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joeb

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Posts: 8,574
Reply with quote  #1 




https://whowhatwhy.org/2019/08/10/jeffrey-epstein-death-a-little-skepticism-is-warranted/

AUGUST 10, 2019 | RUSS BAKER
JEFFREY EPSTEIN DEATH: A LITTLE SKEPTICISM IS WARRANTED


How and why did Jeffrey Epstein die? Did he commit suicide to escape an embarrassing trial and a lengthy prison sentence as a child rapist? Or did he know too much about too many powerful people who did not want to be implicated? In any case, any serious person would admit that the timing was most convenient.
It is also curious that he supposedly attempted suicide once before. So shouldn’t the authorities at a  federal facility have been monitoring him? Amazingly, Epstein reportedly had been taken off  “suicide watch” a few days ago.  Could somebody whose power extended into a federal prison have used that first attempt as cover for an “involuntary suicide?”
Are we allowed even to talk about such possibilities? Ever since the CIA in 1967 issued a memo recommending the use of terms like “conspiracy theorist” to discourage inquiries in non-consensus directions, the corporate media has marched in lockstep to that tune.
It has continuously deployed this disparaging term to cast a cloud over a diverse range of individuals who have  nothing in common. These range from those who accept the most outrageous default explanation for almost everything, to serious investigators who wonder if it is possible that, say, every powerful politician in America has been killed by a “lone nut” —  this, while in other countries, people assume a reasonable probability that more may have been going on.
Besides, we know that actual conspiracies happen all the time.  Just a few examples of notorious conspiracies include long-denied and covered-up but ultimately documented plots by America’s intelligence services in which elected foreign leaders were deposed and murdered.  Then there are large conspiracies of the sort found in the Iran-Contra Affair. And all the price-fixing conspiracies And of course the stuff of “true crime,” in which everyone from spouses and lovers to business partners and enemies get together with others and secretly work out how to snuff someone.
What of Epstein? Does he seem like the sort that someone else might want out of the way?
Not only did association with him hang over a former and a current president, a corporate titan and a member of the British royal family, but also all manner of wealthy and famous people, plus a particularly voluble and litigious lawyer and const






https://freepressonline.com/Content/Default/Tapley-archives-2019/-3/990

Deep State: Threats




https://www.nydailynews.com/new-york/brooklyn/ny-brooklyn-nypd-supervisor-sexual-harassment-20190812-gzyxiyhohzb2ljg7dd6cfrzl5y-story.html


“NOW HE CAN DO WHATEVER HE WANTS:” NYPD lieutenant accused of sexually harassing female precinct employee now works for Internal Affairs Bureau

By ESHA RAY

NEW YORK DAILY NEWS |
AUG 12, 2019 | 6:00 AM




https://www.theguardian.com/world/2019/aug/12/hong-kong-protests-brutal-undercover-police-tactics-spark-outcry

Hong Kong protests: brutal undercover police tactics spark outcry
Footage of helmeted protesters suddenly making arrests causes concern after weekend of intense clashes


https://www.theguardian.com/environment/2019/aug/12/west-virginia-appalachia-miners-green-new-deal

Coal is over': the miners rooting for the Green New Deal
Appalachia’s main industry is dying and some workers are looking to a new economic promise after Trump’s proves empty


https://www.theguardian.com/sport/2019/aug/12/concerns-rise-with-tokyo-heat-after-rowers-treated-at-olympic-test-event

Olympic Games 2020
Concerns rise with Tokyo heat after rowers treated at Olympic test event
*                 British athlete among those treated for heatstroke
*                 Concerns also raised about wellbeing of spectators


https://www.foxnews.com/auto/jeffrey-epstein-former-cellmate-apparent-suicide-attempt

Jeffrey Epstein feared cellmate, a muscle-bound ex-cop charged in murder who was moved before financier's death: report



https://sports.yahoo.com/chicago-cop-in-trouble-after-hulk-hogan-livestreams-ride-along-on-airport-tarmac-155734427.html


Chicago cop in trouble after Hulk Hogan live-streams ride along on airport tarmac

Blake Schuster
Yahoo Sports Contributor
Yahoo SportsAug 10, 2019, 11:57 AM


https://time.com/5649505/michigan-police-officer-kkk/

Probe of Michigan Police Officer's KKK Document May Lead to New Investigation of 2009 Shooting.



https://newsmaven.io/pinacnews/eye-on-government/federal-judge-orders-release-of-cop-s-employment-record-in-excessive-force-video-xoa4fl8PGUyOl---CdQjyg/

Federal Judge Orders Release of Cop's Employment Record in Excessive Force Video





https://nypost.com/2019/08/09/ex-baltimore-cop-gets-nine-months-in-jail-for-pummeling-suspect/

Baltimore cop gets nine months in jail for pummeling suspect




https://meduza.io/en/feature/2019/08/12/a-masked-moscow-riot-cop-gut-punched-a-woman-last-saturday-now-there-s-a-100-000-ruble-reward-for-information-leading-to-his-name

A masked Moscow riot cop gut-punched a woman last Saturday. Now there’s a 100,000-ruble reward for information leading to his name.
6:08 am, August 12, 2019Source: Meduza



https://newsmaven.io/pinacnews/cops-in-cuffs/connecticut-cop-arrested-for-alleged-57-000-medicaid-fraud-tIkfHBVuxESz4FKe71986g/

Connecticut Cop Arrested for Alleged $57,000 Medicaid Fraud


https://newsmaven.io/pinacnews/cops-gone-rogue/texas-detective-sentenced-to-prison-for-helping-drug-cartels-deliver-1000-kilos-4wFiYACNE0C95tGJ4-Qn8A/

Texas Detective Sentenced to Prison for Helping Drug Cartels Deliver 1000 Kilos


https://newsmaven.io/pinacnews/eye-on-government/pennsylvania-judge-rules-vehicle-search-prompted-by-only-marijuana-odor-illegal-OrQYp1gm4EWDE3Kv8w8H-Q/

Pennsylvania Judge Rules Vehicle Search Prompted by Only Marijuana Odor Illegal


https://newsmaven.io/pinacnews/citizen-journalism/watch-cops-tackle-arrest-man-for-giving-finger-saying-f-the-police-WQD02mNn0ky4FhhaaAIycA/

WATCH: Cops Tackle, Arrest Man for Giving Finger, Saying F the Police


https://newsmaven.io/pinacnews/citizen-journalism/trooper-rips-out-car-window-i-m-not-going-to-talk-to-you-through-a-crack--Rt3tWB3z0eNbbzaX-eIqw/

Trooper Rips Out Car Window: "I'm not Going to Talk to You Through a Crack!"



https://newsmaven.io/pinacnews/eye-on-government/la-deputy-investigating-teen-girl-s-rape-sentenced-to-3-years-for-raping-her-zcunYw0PO0eUkpJM8my3gQ/



LA. Deputy Investigating Teen Girl's Rape Sentenced to 3 Years for Raping her



https://www.nbcnewyork.com/on-air/as-seen-on/Vigil-Held-at-Queens-Nail-Salon-Where-Woman-Was-Killed_New-York-529147581.html


Cop says Shoot 50 cent







https://www.theroot.com/florida-white-supremacist-arrested-for-plot-to-shoot-up-1837146937

Photo: Orange County Jail
Florida cops arrested a 26-year-old man Friday after he threatened to shoot up a Walmart—FBI Still Fixated on ‘Black Identity Extremists’

Anne Branigin
Yesterday 12:19pmFiled to: PR




https://www.cnn.com/videos/us/2019/08/11/hate-crime-data-federal-reports-heather-heyer-khalid-jabara-sidner-pkg-vpx.cnn

Why Heather Heyer's name isn't on FBI hate crime list
In August 2017, a neo-Nazi drove his car into counter-protesters in Charlottesville, Virginia, killing Heather Heyer and injuring many more. But if you look at the federal hate crimes report, it's like it never happened at all. CNN's Sara Sidner reports.Source: CNN



https://m.washingtontimes.com/news/2019/aug/11/bruce-ohr-gave-fbi-false-information-trump-judicia/

Clinton operatives fed false information to FBI on Trump, review of interview reveals





https://www.wsj.com/articles/fbi-and-facebook-potentially-at-odds-over-social-media-monitoring-11565277021

Why would FBI agents create mass shooting events?

*                 TECH
FBI Surveillance Proposal Sets Up Clash With Facebook
Agency solicits vendor proposals to collect data from Facebook, other social media to head off safety threats



https://whowhatwhy.org/2018/04/04/the-fbi-in-peace-war-and-assassination/

APRIL 4, 2018 | JEFF SCHECHTMAN
THE PLOT TO KILL KING
A Look at Who Really Killed Martin Luther King

The evidence that James Earl Ray did not kill Martin Luther King is overwhelming. As the Washington Post recently pointed out, famed attorney William Pepper stands astride all of the information and work that has uncovered the truth.
Pepper was a friend of King in the last years of his life. Some years after King’s death, Pepper went on to represent James Earl Ray in his guilty plea and subsequent conviction. But Pepper believes that Ray was framed by the FBI, the CIA, the military, the Memphis police, and organized crime figures from New Orleans and Memphis.
In this WhoWhatWhy podcast, William Pepper talks to Jeff Schechtman about the totality of the case. He tells of his initial interview with Ray, 40 years ago, and why it became clear to him right away that Ray was innocent. Pepper explains that Ray had no motive for the shooting, that he acted at the direction of his handler, a man named “Raoul,” with clear ties to Hoover and the FBI.
Pepper explains how, over the years, the evidence has mounted about Hoover’s hatred of King, which lay behind the FBI’s unending surveillance of King and the entire civil rights movement, and why Hoover sent his number two man, Clyde Tolson, to Memphis to help oversee the assassination of King and to help set up Ray as the patsy.
It’s a story that actually begins a half century ago today, in a hospital emergency room in Memphis. Pepper thinks it’s possible that King did not die from the gunshot wound — but that he was actually murdered in that emergency room.
William F. Pepper is the author of The Plot to Kill King: The Truth Behind the Assassination of Martin Luther King, Jr. (Skyhorse Publishing,  January 16, 2018).



https://whowhatwhy.org/2019/08/11/the-terrible-toll-of-grand-theft-auto/

The Terrible Toll of Grand Theft Auto
Reading Time: 4 minutes
How many fatalities on the world’s roads does Super Mario Kart cause each year? What role did the game Call of Duty play in the invasion of Iraq? And when will the video game industry be held to account for the carnage it causes?



http://ticklethewire.com/2019/08/12/fbi-investigates-epsteins-apparent-suicide-amid-mounting-conspiracy-theories/



Organization who assassinated Epstein and Dr King investigate the crime.
FBI Investigates Epstein’s ‘Apparent Suicide’ Amid Mounting Conspiracy Theories




http://www.fbicover-up.com


Welcome to our website about the murder of Vince Foster, Deputy White House Counsel under President Clinton.  Brett Kavanaugh was in charge of the Foster death investigation and led the cover-up inside the Office of the Independent Counsel.  A federal court ordered Independent Counsel Ken Starr to include evidence, found in government records, of an FBI cover-up, to the final Report. 



https://www.amazon.com/Failure-Public-Trust-FBI-cover-up-com/dp/B002IXVSIA

Failure of the Public Trust, FBI cover-up.com : Proof of FBI and OIC Cover-Up in: John; Knowlton, Patrick; Turley, Hugh Clarke: Amazon.com: Books
Failure of the Public Trust, FBI cover-up.com : Proof of FBI and OIC Cover-Up in [https://www.amazon.com/Failure-Public-Trust-FBI-cover-up-com/dp/B002IXVSIAJohn; Knowlton, Patrick; Turley, Hugh Clarke] on Amazon.com. *FREE* shipping on qualifying offers.






http://www.gopusa.com/jeffrey-epsteins-death-stinks/


Jeffrey Epstein’s Death Stinks




https://lasvegas.cbslocal.com/2016/08/10/the-list-of-clinton-associates-whove-died-mysteriously-check-it-out/




The List of Clinton Associates Who Allegedly Died Mysteriously. Check It Out.
August 10, 2016 at 7:57 am
Filed Under:2016, bill clinton, Clinton, Clinton death list, Hillary Clinton, mysterious Clinton deaths, Politics
This is a message that began being forwarded via email in the mid-1990s of various Bill and Hillary Clinton associates alleged to have died under mysterious circumstances. This conspiracy theory continued to resurrect itself during Hillary Clinton’s 2008 and 2016 presidential bids.
 
===============

THE CLINTON DEAD POOL
1- James McDougal – Clintons convicted Whitewater partner died of an apparent heart attack, while in solitary confinement. He was a key witness in Ken Starr’s investigation.
2 – Mary Mahoney – A former White House intern was murdered July 1997 at a Starbucks Coffee Shop in Georgetown .. The murder …happened just after she was to go public w:th her story of sexual harassment in the White House.
3 – Vince Foster – Former White House counselor, and colleague of Hillary Clinton at Little Rock’s Rose Law firm. Died of a gunshot wound to the head, ruled a suicide.
4 – Ron Brown – Secretary of Commerce and former DNC Chairman. Reported to have died by impact in a plane crash. A pathologist close to the investigation reported that there was a hole in the top of Brown’s skull resembling a gunshot wound. At the time of his death Brown was being investigated, and spoke publicly of his willingness to cut a deal with prosecutors. The rest of the people on the plane also died. A few days later the Air Traffic controller commited suicide.
5 – C. Victor Raiser, II – Raiser, a major player in the Clinton fund raising organization died in a private plane crash in July 1992.
6 – Paul Tulley – Democratic National Committee Political Director found dead in a hotel room in Little Rock , September 1992. Described by Clinton as a “dear friend and trusted advisor”.
7 – Ed Willey – Clinton fundraiser, found dead November 1993 deep in the woods in VA of a gunshot wound to the head. Ruled a suicide. Ed Willey died on the same day his wife Kathleen Willey claimed Bill Clinton groped her in the oval office in the White House. Ed Willey was involved in several Clinton fund raising events.
8 – Jerry Parks – Head of Clinton’s gubernatorial security team in Little Rock .. Gunned down in his car at a deserted intersection outside Little Rock Park’s son said his father was building a dossier on Clinton He allegedly threatened to reveal this information. After he died the files were mysteriously removed from his house.
9 – James Bunch – Died from a gunshot suicide. It was reported that he had a “Black Book” of people which contained names of influential people who visited prostitutes in Texas and Arkansas
10 – James Wilson – Was found dead in May 1993 from an apparent hanging suicide. He was reported to have ties to Whitewater..
11 – Kathy Ferguson – Ex-wife of Arkansas Trooper Danny Ferguson, was found dead in May 1994, in her living room with a gunshot to her head. It was ruled a suicide even though there were several packed suitcases, as if she were going somewhere. Danny Ferguson was a co-defendant along with Bill Clinton in the Paula Jones lawsuit Kathy Ferguson was a possible corroborating witness for Paula Jones.
12 – Bill Shelton – Arkansas State Trooper and fiancee of Kathy Ferguson. Critical of the suicide ruling of his fiancee, he was found dead in June, 1994 of a gunshot wound also ruled a suicide at the grave site of his fiancee.
13 – Gandy Baugh – Attorney for Clinton’s friend Dan Lassater, died by jumping out a window of a tall building January, 1994. His client was a convicted drug distributor.
14 – Florence Martin – Accountant & sub-contractor for the CIA, was related to the Barry Seal, Mena, Arkansas, airport drug smuggling case. He died of three gunshot wounds.
15 – Suzanne Coleman – Reportedly had an affair with Clinton when he was Arkansas Attorney General. Died of a gunshot w
0
joeb

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Posts: 8,574
Reply with quote  #2 




https://www.courthousenews.com/reported-hate-crimes-on-the-rise-but-federal-prosecutions-drop/

Reported Hate Crimes on the Rise, But Federal Prosecutions Drop
August 13, 2019


https://www.courthousenews.com/black-lives-matter-protest-liability/?eType=EmailBlastContent&eId=fb9bde8b-8f53-467b-8908-1335bae872e0

August 9, 2019
BRIEF


BATON ROUGE, La. – A district court improperly dismissed an officer’s negligence claim against the organizer of a 2016 Black Lives Matter protest in Baton Rouge, the Fifth Circuit ruled. The officer alleges the organizer led demonstrators onto a highway and provoked an altercation between police and protestors, causing the officer’s injuries. 
The officer has sufficiently alleged that his injuries were the result of organizer DeRay Mckesson’s “own tortious conduct in organizing a foreseeably violent protest.”



https://www.usnews.com/news/best-states/maryland/articles/2019-08-09/baltimore-police-hire-fbi-agent-to-lead-integrity-bureau


Baltimore Police Hire FBI Agent to Lead Integrity Bureau
Baltimore's Police Commissioner has named a senior FBI agent as the head of the department's Public Integrity Bureau, which oversees officer misconduct investigations and has faced criticism




https://www.google.com/search?q=john+conditt&ie=UTF-8&oe=UTF-8&hl=en-us&client=safari#imgrc=W1abGJtC-8qhxM:


John Conditt




http://archive.boston.com/news/nation/articles/2004/02/18/retired_fbi_agent_guilty_of_sex_abuse/

Retired FBI agent guilty of sex abuse
Was bureau's chief of internal affairs
By Associated Press  |  February 18, 2004
WASHINGTON -- The former chief internal watchdog at the FBI has pleaded guilty to sexually assaulting a 6-year-old girl and has admitted he had a history of molesting other children before he joined the bureau for what became a two-decade career.
John H. Conditt Jr., 53, who retired in 2001, was sentenced last week in Tarrant County Court in Fort Worth to 12 years in prison after he admitted he molested the daughter of two FBI agents after he retired. He acknowledged molesting at least two other girls before he began his law enforcement career, his lawyer said.
Conditt sought treatment for sex offenders after his arrest last year, said his attorney, Toby Goldsmith.
"The problem these people have is they don't really feel like it is their fault," Goldsmith said. "The treatment doesn't work unless you admit you are the one who instigated it, and he did that."
Conditt headed the internal affairs unit, which investigates agent wrongdoing, for the Office of Professional Responsibility at FBI headquarters in Washington from 1999 until June 2001, the FBI said.
FBI officials said yesterday they had no information suggesting Conditt had any problems during his career and he was never the subject of an investigation. Assistant District Attorney Mitch Poe of Tarrant County, who prosecuted





https://www.muckrock.com/foi/los-angeles-91/denial-of-cve-grant-76484/

Subject: California Public Records Act Request: Denial of CVE Grant
Email

To Whom It May Concern:
Pursuant to the California Public Records Act, I hereby request the following records:
All documents, communications, reports, briefs, memorandums pertaining to Los Angeles Mayor Eric Garcetti’s decision to turn down federal funds for countering violent extremism, chronicled in the below article:
https://www.dailynews.com/2018/08/16/la-mayor-turns-down-425k-in-federal-funding-to-counter-violent-extremism-after-opposition-from-civil-rights-groups-stalls-process/
This includes all written communication, email and otherwise, between Mayor Garcetti’s Office and the Department of Homeland Security which discuss these “countering violent extremism” grant proposals.
The requested documents will be made available to the general public, and this request is not being made for commercial purposes.
In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 calendar days, as the statute requires.
Sincerely,
Ava Sasani



https://www.muckrock.com/news/archives/2019/aug/09/foia-roundup-89/

August 9, 2019
This week’s FOIA round-up: Interior was interested in FBI’s “gold standard” FOIA policy, AP collects data on medical marijuana cards, and an Arkansas judge rules clerk broke public records law
Plus, see the results of the Oregon Public Records Advisory Council survey
Written by Shafaq Patel (@shafaqpatel)
Edited by JPat Brown
In this week’s FOIA round-up, the Department of the Interior staff emails show employees were interested in the Federal Bureau of Investigation’s “500-page per month” policy, the Associated Press created a new dataset by collecting information from each state to see why people wanted a medical marijuana card, and an Arkansas judge rules that a clerk broke state public-records laws, but cites as extenuating circumstances the clerk was acting on advice that they had received from state judicial authorities.
See a great use of public records we missed? Send over your favorite FOIA stories via email, on Twitter, or on Facebook, and maybe we will include them in the next roundup. And if you’d like even more inspiration, read past roundups.
Department of the Interior staff emails show employees were interested in FBI’s “gold standard” policy
Internal emails show that Department of the Interior employees looked to the FBI’s FOIA policies as a potential solution to the increase in number of requests. Rachel Spector, an official with Interior’s Office of the Solicitor, wrote to an FBI official seeking information on their procedures in an email stating, “Sorry to be so persistent, but we are scrambling to get our arms around a significant surge in FOIA requests.” Spector also referred to the Bureau’s FOIA program as “the gold standard.”




https://www.nydailynews.com/new-york/ny-saipov-wiretaps-20190812-7enst4qqofasxh7qbc53h5d4ya-story.html

Attorneys for alleged terrorist Sayfullo Saipov demand feds reveal wiretaps with ISIS supporters or drop death penalty for Hudson River bike path attack

By STEPHEN REX BROWN

NEW YORK DAILY NEWS |
AUG 12, 2019 | 2:03 PM




https://www.latimes.com/california/story/2019-08-12/facial-recognition-software-mistook-1-in-5-california-lawmakers-for-criminals-says-aclu

Facial recognition software mistook 1 in 5 California lawmakers for criminals, says ACLU




http://ticklethewire.com/2019/08/13/border-patrol-agent-admits-he-intentionally-struck-migrant-with-truck/

Border Patrol Agent Admits He ‘Intentionally Struck’ Migrant with Truck






https://www.muckrock.com/foi/united-states-of-america-10/jeffrey-epstein-files-federal-bureau-of-investigation-78805/


Subject: Freedom of Information Act Request: Jeffrey Epstein files (Federal Bureau of Investigation)
Portal
Dear Federal Bureau of Investigation:
This letter is a formal Freedom of Information Act request for the following records.
This request concerns records related to Jeffery E. Epstein, who died recently while in Federal custody.
As proof of death, and subject identification, please see:
https://www.justice.gov/opa/pr/statement-attorney-general-william-p-barr-death-jeffrey-epstein
https://www.google.com/search?q=Jeffrey+Epstein+death&prmd=niv&source=lnms&tbm=nws
This request includes both state and Federal records, including any such records that may be in each others' possession.
# Expedited processing
I request that part A of this request receive maximally expedited processing, as it concerns journalistic interest in multiple breaking news stories of international significance. For the same reason, I note that the journalistic waiver request below is particularly strong.
Please pay particular attention to the request below for rolling updates. Please prioritize your response in the order of records that can be produced the most quickly (including consideration of e.g. time to review), and keep me appraised of progress, ETAs, and records in pipeline (e.g. pending search or processing).
For the purposes of expedited interim rolling updates only, please ignore the format provisions of this request if (and only if) providing the records in another format would be faster, and only to that extent, i.e. provide the records in the fastest possible manner (and otherwise as requested). If you use this clause, then please say so clearly, and provide such records in the proper requested format pursuant to non-expedited processing.
# Exemptions moot due to death
Because dead people have no Privacy Act rights, this FOIA request includes all records that would otherwise be covered by the Privacy Act. No PA or similar waiver will be provided on anyone's behalf.
Please note that all criminal investigations into or prosecutions of Jeffrey Epstein have automatically terminated by his death, and therefore you may not invoke 5 USC 552(b)(7)(A, B, C, or F), or (c)(1), as to Epstein. See e.g. Davis v. DOJ, 460 F.3d 92, 97-98 (D.C. Cir. 2007); Schrecker v. DOJ, 349 F.3d 657, 661 (D.C. Cir. 2003); and Vest v. Dep't of the Air Force, 793 F. Supp. 2d 103, 122 (D.D.C. 2011) (re (b)(7) of dead people).
You may not claim 552(b)(5) as to records more than 25 years old. Please note that some of the cases listed below predate that cut-off.
Furthermore, if you wish to claim 552(b)(6) exemption as to Epstein's personal privacy, you would need to surmount a very high burden of proof, especially given that what has already been disclosed about Epstein has made it nearly impossible for him to be defamed. Defamation requires that the new information harm his reputation. As a dead serial child sex abuser, he has no reputation left to be harmed. See e.g. Grandison v. DOJ, 600 F. Supp. 2d 103, 114 (D.D.C. 2009); Schoenman v. FBI, 763 F. Supp. 2d 173, 176 (D.D.C. 2011); and Summers v. DOJ, 517 F. Supp. 2d 231, 241 (D.D.C. 2007) (re (b)(6) of dead people). See also Rosenfeld v. DOJ, No. 07-3240, 2012 WL 710186, at *4 (N.D. Cal. Mar. 5, 2012) and Citizens for Responsibility & Ethics in Wash. v. DOJ, 846 F. Supp. 2d 63, 71 (D.D.C. 2012) (re public figure).
However, I do not facially challenge the ability to invoke:
* (b)(7)(D) (confidential sources)
* (b)(7)(E) (methods)
* (b)(7)(A) (as to enforcement proceedings against someone other than Epstein)
* (b)(7)(B) (as to a reasonably expected prosecution of someone other than Epstein)
* (b)(7)(C) (as to the personal privacy of someone other than Epstein)
* (b)(7)(F) (as to the safety of someone other than Epstein)
(and equivalent state law).
# Exemptions related to any judicial seal
I understand that several responsive records may currently be under seal in one or more courts.
For such records, I stipulate that you may invoke 552(b)(3) (or state law equivalents), and will not contest (b)(3) exemption claims while the seal is in place, provided that you furnish, for each such record:
a) a complete citation to both the sealed record (case name, case number, court, filing date, ECF #) and all order(s) sealing the record (same)
b) a statement detailing any exemptions you claim on that record, other than the mere fact of the order of seal
c) a statement of whether you would object to a press-intervenor motion to unseal the record, given Epstein's death
# Other Jeffrey Epsteins
Please exclude records relating to persons named Jeffrey Epstein who are not the one identified above (i.e. the billionaire repeat sex offender).
I have already made efforts to exclude, e.g. in the case listing below:
Jeffrey M. Epstein
Jeffrey A. Epstein
Jeffrey Epstein, a lawyer in federal practice
If any cases identified in fact are about a different Epstein, please say so, and exclude those records.
# Component delegation
This request covers every Federal Bureau of Investigation component, including component agencies, departments, offices, OIGs, etc. See "# Forwarding; multi-agency / multi-component records" below.
Please note that this request imposes an affirmative obligation to take immediate steps to preserve responsive records against spoliation, including both any automated or routine record deletion and any act by an employee to delete such records.
This is an explicit evidence preservation demand, and the documents sought relate to ongoing and/or currently contemplated litigation.
At your discretion, you may either apply only a single tracking number for the whole request tree (acting for all subcomponents), or each subcomponents may apply its own tracking numbers.
In either case, you are expected to strictly comply with 5 USC 552(a)(6) and (a)(7), and analogous state law.
In particular, you are expected to provide notice (by email) of all referrals made, and any other tracking numbers of which you are aware.
# Primary request
A. Jeffrey Epstein's file(s)
0. Omnibus covering request and specific pointers
For all portions of this request, you are requested to use the following as search terms and locations to search.
As an omnibus covering request, please provide all records about Jeffrey E. Epstein that are in the possession of; or held, maintained, or created by; each of the following:
a) Agencies, offices, & locations
* Federal
i) Federal Bureau of Investigation (FBI)
ii) FBI Field Office - Miami (FBI Miami)
iii) FBI Field Office - New York (FBI NY)
iv) FBI Headquarters (FBI HQ)
v) Department of Justice (DOJ)
vi) DOJ Office of Professional Responsibility (OPR)
vii) U.S. Attorney's Office (USAO) for the Southern District of New York (SDNY)
viii) USAO for the Southern District of Florida (SDFL)
ix) USAO for the District of New Jersey (DNJ)
x) USAO for the Middle District of Florida (MDFL)
xi) Federal Bureau of Prisons (BOP)
* New York
xii) New York Office of the Governor (NY Gov)
xiii) New York Office of the Attorney General (NY AG)
xiv) Metropolitan Correctional Center, New York (MCC)
xv) NY City (NYC) Police Department (NYPD)
xvi) NY State Police (NYSP)
xvii) NYC Dep't of Correction (DOC) (NYC DOC)
xviii) NY Department of Corrections and Community Supervision (NY DOC)
* Florida
xix) Florida Office of the Governor (FL Gov)
xx) Florida Office of the Attorney General (FL AG)
xxi) Florida Department of Law Enforcement (FDLE)
xxii) Florida State Attorney's (FLSA) Office for the 15th Judicial Circuit (15th Cir.)
xxiii) Palm Beach County police / Palm Beach Sheriff's Office (PBSO)
xxiv) Town of Palm Beach Police Department (PBPD)
b) People
i) U.S. Attorney (USA) Geoffrey Berman
ii) USA R. Alexander Acosta
iii) USA Wifredo A. Ferrer
iv) Assistant USA (AUSA) A. Marie Villafaña
v) AUSA Dexter A. Lee
vi) AUSA Eduard I. Sanchez
vii) AUSA Andrew Laurie
viii) AUSA Bruce Reinhart
ix) FBI Special Agent (S/A) Timothy R. Slater
x) FBI S/A Nesbitt E. Kuyrkendall
xi) Florida Governor Ron DeSantis
xii) FLSA Barry Krischer
xiii) PBSO Sheriff Ric Bradshaw
xiv) PBSO Colonel Michael Gauger
xv) PBSO Captain David Sleeth
xvi) Chief Karen Atkinson (N. Div. 1)
c) Cases
Feinberg, et al v. Gonsalves, et al, No. 1:86-cv-749 (D.D.C.)
Stroll v. Epstein, No. 1:92-cv-1021, 818 F.Supp. 640 (S.D.N.Y. 1993)
USA v. Epstein, et al, No. 1:92-mj-2283 (S.D.N.Y.)
USA v. Epstein, et al, No. 1:93-cr-193 (E.D.N.Y.)
USA v. Epstein, No. 1:93-mj-73 (E.D.N.Y.)
Pierce Segerberg PC, et al v. Epstein, No. 1:95-cv-1109 (D. Colo.)
USA v. Epstein, et al, No. 1:96-cv-8307, 27 F.Supp.2d 404 (S.D.N.Y. 1998)
Mamberg f/k/a Epstein v. Epstein, 272 AD 2d 200, 707 N.Y.S.2d 439 (N.Y. App. Div., 1st Dept. 2000)
Epstein v. Epstein, 289 AD 2d 78, 734 N.Y.S.2d 144 (N.Y. App. Div., 1st Dept. 2001)
Financial Trust Company & Epstein v Citibank, No. 02-cv-108, (D.V.I.), 268 F.Supp.2d 561 (2003); 351 F.Supp.2d 329 (2004)
Citibank, N.A. v. Epstein, et al, No. 1:02-cv-5332 (S.D.N.Y.)
Shanks v. Wexner et al, No. 2:02-cv-7671 (E.D. Pa.)
Securities and Exchange Commission v. Glick et al, No. 1:04-cv-10801 (D. Mass.)
Coronel v. ADVO, Inc et al, No. 3:06-cv-1457 (D. Conn.)
Golden v. Harding et al, No. 3:06-cv-1470 (D. Conn.)
Kelleher v. ADVO, Inc et al, No. 3:06-cv-1422 (D. Conn.)
Field v. ADVO, Inc et al, No. 3:06-cv-1481 (D. Conn.)
In re Investigation of Jeffrey Epstein, No. 06-cf-945AXXXMB (Fla. 15th J. Cir.)
Williamson v. Culbro Corp. Pension Fund & Epstein, 41 A.D.3d 229, 838 N.Y.S.2d 524 (N.Y. App. Div., 1st Dept. 2007)
Highland Crusader Offshore Partners v. Terrestar Corp., No. 600320/08, 2008 NY Slip Op 32843 (N.Y. Cty. Oct. 14, 2008)
Cordero v. Epstein, 22 Misc. 3d 161, 869 N.Y.S.2d 725 (N.Y. Cty. 2008)
Ava a/k/a Cordero v. New York Post, No. 115597/07, 2008 NY Slip Op 51281 (N.Y. Cty. June 24, 2008)
Ava a/k/a Cordero v. New York Post, 64 A.D.3d 407, 885 N.Y.S.2d 247m 2009 NY Slip Op 5611 (N.Y. App. Div., 1st Dept. 2009)
Doe et al v. Epstein, No. 9:08-cv-80069 (S.D. Fla.)
Doe v. Epstein, No. 9:08-cv-80119 (S.D. Fla.)
Doe v. Epstein, No. 9:08-cv-80232 (S.D. Fla. Feb. 12, 2009)
Doe v. Epstein, No. 9:08-cv-80380 (S.D. Fla.)
Doe v. Epstein, No. 9:08-cv-80381, 611 F.Supp.2d 1339 (S.D. Fla. 2009)
Doe v. Epstein et al, No. 9:09-cv-80469 (S.D. Fla.)
Doe v. Epstein, No. 9:09-cv-80591 (S.D. Fla.)
Doe v. Epstein, No. 9:09-cv-80656 (S.D. Fla.)
Does v. USA, No. 08-cv-80736 (S.D. Fla.); 817 F.Supp.2d 1337 (2011); 950 F.Supp.2d 1262 (2013); 2015 WL 11254692 (Apr. 7, 2015); _ (July 6, 2015); 359 F.Supp.3d 1201 (2019)
* Non-prosecution agreement from In re Epstein filed at ECF No. 361-62, Feb. 10, 2016
* Appeals: Nos. 13-12923-C, 13-12926-C, 13-12928-C, & 19-10036-H (11th Cir.)
Doe v. Epstein, No. 9:09-cv-80802 (S.D. Fla. Nov. 18, 2009)
Doe v. Epstein et al, No. 9:08-cv-80804 (S.D. Fla. Oct. 3, 2008)
C.M.A. v. Epstein et al, No. 9:08-cv-80811 (S.D. Fla.)
Doe v. Epstein, No. 9:08-cv-80893 (S.D. Fla.)
Doe v. Epstein, No. 9:08-cv-80993 (S.D. Fla.)
Doe v. Epstein, No. 9:08-cv-80994 (S.D. Fla. Feb. 12, 2009)
Epstein v. State, No. 4D09-2554, 16 So. 3d 315 (Fla. D. App., 4th Dist. 2009)
Palm Beach Marine Construction, Inc. v. Epstein, No. 9:09-cv-80175 (S.D. Fla.)
L.M. v. Espstein, No. 9:09-cv-81092 (S.D. Fla.)
Molyneux et al v. Epstein, No. 3:10-cv-34 (D.V.I.)
Orseck v. Epstein, No. 1:10-cv-21586 (S.D. Fla.)
Doe v. Epstein, No. 9:10-cv-80309 (S.D. Fla.)
C.L. v. Epstein, No. 9:10-cv-80447 (S.D. Fla.)
J. v. Epstein et al, No. 9:10-cv-81107 (S.D. Fla.)
J. v. Epstein et al, No. 9:10-cv-81108 (S.D. Fla.)
J. v. Epstein et al, No. 9:10-cv-81109 (S.D. Fla.)
J. v. Epstein et al, No. 9:10-cv-81110 (S.D. Fla.)
J. v. Epstein et al, No. 9:10-cv-81111 (S.D. Fla.)
People v. Epstein, Indict. No. 30129/2010 (N.Y. Sup. Ct. 2010)
In re Edwards, No. 112345/10, 2011 NY Slip Op 31081 (N.Y. Cty. April 12, 2011)
People v. Epstein, No. 6081, 89 A.D. 3d 570, 933 N.Y.S.2d 239 (N.Y. App. Div., 1st Dept. 2011)
Irving H. Picard v. Kahn et al, No. 1:12-cv-2620 (S.D.N.Y.)
Edwards v. Epstein, No. 4D14-2282, 178 So. 3d 942 (Fla. D. App., 4th Dist. 2014)
Giuffre v. Edwards, No. 4D16-1847, 226 So. 3d 1034 (Fla. D. App., 4th Dist. 2017)
Doe v. Black, No. 13-usc-12923, 749 F.3d 999 (11th Cir. 2014)
Doe v. Epstein, No. 13-usc-12926 (11th Cir.)
Lederer v. N.Y. Daily News, No. 650400/15, 2016 NY Slip Op 31394 (N.Y. Cty. July 8, 2016)
Ransome v. Epstein and Maxwell, No. 15-cv-7433 (S.D.N.Y.), ECF No. 496 (Nov. 2, 2016); 221 F.Supp.3d 472 (Nov. 21, 2016); _ (April 27, 2017); ECF No. 892 (May 3, 2017); 325 F.Supp.3d 428 (2018); _ (Feb. 25, 2019)
Johnson v. Trump et al, No. 5:16-cv-797 (C.D. Cal.)
Hoffenberg v. Epstein et al, No. 1:16-cv-3989 (S.D.N.Y.)
Doe v. Trump et al, No. 1:16-cv-4642 (S.D.N.Y.)
Doe v. Trump et al, No. 1:16-cv-7673 (S.D.N.Y.)
Giuffre v. Epstein, No. 9:16-mc-81608 (S.D. Fla.)
Giuffre v. Maxwell, No. 16-cv-3945 (2d Cir.)
Doe (Ransome) v. Epstein et al, No. 1:17-cv-616 (S.D.N.Y.)
Brown v. Maxwell, Nos. 18-2868-cv, 16-3945-cv(L), 17-1625 (CON), 17-1722(CON) (2d Cir. July 3, 2019)
Giuffre v. Maxwell, No. 17-cv-1625 (2d Cir.)
Giuffre v. Maxwell, No. 17-cv-1722 (2d Cir.)
Giuffre v. Maxwell, No. 18-cv-2868 (2d Cir.)
Gerber et al v. The Financial Trust Company et al, No. 1:18-cv-7580 (S.D.N.Y.)
Epstein v. Brunel, No. 3D18-1997 (Fla. D. App., 3d Dist. April 24, 2019)
Edwards v. Epstein (Fla. Palm Beach County Court, 2018)
USA v. Epstein, No. 1:19-cr-490 (S.D.N.Y. July 18, 2019)
USA v. Epstein, No. 19-cr-2221 (2d Cir.)
Also:
Unknown sealed grand jury proceedings, indictments, or other criminal cases against Epstein, likely in SDNY, SDFL, MDFL, DNJ, and/or Fla. 15th Cir., or equivalent state jurisdictions
d) Press coverage & witness references
See e.g:
https://www.justice.gov/opa/pr/statement-attorney-general-william-p-barr-death-jeffrey-epstein
https://edition-m.cnn.com/2019/08/06/us/epstein-florida-criminal-investigation/index.html
https://www.miamiherald.com/news/state/florida/article233668342.html
https://edition-m.cnn.com/2019/07/25/us/jeffrey-epstein-injured-jail-cell/index.html
https://www.courthousenews.com/wp-content/uploads/2019/07/Epstein-bail.pdf
https://www.politico.com/f/?id=00000169-11f3-d0be-adfb-75fff4490000
https://www.scribd.com/document/421242877/Federal-prosecutor-Marie-Villafana-s-letter-to-the-sheriff-s-office
https://www.courtlistener.com/recap/gov.uscourts.flsd.317867/gov.uscourts.flsd.317867.304.1.pdf
https://www.courtlistener.com/recap/gov.uscourts.flsd.317867.291.0.pdf
# Specific records by respondent / originating agency
The following sub-parts give more specific directions by respondent / originating agency.
1. FBI, NYPD, NYSP, PBSO, PBPD, DOJ, USAO SDFL/MDFL/DNJ/SDNY, & FLSA 15th Cir.
Please provide all records you have about Epstein. These records are expected to be primarily related to surveillance, investigation, prosecution, transportation, incarceration, or carceral medical treatment of Epstein; any general dossier(s) about Epstein; and any of the cases listed above.
a) Please search
i) your automated indices
ii) the older general (manual) indices.
iii) the ELSUR electronic surveillance indices.
iv) all Field Offices, in particular those assigned to or located in MDFL, SDFL, SDNY, DNJ, & 15th Cir.
b) Please include any records related to Epstein's death, and his earlier injury, including photographs, medical records, autopsy, etc.
2. DOJ, NY AG, FL AG, NY Gov, FL Gov, DOJ OPR, & FDLE
Please provide all records you have about Epstein. These records are expected to be primarily related to determinations about pursuing criminal charges against Epstein, review of prosecutorial decisions; ethics / professional responsibility / etc investigations into prosecutors assigned to Epstein; and any of the cases listed above.
a) Please note that this explicitly includes both the recent prosecution of Epstein, and the earlier state prosecutions & investigations which were Federally paralleled by investigation, consideration, and negotiations (though not resulting in a separate Federal indictment).
b) This includes related OPR & FDLE investigations, such as those into Acosta and Kirscher.
3. BOP, NY DOC, NYC DOC, FL DOC, & MCC
Please provide all records you have about Epstein. These records are expected to be primarily related to transportation, incarceration, or carceral medical treatment of Epstein, and any general dossier about Epstein.
a) Please include both HQ / non-local records, and those local to every facility or office in which Epstein was held or transported (however briefly).
b) Please include any records related to Epstein's death, and his earlier injury, including photographs, medical records, autopsy, etc.
# General
For all of the above, you may exclude any records that are part of the public (unsealed) record in any of the cases listed above, and are requested to do so if it would limit (rather than expand) any burdens related to search or production of records.
For all of the above, please first apply and act on a reasonable interpretation of the most likely sources of non-public records of possible public interest, so as to expedite at least partial release of responsive records.
Then, please contact me (at the email below) with an explanation of what records you are likely to have, how difficult they might be to find or produce (e.g. where they might be located, what parts would be more burdensome than others and why, etc), and I will work with you to narrow the request to suit your record storage practices, exclude records that are of no public interest, and limit the burdens of search or production.
Please note that in order to effectively negotiate a narrowing, I would need you to first provide me with such details. I do not know your storage practices and cannot divine where you may or may not have relevant records, nor can I name a specific record without knowing what the options are. I will be most able to narrow the request if provided with options for what to potentially include or exclude.
###
Fiat Fiendum FOIA template
Version 5.0
###
# FOIA template structure
All content after the version number line above, except for the contact details at the very end, is part of my standard FOIA request template and identical between all of my FOIA requests. The provisions below are generally applicable to all FOIA / Privacy Act requests that I make.
There is one exception: the contact details below my signature at the very bottom (provided by MuckRock) are different for each request. Please use the distinct contact details matching each request, to ensure that your responses are correctly tracked.
The template provisions specify e.g. additional requests relating to my FOIA/PA requests themselves, form and format, timing, redaction & review, rolling updates, § 508 compliance, identity, fee waiver, my identity, and the like. They apply to this request, but are not specific to it.
If anything in the request-specific section above explicitly overrides anything in this template section, the request-specific section controls. If there is any ambiguity about such an override, please ask me for clarification.
The version number above is provided to make it easier for you to process my requests. Since all content (except contact info) below identical version number lines is identical between my requests, you need track only the request-specific portions (at the top) and the latest version of my general provisions.
Please read each new version carefully, as updates generally contain substantive changes.
## Template version updates
If you receive any FOIA request from me with a newer template version number than any pending prior FOIA requests from me, please replace the template portion of all prior requests with the updated version, treat the update as a clarification of and/or extension to the prior request, and process each updated request accordingly. Do not close the original request or change its request date. If you are permitted by law to refuse to honor such an update, and you choose to exercise that refusal, please process any differences between the new version and the prior version as a new FOIA request in its own right.
# Additional FOIA requests
In addition to the records specified in the request-specific section above, I also request:
B. all records relating to the fulfillment of this request, such as FOIA logs, documentation of searches, referral emails, etc.
This part of the request is to be processed only after you have completed processing all of the above parts. This part does not request that you create any new record; rather, it requests the records that you will have created in processing the above parts, and will therefore exist before you conduct the search for this part. See McGehee v. CIA, 697 F. 2d 1095, 1100-05 (D.C. Cir. 1983) (agency must use time-of-search cut-off date, not time-of-request).
C. all records relating to any complaint(s), FOIA request(s)/appeal(s), and/or Privacy Act request(s)/appeal(s) made by me. This includes, but is not limited to:
1. all records relating to the processing my previous requests, complaints, etc;
2. all records containing the terms my name, email address(es), and other contact or identifying information, listed below my signature; and
3. all records containing any of my complaint, request or appeal identifiers.
Parts (B) and (C) must be processed only after you have processed the items above that line, i.e. such that at the time of the search, the records described will have already been created at the time you conduct the search. Part (C) must be processed after part (B) is completed.
Parts (B) and (C) may overlap with similar prior requests. However, the cut-off date is, at earliest, the date that you complete search on all of the above items. If you wish to administratively merge this request with a prior similar request, I consent on condition that you extend the cut-off date for the prior request, and provide rolling updates. Otherwise, you must treat this as a new request.
For all responsive records, I also request:
D.
1. all parts of the record (i.e. no portion of a record with some responsive portion may be considered "non-responsive");
2. all versions of the record, whether or not currently in use;
3. all record metadata, such as dates on which they were drafted, passed, went into effect, withdrawn, or similar events; person(s) / office(s) responsible; authors; IDs; revision numbers; etc.;
4. a detailed index of all claims of exemption/privilege, regardless of whether the record is claimed to be exempt in whole or in part;
access to inspect the record directly, in its native electronic format; and
5. if any classification applies, mandatory declassification review (MDR) under E.O. 13526, and the result of the MDR, including any declassified records.
"All parts of the record" means that the "record" should be considered to be the most comprehensive record with any responsive portion. For instance:
a) if any portion of an email is responsive, the entire contents of all email thread(s) to which that email belongs is also responsive (including attachments);
b) if a record is part of a larger record, such as a responsive table that is in a chapter of a report, then the entire larger record (e.g. the full report) is responsive, together with any appendices, amendments, etc.;
c) if a record is part of a book, the entire book is responsive;
d) if a record is part of a database, all related database records are responsive;
etc.
"Related database records" has the technical meaning used in relational database management systems (such as SQL). It recursively includes all directly and indirectly related records (starting with all responsive records, include as responsive the full row of each, and recursively include as responsive all rows for which any responsive record has a foreign key or is referenced by a foreign key), together with the schema for all responsive records.
Items in part (D) should be prioritized at the same level as the record they apply to.
# Timing
For all requests above, the "cut-off date" is, at the earliest, the date that you conduct the search.
The priority order listed above is only for items that may take extra time to respond to, and must not be taken as blocking response to an otherwise lower priority item that could be released more quickly than a higher priority item that is pending time-intensive search or review.
# FOIA IA notice
Please note that this request is made after the enactment of Public Law No. 114-185, S. 337 (114th), the FOIA Improvement Act of 2016 (FOIA IA). The revised statute, as specified in the FOIA IA, applies to this request. FOIA IA § 6.
In particular, please note that:
1. you must provide electronic format documents, §§ 552(a)(2) (undesignated preceding text), 552(a)(2)(E) (undesignated following text), 552(a)(3)(B), and 552(a)(3)(C);
2. you may not specify an appeal duration less than 90 days, § 552(a)(6)(C)(A)(i)(III)(aa);
3. you may not withhold any record unless "the agency reasonably foresees that disclosure would harm an interest protected by an exemption described in subsection (b), or disclosure is prohibited by law", § 552(a)(8)(A)(i);
4. you must segregate and partially release records where possible, §§ 552(a)(8)(A)(ii) and 552(b) (undesignated matter following (b)(9)); and
5. you may not claim deliberative process exemption for records more than 25 years old, § 552(b)(5).
# "Record" defined
For the purposes of this request, except as otherwise specified, "record" means any agreement, appendix, application, assessment, attachment, checklist, circular, contract, correspondence (including but not limited to email), data management plan, documentation of search parameters, email, email attachment, form, guide, handbook, index of records, information consent agreement, information sharing agreement, instruction, interpretation, kit, management instruction, manual, memorandum, memorandum of understanding, notice, notification, opinion, order, plan, policy, policy statement, processing note, publication, recording, referral, report, request certification form, request detail report, response, rule, script, standard operating procedure, submission, talking point, training document, video, or related record described, regardless of publication status.
# Anti-duplication exclusion
This request specifically excludes providing me with new copies of any records which have been already provided to me or published online for free (e.g. on the agency's online "reading room"), in full or identically to the form that would be provided to me under this request (i.e. with exactly the same format, redactions, and claimed exemptions).
This is only an exclusion on providing records under this request that are identical to those already provided to me or available online, and only if I am or have already been provided a link to the online version (if "available online").
This exclusion is only intended to limit unnecessary duplication or provision, not to limit what records are responsive to this request, nor to permit failure to disclose the location of a responsive record available online. If this exclusion would in any way increase the cost or duration to respond to this request, it is to be ignored to the extent it does so.
This request is to be treated as separate from all others that I have filed.
# Forwarding; multi-agency / multi-component records
Please forward this request to the FOIA office of every agency component and subcomponent that may have responsive records for independent processing, with a copy to me.
This request includes any records held jointly by your agency in conjunction with any other agency and/or department, in interagency and/or interdepartmental systems of records, or by other agencies or third parties (including contractors) acting pursuant to any agreement with your agency.
# Minimal redaction
Please note that the FOIA requires you to service the maximum extent of my request that can be done via e.g. partial redaction of exempt material. If you believe some portions of a record to be exempt because it contains Sensitive Security Information (SSI, 49 CFR 15 & 1520) or classified information (18 USC 798), please provide a version of the record redacted to the minimum extent necessary to remove exempt information (e.g. per 49 CFR 1520.15), along with adequate information to describe the reason for each specific exemption.
## Redaction of repeatedly occurring content
When redacting any content that appears more than once in the full set of responsive records, please assign a replacement identifier for each, so that your redaction does not obfuscate the commonality.
For example, suppose that responsive records include the names Alice, Bob, Charlie, and Diego, and you determine that each of those names are redactable (e.g. under (b)(7)(C)). Rather than redacting each with only the text "(b)(7)(C)", replace each instance of "Alice" with "(b)(7)(C) - Person 1", each instance of "Bob" with "(b)(7)(C) - Person 2", etc. This e.g. withholds Alice's identity while not withholding the fact of commonality between occurrences.
Please use reasonably descriptive identifiers. For instance, if Elizabeth's name is not redacted but her personal cellphone number is, and that cellphone number appears e.g. both in her email signature and elsewhere by itself, it should in both cases be redacted with the same descriptive identifier, such as "[Alice's cell #]". For documents, this can be specified in the margins. If space or file format does not permit you to do so, then please use a short code (e.g. "[#52]", and provide a table matching codes to full identifiers in your response letter.
If you make any such redactions, please keep but do not provide a table matching codes/identifiers to the redacted content, for use in case your redaction is examined or overturned on appeal or in litigation.
This is a form and format request pertaining to your process of redaction. Because it only applies in situations when you have already exercised the voluntary decision to alter the records from the original form requested, you have necessarily waived any objection to this section "creating a new record", since your act of redaction itself already "makes a new record" in that limited sense. This is only about how you do a redaction you have already decided to make.
This provision limits the scope of your redaction to the minimum possible extent, so that even if you decide to withhold some particular piece of content, you do not also withhold the fact of its being the same as the same content appearing elsewhere. That fact is itself metadata that is explicitly requested as part of this request.
If you decide that the mere fact of two pieces of content being the same is itself withholdable, then please redact it using an identifier that encodes only the reason, and provide a table matching those reason-only identifiers to justifications in your response letter.
# Estimates and rolling updates
In order to help tailor my request, please provide an upfront estimate of the time and cost it will take to complete this request, broken down any significant factors that would affect cost to service, number of records in each category, and your estimate of how many records in the category are likely to be exempt.
Please provide me with incremental updates, with updated estimates for fulfillment of the remainder, rather than having the entirety of the request be blocked until fully completed.
# No new records; electronic & original format
This request does not ask you to create new records.
If you determine that a response would require creating a new record that you do not want to create, please first contact me by email with an explanation of what records you have that would most closely match the information requested and might be acceptable substitutes, so that we can reasonably tailor the request.
In particular, I specifically request that you do not create new documents in response to this request that are modifications of a digital record, such as page-view images, print views, scans, or the like. No such creation or substitution is authorized by FOIA or the Privacy Act.
However, if the same or similar records are held in both electronic and paper formats, this request includes both the paper and electronic versions. The paper version and the digital version are distinct records, and each may contain distinct information such as handwritten or other markings on the paper copy and embedded metadata in the electronic version.
I specifically request both the original, electronic format record, and (if it contains any additional markings) the paper record.
To the extent that the native electronic format is proprietary or otherwise not in format accessible by widely available, open source software, I also request
1. an export of the proprietary format into a standard, open format, as described below, and
2. all proprietary software necessary to use and understand the original, proprietary format records.
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