda,
reports, research and other documents in connection with
Plaintiffs Carlos Romero-Barcelo, et al. have served
the First Set of Written Interrogatories on defendants.
answers to certain Interrogatories.
Plaintiffs hereby request the production of all docu--
ments requested in said. interrogatories, together with
additional documents (as that term is defined in the First.
Set of Written Interrogatories), as listed hereinafter:
1. A copy of a Navy communication designated
"CINCLANFLT 191417," dated October 1973.
2. A letter from Cameron B. Kepler, U.S. Depart-
ment of Interior to the Navy, dated June 22, 1971.
3. A document entitled "Phase I, Final Report,
Department of the Navy Supplement to Draft Environmental
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23-August 1973 and discussing the relocation of Culebra
to Desecheo.
29. A Navy document design ted AFWR 1020387
September 73, pertaining to an estimate of the training
requirements in the AFWR area regardless of target loca-
tion.
30. The following Navy documents:
.a. COMCARI}3SF 0719502, September 73;
b. COMSECONDFLT.1521112, August 73';
C. ATKCARAIRWINGRES 20 0812242,. August 73;
d. CINCLANTFLT 041915Z, January 72.
31.- All written responses or evaluations by the
Navy of a letter dated August 9, 1971, from Antonio Rivera
Rodriquez, Mayor of Vieques, to Admiral Ward and Captain
Ronald J. Harp, U.S. Naval.Station Roosevelt Roads, Culebra,
PR.
32. All comments made by federal or state govern-
ment agencies on a.document entitled "Draft EIS - Atlantic
Fleet Integrated Weapons Training Range," March 30, 1973.
3. All memoranda, notes, reports, records or
other documents with respect to all meetings or conferences
held by Navy personnel since March 6, 1978, to discuss:
a. the military necessity for the continued
use of Vieques as a target range;
b. alternatives
as a mili.tar target range.
to the current use of Vieques
All memoranda, notes, reports, records or
other documents with respect to all meetings or conferences
held since March 6, 1978, by United States Department of
Defense, State Department, National Security Council, Cen-
tral Intelligence Agency, or other Executive Branch personnel
to discuss:
092 Q-1-An
 Vieques as a t.Lrget range;
`1
6b. alternatives to the current use of Vie--
q lies as a military target range.
35. A copy of the correspondence from Secretary
of Defei se, Melvin Laird, to the U.S. Congress in which the
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a. the necessity for. the continued use of
Secretary's recommendations, derived from the 1971 Culebra
study we e forwarded to Congress.
36. A copy of all correspondence sent by any
member of Congress'to the Office of the Secretary of Defense
in response to the correspondence described in No. 35,
supra.
37. A.copy of all correspondence sent by the
Department of Defense to the Government of the Commonwealth
of Puerto Rico referring to the results or recommendations
of the 1971 Culebra study.'
38. A copy of all memoranda, reports, or re-
sponses to, or any documents evaluating, any of the recom-
mendations of the 1971 Culebra study, by:
a. Department of Defense
b. National Security Council;
C. Department of State;
d. Central Intelligence Agency;
e. Any other entity of the federal govern-
A copy of all directives, orders or other
documents of the Department of Defense, the National Security
Council, or Central Intelligence Agency, or any other entity
of the federal government implementing or intending to
implement any of the recommendations of the 1971 Culebra
study.
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A) Production Request:
34, 38, 39
Enclosure (3)
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 rr s.~ ~.` S HEO ^ 11%V ONLY _j SECRET
pproved For Rely 0/I
5UBJ Ct: (Optional)
FROM: I
Ottice of General Counsel
7C 31 Hqs.
TO: (Officer designation, room number, and
huiiding)
LJrrIAL v
INITTIALS to whom. Draw a line across column attar each come ant.)
FORM
3--62
151 USE EDITIONS S Cl SECRET
CONFIDENTIAL L USE ONLY
COMMENTS (Number each comment to show from whom