Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 1 of 11

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

BENJAMIN WITTES,
1775 Massachusetts Avenue NW
Washington, DC 20036, and
SCOTT R. ANDERSON,
1775 Massachusetts Avenue NW
Washington, DC 20036,
Plaintiffs,

Civil Action No. _________________

v.
U.S. FEDERAL BUREAU OF
INVESTIGATION
935 Pennsylvania Avenue, NW
Washington, D.C. 20535,
Defendant.

COMPLAINT
1.

Plaintiffs Benjamin Wittes and Scott R. Anderson bring this action against the

Federal Bureau of Investigations (“FBI”) to compel compliance with the Freedom of Information
Act (“FOIA”) by releasing records relating to allegations of inconsistent discipline of FBI
personnel in response to the personal expression of political views that are generating significant
public concern. See 5 U.S.C. § 552. Plaintiffs allege as follows:
2.

Throughout his more than two-decade career as an FBI agent, Peter Strzok was

involved in numerous high-profile and sensitive investigations, including the criminal
investigation into former Secretary Hillary Clinton’s use of a private email server and

1

 Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 2 of 11

investigations into Russian interference in the 2016 Presidential election. 1 On June 15, 2018, the
FBI proposed to fire Mr. Strzok from his position as an FBI agent in response to recently
discovered private communications between Mr. Strzok and an FBI attorney, Lisa Page, from
prior years that were critical of then-candidate, now President, Donald Trump. Despite a
negotiated agreement from the FBI’s Office of Professional Responsibility (“OPR”) on August
8, 2018 determining that Mr. Strzok should be demoted and receive a 60-day suspension, the FBI
abruptly fired Mr. Strzok the following day, August 9, 2018. 2
3.

On August 6, 2019, Mr. Strzok filed a lawsuit against DOJ, alleging that he was

subject to viewpoint discrimination by the FBI and was treated differently than others because
his communications were critical of President Trump. Mr. Strzok alleges that while he and
others who expressed negative views of President Trump have been subject to discipline, the FBI
has not taken any action against agents who have expressed negative views of Secretary Clinton,
specifically during the 2016 presidential campaign. 3
4.

It has been publicly reported that the FBI maintains an internal database that

tallies discipline of FBI personnel. In a May 2009 report entitled “Review of the Federal Bureau
of Investigation’s Disciplinary System,” the Justice Department’s Office of the Inspector General
described the FBI’s use of the Case Management System as follows: “The FBI implemented the
Case Management System to track allegations, investigations, adjudications, and appeals in a

Aruna Viswanatha, Former FBI Agent Sues Justice Department Over Firing, The Wall Street Journal (Aug. 6,
2019), https://www.wsj.com/articles/former-fbi-agent-sues-justice-department-over-firing11565116096?mod=searchresults&page=1&pos=4; Del Quentin Wilber, Inside the FBI Life of Peter Strzok and
Lisa Page, as Told in Their Text Messages, The Wall Street Journal (Feb. 2, 2018),
https://www.wsj.com/articles/inside-the-fbi-life-of-peter-strzok-and-lisa-page-as-told-in-their-text-messages1517589380; Alex Hosenball, Mike Levin, and Pierre Thomas, Special counsel Robert Mueller has assembled a
team of 16 seasoned prosecutors, ABC News (Sept. 29, 2017), https://abcnews.go.com/Politics/special-counselrobert-mueller-assembled-team-16-seasoned/story?id=50186443.
2
Complaint, Peter Strzok v. Attorney General William F. Barr, et. al., 1:19-CV-2367 (D.D.C. Aug. 6, 2019).
3
Id.
1

2

 Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 3 of 11

database in November 2004. One section of the Case Management System tracks precedent
decisions for each offense.” 4
5.

Federal regulations covering FBI personnel state that an FBI employee has the

right to “[e]xpress his or her opinion as an individual privately and publicly on political subjects
and candidates.” 5 C.F.R. § 734.402(a).
6.

Upon information and belief, the FBI has used Mr. Strzok’s case as a training

example. Upon information and belief, in or about August 2018, the FBI held an ethics training
for senior executives that incorporated Mr. Strzok’s communications that led to his firing. It is
unclear how the training program defined the rights employees have to privately express their
views on investigative subjects and when such views constitute fireable offenses.
7.

Accordingly, on August 14, 2019 and August 19, 2019, Plaintiffs submitted

seventeen FOIA requests for records from the Case Management System (“CMS”) that the FBI
uses to track misconduct cases against FBI employees. Eight of the requests seek records
concerning misconduct allegations against FBI employees for making inappropriate comments,
either positive or negative, about the four most recent presidential nominees: Donald Trump,
Barack Obama, Hillary Clinton, and Mitt Romney. An additional eight FOIA requests seek
records pertaining to any penalties related to such misconduct allegations. The seventeenth
request seeks records that the FBI may have concerning allegations and related penalties against
FBI personnel who may make inappropriate political comments, including statistics on the total
number of cases. Plaintiffs also submitted an eighteenth FOIA request, on August 14, 2019,
seeking a copy of the August 2018 ethics presentation to senior FBI executives, including any
materials related thereto.
U.S. Dep’t of Justice Office of the Inspector General Evaluation and Inspections Division, Review of the Federal
Bureau of Investigation’s Disciplinary System, at 28 (May 2009), https://oig.justice.gov/reports/FBI/e0902/final.pdf.

4

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 Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 4 of 11

JURISDICTION AND VENUE
8.

This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1331 and 5

U.S.C. § 552(a)(4)(B).
9.

Venue is proper pursuant to 5 U.S.C. § 552(a)(4)(B).
PARTIES

A. Plaintiffs
10.

Plaintiff Benjamin Wittes is the Editor-in-Chief of Lawfare, an online publication

published by The Lawfare Institute, a 501(c)(3) not-for-profit educational organization, and a
Senior Fellow in Governance Studies at the Brookings Institution. Lawfare is dedicated to
informing public understanding on the operations and activities of the federal government.
11.

Plaintiff Scott R. Anderson is a Senior Editor of Lawfare and Fellow in

Governance Studies at the Brookings Institution.
12.

Plaintiffs intend to make public records obtained through these FOIA requests and

provide information about and analysis of the records as appropriate on Lawfare’s website,
www.lawfareblog.com.
B. Defendant
13.

Defendant Federal Bureau of Investigation is an agency of the executive branch of

the federal government of the United States. Defendant is headquartered at 935 Pennsylvania
Ave. NW, Washington, DC 20535. Defendant has possession, custody, and control of the
records that Plaintiffs seek.
FACTUAL ALLEGATIONS
14.

On August 14, 2019, Plaintiffs sent a FOIA request (the “First Request”) to

Defendant using their online eFOIPA Request System, seeking the following records:

4

 Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 5 of 11

1.

Any records relating to any case in which an FBI employee
was accused of misconduct relating to any partisan or
political statements he or she may have made, including
positive or negative statements he or she may have made
about any candidates in elections or elected officials;

2.

Any records relating to any oral reprimand, letter of
censure, suspension, demotion, removal, or any other
adverse or non-adverse action that an FBI employee
received for alleged misconduct relating to any partisan or
political statements he or she may have made, including
positive or negative statements he or she may have made
about any candidates in elections or elected officials; and

3.

Any records indicating the actual or approximate number of
FBI employees who: (a) have been accused of misconduct
as described in paragraph 1 above; or (b) received any
adverse or non-adverse action for alleged misconduct as
described in paragraph 2 above in any given time period.

That same day, Plaintiffs received an email receipt confirming submission of this request. A true
and correct copy of the email confirmation for Plaintiffs’ First Request is attached as Exhibit A.
15.

On August 14, 2019, Plaintiffs sent an additional FOIA request (the “Second

Request”) to Defendant using their online eFOIPA Request System, seeking the following
records:
1.

A copy of all slides from any powerpoint presentation
given to members of the Senior Executive Service (“SES”)
in August 2018 that made specific reference to Peter Strzok
or Lisa Page, including but not limited to those entitled
“FBI Fundamentals: Doing the Right Thing the Right
Way,” or anything similar, and those presented by
personnel from the FBI’s Office of Professional
Responsibility (“OPR”) or Office of Integrity and
Compliance (“OIC”);

2.

Any audio or video recording of any presentations
identified in paragraph 1;

3.

Any handouts, readings, or other written materials
Disseminated electronically or in hard copy in association
with any presentations identified in paragraph 1; and

5

 Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 6 of 11

4.

Any e-mail communications discussing the development,
review, and clearance of any powerpoint presentations
identified in paragraph 1.

That same day, plaintiffs received an email receipt confirming submission of this request. A true
and correct copy of the email confirmation for Plaintiffs’ Second Request is attached as Exhibit
B.
16.

On August 19, 2019, Plaintiffs sent eight additional FOIA requests to Defendant

using their online eFOIPA Request System, requesting any records in the FBI’s Case
Management System for disciplinary measures, or any successor system, indicating that an FBI
employee was accused of misconduct relating to: (1) negative statements he or she made about
Barack H. Obama (the “Third Request”); (2) positive statements he or she made about Barack H.
Obama (the “Fourth Request”); (3) negative statements he or she made about Willard Mitt
Romney (the “Fifth Request”); (4) negative statements he or she made about Hillary R. Clinton
(the “Sixth Request”); (5) negative statements he or she made about Donald J. Trump (the
“Seventh Request”); (6) positive statements he or she made about Donald J. Trump (the “Eighth
Request”); (7) positive statements he or she made about Hillary R. Clinton (the “Ninth
Request”); and (8) positive statements he or she made about Willard Mitt Romney (the “Tenth
Request”). That same day, plaintiffs received email receipts confirming submission of these
requests. True and correct copies of the email confirmations for Plaintiffs’ Third through Tenth
Requests are attached as Exhibit C, Exhibit D, Exhibit E, Exhibit F, Exhibit G, Exhibit H,
Exhibit I, and Exhibit J.
17.

On August 19, 2019, Plaintiffs sent eight additional FOIA requests to Defendant

using their online eFOIPA Request System, requesting any records in the FBI’s Case
Management System for disciplinary measures, or any successor system, indicating that an FBI

6

 Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 7 of 11

employee was the subject of an oral reprimand, letter of censure, suspension, demotion, removal,
or any other adverse or non-adverse action for alleged misconduct relating to: (1) negative
statements he or she made about Barack H. Obama (the “Eleventh Request”); (2) positive
statements he or she made about Barack H. Obama (the “Twelfth Request”); (3) negative
statements he or she made about Willard Mitt Romney (the “Thirteenth Request”); (4) positive
statements he or she made about Willard Mitt Romney (the “Fourteenth Request”); (5) negative
statements he or she made about Hillary R. Clinton (the “Fifteenth Request”); (6) positive
statements he or she made about Hillary R. Clinton (the “Sixteenth Request”); (7) negative
statements he or she made about Donald J. Trump (the “Seventeenth Request”); and (8) positive
statements he or she made about Donald J. Trump (the “Eighteenth Request”). That same day,
plaintiffs received email receipts confirming submission of these requests. True and correct
copies of the email confirmations for Plaintiffs’ Eleventh through Eighteenth Requests are
attached as Exhibit K, Exhibit L, Exhibit M, Exhibit N, Exhibit O, Exhibit P, Exhibit Q, and
Exhibit R.
18.

Plaintiffs sought fee waivers pursuant to 5 U.S.C. § 552(a)(4)(A)(iii) and 28

C.F.R. § 16.10(k). See Exhibits A through R.
19.

Plaintiffs demonstrated that they satisfy the requirements for fee waivers based on

their status as representatives of the media and because disclosure of the information “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.” 5 U.S.C. § 552(a)(4)(A)(ii)-

7

 Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 8 of 11

(iii). Significant public concern exists regarding the FBI’s discipline of Mr. Strzok, and the
information sought via Plaintiffs’ FOIA requests is central to such concerns. 5
20.

Plaintiffs also requested expedited processing pursuant to 5 U.S.C. § 552(a)(6)(E)

and 28 C.F.R. § 16.5(e). Exhibits A through R. Plaintiffs’ requests were narrowly tailored to
make it easy for the FBI and DOJ to respond to them in an expedited fashion.
21.

Plaintiffs demonstrated that they satisfy the requirement for expedited processing

based on the “urgency to inform the public about an actual or alleged Federal Government
activity” and because the requests concern a “matter of widespread and exceptional media
interest in which there exist possible questions about the government’s integrity that affect public
confidence.” 28 C.F.R. § 16.5(e)(1)(ii), (iv). The matter at issue has generated substantial media
coverage and continues to call into question the integrity of the FBI’s investigations as well as its
discipline of Mr. Strzok and Lisa Page. 6 With the December 9, 2019 release of the Office of the
Inspector General’s report on the FBI’s investigation into Russian interference in the 2016
election, which noted that certain FBI agents involved in the investigation exchanged personal
communications that were favorable to President Trump, extensive headline news coverage on
this subject has persisted. 7

5
Patricia Ravalgi, Once-Heroic Agents Have Helped Trump’s Effort to Divide and Conquer the FBI, The Daily
Beast (Dec. 2, 2019), https://www.thedailybeast.com/under-trump-once-heroic-fbi-agents-have-helped-potusefforts-to-divide-and-conquer-the-bureau; Gerald F. Seib, American Institutions Become Collateral Damage Amid
Impeachment Fight, The Wall Street Journal, (Nov. 18, 2019), https://www.wsj.com/articles/collateral-damageamerican-institutions-hurt-amid-impeachment-fight-11574088848?mod=searchresults&page=1&pos=1; Courtney
Buble, Former FBI Agent Peter Strzok’s Lawsuit Highlights a Gray Area in the Hatch Act, Government Executive
(Aug. 9, 2019), https://www.govexec.com/workforce/2019/08/former-fbi-agent-peter-strzoks-lawsuit-highlightsgray-area-hatch-act/159075/.
6
Id.
7
U.S. Dep’t of Justice Office of the Inspector General, Review of Four FISA Applications and Other Aspects of the
FBI’s Crossfire Hurricane Investigation, at p. 339 FN 447 (Dec. 2019), https://www.justice.gov/storage/120919examination.pdf; see also Aaron Blake, 4 takeaways from the Horowitz report on the Russia investigation, The
Washington Post, (Dec. 9, 2019), https://www.washingtonpost.com/politics/2019/12/09/takeaways-horowitz-reportrussia-investigation/.

8

 Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 9 of 11

22.

On August 28, 2019, Defendant acknowledged receipt of Plaintiffs’ Third

Request and, in separate correspondence, denied expedited processing on the ground that
Plaintiffs “ha[d] not provided enough information concerning the statutory requirements for
expedition[.]” True and correct copies of these letters from the Defendant are attached as
Exhibits S and T. Both letters reference “FOIPA Request No. 1445323-000,” which is not
clearly associated with any of Plaintiffs’ requests. That said, the FBI’s online eFOIPA Request
System associates both letters with the Plaintiffs’ Third Request, which it identifies using the
internal reference number “07396d0.” A screenshot of the eFOIPA Request System showing the
two eFOIPA files in response to “Submission: 07396d0” is attached as Exhibit U.
23.

Pursuant to FOIA, “[e]ach agency, upon any request for records [under FOIA],

shall . . . determine within 20 days (excepting Saturdays, Sundays, and legal public holidays)
after the receipt of any such request whether to comply with such request and shall immediately
notify the person making such request . . . .” 5 U.S.C. § 552(a)(6)(A)(i). “Any person making a
request to any agency for records under [FOIA] shall be deemed to have exhausted his
administrative remedies with respect to such request if the agency fails to comply with the
applicable time limit provisions . . . .” 5 U.S.C. § 552(a)(6)(C)(i). Plaintiffs submitted two
FOIA requests on August 14, 2019 and the remaining sixteen FOIA requests on August 19,
2019, respectively. The 20-day deadline for the former requests thus expired on September 12,
2019, and for the latter requests on September 17, 2019.
24.

To date, Defendant has failed to make any of the determinations or notifications

required by 5 U.S.C. § 552(a)(6)(A)(i) in relation to any of Plaintiffs’ eighteen requests. Nor has
Defendant responded to any of the Plaintiffs’ requests for fee waivers or seventeen of the
Plaintiffs’ eighteen requests for expedited processing.

9

 Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 10 of 11

25.

Defendant has no lawful basis for failing to produce any responsive records

requested by Plaintiffs.
FIRST CLAIM FOR RELIEF
(Violation of FOIA, 5 U.S.C. § 552)
26.

Plaintiffs re-allege and incorporate by reference all other paragraphs.

27.

Defendant FBI is in violation of FOIA by failing to respond to Plaintiffs’ requests

within the statutorily prescribed time limit and by unlawfully withholding records responsive to
Plaintiffs’ requests.
28.

Accordingly, Plaintiffs are entitled to an order compelling the FBI to grant

Plaintiffs’ requests for records and to release, as soon as practicable, any responsive records.
REQUEST FOR RELIEF
WHEREFORE, Plaintiffs respectfully request that the Court:
a. Declare that Plaintiffs are entitled to fee waivers under 5 U.S.C. § 552(a)(4)(A)(iii)
and 28 C.F.R. § 16.10(k);
b. Declare that the records sought by Plaintiffs in their FOIA requests are public records
under 5 U.S.C. § 552(a)(2)(D), which should be disclosed pursuant to 5 U.S.C. §§
552(a)(6)(A) and 552(a)(3)(A) and Defendant’s corresponding regulations;
c. Order Defendant to grant Plaintiffs’ requests for fee waivers;
d. Order Defendant, by a date certain, to conduct an adequate search that is reasonably
likely to lead to the discovery of any and all records responsive to Plaintiffs’ requests;
e. Order Defendants, by a date certain, to produce to Plaintiffs any and all non-exempt
records or portions of records responsive to Plaintiffs’ request, as well as a Vaughn
index of any records or portions of records withheld due to a claim of exemption;
f. Award Plaintiffs attorneys’ fees and other reasonable costs incurred in this action, see
5 U.S.C. § 552(a)(4)(E);
g. Grant Plaintiffs such other relief as the Court deems appropriate.

10

 Case 1:19-cv-03773-ABJ Document 1 Filed 12/18/19 Page 11 of 11

Dated: December 18, 2019

Respectfully submitted,
By: /s/ Robert S. Litt
Robert S. Litt (DC Bar No. 312470)
MORRISON & FOERSTER LLP
2000 Pennsylvania Avenue, NW
Suite 6000
Washington, DC 20006
(202) 887-1588
rlitt@mofo.com
Counsel for Plaintiffs

11

 Case Document 1-1 Filed 12/18/19 Page 1 of 6

Exhibit A

Case 1:19-cv-03773-ABJ Document 1-1 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

1775 Massachusetts Ave., NW

Wed, Aug 14, 2019 at 5:09 PM

 Case 1:19-cv-03773-ABJ Document 1-1 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20036

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

500

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security. A former senior FBI official who was the subject of
disciplinary
action due to certain private communications recently accused
th FBI
d

 Case 1:19-cv-03773-ABJ Document 1-1 Filed 12/18/19 Page 4 of 6

the FBI and
Justice Department of “treat[ing] [him] more harshly than
they would have
treated similar communications because the content of [his]
communications
was critical of President Trump.†This request is intended
to help determine
whether this allegation is true and FBI personnel may be under
inappropriate
political pressures as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records relating to any case in which an FBI employee
was accused of
misconduct relating to any partisan or political statements he
or she may
have made, including positive or negative statements he or she
may have made
about any candidates in elections or elected officials;
2. Any records relating to any oral reprimand, letter of
censure,

 Case 1:19-cv-03773-ABJ
Document 1-1 Filed 12/18/19 Page 5 of 6
censure,
suspension, demotion, removal, or any other adverse or nonadverse action
that an FBI employee received for alleged misconduct relating
to any
partisan or political statements he or she may have made,
including positive
or negative statements he or she may have made about any
candidates in
elections or elected officials; and
3. Any records indicating the actual or approximate number of
FBI employees
who: (a) have been accused of misconduct as described in
paragraph 1 above;
or (b) received any adverse or non-adverse action for alleged
misconduct as
described in paragraph 2 above in any given time period.
This request is for documents held by, or accessible to, the
FBI’s Internal
Investigations Section (IIS) or Office of Professional
Responsibility (OPR)
dating from November 20, 2011, to the present. We are not
requesting the
names or any other personally identifiable information about
the subjects of
these notices and do not object if such information is
redacted. We do not
believe this request falls within the scope of any existing
FOIA exemptions.
See Department of the Air Force v. Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).

 Case 1:19-cv-03773-ABJ Document 1-1 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

[Quoted text hidden]

 Case Document 1-2 Filed 12/18/19 Page 1 of 7

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-2 Filed 12/18/19 Page 2 of 7
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

202-797-2480

Location

United States

Domestic Address
Address Line 1

Address Line 2

1775 Massachusetts Ave., NW

Wed, Aug 14, 2019 at 4:45 PM

 Case 1:19-cv-03773-ABJ Document 1-2 Filed 12/18/19 Page 3 of 7
City

State

Postal

Washington

District of Columbia

20036

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

500

Proof Of Affiliation for Fee Waiver

 Case 1:19-cv-03773-ABJ Document 1-2 Filed 12/18/19 Page 4 of 7
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security. Current and former FBI employees have indicated that
a
presentation made to members of the FBI’s SES in August 2018
misrepresented
relevant facts relating to Strzok and Page, as well as legal
and policy
limitations on the political activities of FBI personnel. This
request is
intended to determine whether these allegations are true.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

 Case 1:19-cv-03773-ABJ Document 1-2 Filed 12/18/19 Page 5 of 7
Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. A copy of all slides from any powerpoint presentation given
to members of
the Senior Executive Service (“SES†) in August 2018 that
made specific
reference to Peter Strzok or Lisa Page, including but not
limited to those
entitled “FBI Fundamentals: Doing the Right Thing the Right
Way†or anything
similar, and those presented by personnel from the FBI’s
Office of
Professional Responsibility (“OPR†) or Office of Integrity
and Compliance
(“OIC†);
2. Any audio or video recording of any presentations
identified in paragraph
1;
3. Any handouts, readings, or other written materials
disseminated
electronically or in hard copy in association with any
presentations
identified in paragraph 1; and
4. Any e-mail communications discussing the development,
review, and
clearance of any powerpoint presentations identified in
paragraph 1.
We do not believe this request falls within the scope of any
existing FOIA
exemptions. See Department of the Air Force v. Rose, 425 U.S.
352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of

 Case 1:19-cv-03773-ABJ Document 1-2 Filed 12/18/19 Page 6 of 7
processing of
this request.

If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. FBI personnel who have been misinformed regarding
relevant
legal and policy restrictions may be unnecessarily curtailing
their valid
and permissible political activities. Further, an effort to
misrepresent the
facts surrounding Strzok and Page may reflect a broader effort
to
misleadingly characterize that case. In either case, there
would be an
urgent need to publicly correct these misrepresentations and
to inform
members of the public of what has occurred so that they may
encourage their
political representatives to respond accordingly.

**

 Case 1:19-cv-03773-ABJ Document 1-2 Filed 12/18/19 Page 7 of 7
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-3 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-3 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 1:21 PM

 Case 1:19-cv-03773-ABJ Document 1-3 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-3 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was
accused of misconduct relating to negative statements he or
she had made
about Barack H. Obama.

 Case 1:19-cv-03773-ABJ
Document 1-3 Filed 12/18/19 Page 5 of 6
about Barack H. Obama.
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-3 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-4 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-4 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 1:24 PM

 Case 1:19-cv-03773-ABJ Document 1-4 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-4 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was
accused of misconduct relating to positive statements he or
she had made
about Barack H. Obama.
This request is for documents dating from November 20, 2011,

 Case 1:19-cv-03773-ABJ
Document
1-4dating
Filed from
12/18/19
Page
of 6
This request is for
documents
November
20,5 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-4 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-5 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-5 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 1:33 PM

 Case 1:19-cv-03773-ABJ Document 1-5 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-5 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was
accused of misconduct relating to negative statements he or
she had made
about Willard Mitt Romney.
This request is for documents dating from November 20, 2011,

 Case 1:19-cv-03773-ABJ
Document
1-5dating
Filed from
12/18/19
Page
of 6
This request is for
documents
November
20,5 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-5 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-6 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-6 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 1:39 PM

 Case 1:19-cv-03773-ABJ Document 1-6 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-6 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was
accused of misconduct relating to negative statements he or
she had made
about Hillary R. Clinton.
This request is for documents dating from November 20, 2011,

 Case 1:19-cv-03773-ABJ
Document
1-6dating
Filed from
12/18/19
Page
of 6
This request is for
documents
November
20,5 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-6 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-7 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-7 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 1:41 PM

 Case 1:19-cv-03773-ABJ Document 1-7 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-7 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was
accused of misconduct relating to negative statements he or
she had made
about Donald J. Trump.
This request is for documents dating from November 20, 2011,

 Case 1:19-cv-03773-ABJ
Document
1-7dating
Filed from
12/18/19
Page
of 6
This request is for
documents
November
20,5 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-7 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-8 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-8 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 1:43 PM

 Case 1:19-cv-03773-ABJ Document 1-8 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-8 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was
accused of misconduct relating to positive statements he or
she had made
about Donald J. Trump.

 Case 1:19-cv-03773-ABJ
Document 1-8 Filed 12/18/19 Page 5 of 6
about Donald J. Trump.
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-8 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-9 Filed 12/18/19 Page 1 of 6

Exhibit I

Case 1:19-cv-03773-ABJ Document 1-9 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 1:59 PM

 Case 1:19-cv-03773-ABJ Document 1-9 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-9 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was
accused of misconduct relating to positive statements he or
she had made
about Hillary R. Clinton.
This request is for documents dating from November 20, 2011,

 Case 1:19-cv-03773-ABJ
Document
1-9dating
Filed from
12/18/19
Page
of 6
This request is for
documents
November
20,5 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-9 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-10 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-10 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 2:02 PM

 Case 1:19-cv-03773-ABJ Document 1-10 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-10 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was
accused of misconduct relating to positive statements he or
she had made
about Willard Mitt Romney.

 Case 1:19-cv-03773-ABJ
Document
about Willard Mitt
Romney. 1-10 Filed 12/18/19 Page 5 of 6
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-10 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-11 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-11 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 12:16 PM

 Case 1:19-cv-03773-ABJ Document 1-11 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-11 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was the
subject of an oral reprimand, letter of censure, suspension,
demotion,
removal, or any other adverse or non-adverse action for

 Case 1:19-cv-03773-ABJ
1-11or Filed
12/18/19
Page
removal, or any Document
other adverse
non adverse
action
for5 of 6
alleged misconduct
relating to negative statements he or she had made about
Barack H. Obama.
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-11 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-12 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-12 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 12:19 PM

 Case 1:19-cv-03773-ABJ Document 1-12 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-12 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was the
subject of an oral reprimand, letter of censure, suspension,
demotion,
removal, or any other adverse or non-adverse action for

 Case 1:19-cv-03773-ABJ
1-12or Filed
12/18/19
Page
removal, or any Document
other adverse
non adverse
action
for5 of 6
alleged misconduct
relating to positive statements he or she had made about
Barack H. Obama.
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-12 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-13 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-13 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 12:21 PM

 Case 1:19-cv-03773-ABJ Document 1-13 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-13 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was the
subject of an oral reprimand, letter of censure, suspension,
demotion,
removal, or any other adverse or non-adverse action for

 Case 1:19-cv-03773-ABJ
1-13or Filed
12/18/19
Page
removal, or any Document
other adverse
non adverse
action
for5 of 6
alleged misconduct
relating to negative statements he or she had made about
Willard Mitt
Romney.
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-13 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-14 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-14 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 12:23 PM

 Case 1:19-cv-03773-ABJ Document 1-14 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-14 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was the
subject of an oral reprimand, letter of censure, suspension,
demotion,
removal, or any other adverse or non-adverse action for

 Case 1:19-cv-03773-ABJ
1-14or Filed
12/18/19
Page
removal, or any Document
other adverse
non adverse
action
for5 of 6
alleged misconduct
relating to positive statements he or she had made about
Willard Mitt
Romney.
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-14 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-15 Filed 12/18/19 Page 1 of 6

Exhibit 0

Case 1:19-cv-03773-ABJ Document 1-15 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 12:39 PM

 Case 1:19-cv-03773-ABJ Document 1-15 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-15 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was the
subject of an oral reprimand, letter of censure, suspension,
demotion,
removal, or any other adverse or non-adverse action for

 Case 1:19-cv-03773-ABJ
1-15or Filed
12/18/19
Page
removal, or any Document
other adverse
non adverse
action
for5 of 6
alleged misconduct
relating to negative statements he or she had made about
Hillary R. Clinton.
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-15 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-16 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-16 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 12:55 PM

 Case 1:19-cv-03773-ABJ Document 1-16 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-16 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was the
subject of an oral reprimand, letter of censure, suspension,
demotion,
removal, or any other adverse or non-adverse action for

 Case 1:19-cv-03773-ABJ
1-16or Filed
12/18/19
Page
removal, or any Document
other adverse
non adverse
action
for5 of 6
alleged misconduct
relating to positive statements he or she had made about
Hillary R. Clinton.
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-16 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-17 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-17 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 12:57 PM

 Case 1:19-cv-03773-ABJ Document 1-17 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-17 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was the
subject of an oral reprimand, letter of censure, suspension,
demotion,
removal, or any other adverse or non-adverse action for

 Case 1:19-cv-03773-ABJ
1-17or Filed
12/18/19
Page
removal, or any Document
other adverse
non adverse
action
for5 of 6
alleged misconduct
relating to negative statements he or she had made about
Donald J. Trump.
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-17 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-18 Filed 12/18/19 Page 1 of 6

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-18 Filed 12/18/19 Page 2 of 6
Scott Anderson <scott.anderson@lawfareblog.com>

eFOIA Request Received
efoia@subscriptions.fbi.gov <efoia@subscriptions.fbi.gov>
To: scott.anderson@lawfareblog.com

Organization Representative Information
Organization Name

Lawfare

Prefix

First Name

Scott

Middle Name

Last Name

Anderson

Suffix

Email

scott.anderson@lawfareblog.com

Phone

Location

United States

Domestic Address
Address Line 1

Address Line 2

P.O. Box 33226

Mon, Aug 19, 2019 at 1:07 PM

 Case 1:19-cv-03773-ABJ Document 1-18 Filed 12/18/19 Page 3 of 6
City

State

Postal

Washington

District of Columbia

20033

Agreement to Pay
How you will pay

Allow up to $

I am requesting a fee waiver for my request and have reviewed the FOIA reference
guide. If my fee waiver is denied, I am willing to pay additional fees and will enter
that maximum amount in the box below.

200

Proof Of Affiliation for Fee Waiver
Waiver Explanation

FOIA provides that any fees associated with a request are
waived 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.†5 U.S.C. § 552(a)(4)(A)(iii).
We are the editor-in-chief and senior editor for Lawfare, an
online
publication dedicated to informing public understanding on
operations and
activities of the government. Lawfare is published by The
Lawfare Institute,
a 501(c)(3) not-for-profit educational organization, and in
cooperation with
The Brookings Institution, a 501(c)(3) nonprofit public policy
organization.
This request is submitted in connection with Lawfare’s
mission to publish
information that is likely to contribute significantly to the
public
understanding of federal agency activities related to law and
national
security—specifically, the extent to which FBI personnel are
facing
inappropriate political pressures. A former senior FBI
ffi i l h
th

 Case 1:19-cv-03773-ABJ Document 1-18 Filed 12/18/19 Page 4 of 6

official who was the
subject of disciplinary action due to certain private
communications
recently accused the FBI and Justice Department of
“treat[ing] [him] more
harshly than they would have treated similar communications
because the
content of [his] communications was critical of President
Trump.†This
request is intended to help determine whether this allegation
is true and
FBI personnel may be under inappropriate political pressures
as a result.
In addition to satisfying the requirements for a waiver of
fees associated
with the search and processing of records, we are entitled to
a waiver of
all fees except “reasonable standard charges for document
duplication.†5
U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees
be limited to
document duplication costs for any requester that qualifies as
“a
representative of the news media.†Id. Lawfare is a “news
media
organization[]†that “gathers information of potential
interest to a segment
of the public, uses its editorial skills to turn the raw
materials into a
distinct work, and distributes that work to an audience.â€
Nat’l Sec. Archive
v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).
We intend to give
the public access to documents transmitted via FOIA on our
website,
https://www.lawfareblog.com, and to provide information about and
analysis
of those documents as appropriate.

Documentation Files

Non-Individual FOIA Request
Request Information

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. §
552, we hereby
request that your office produce the following records within
20 business
days:
1. Any records in the FBI’s “Case Management System†for
disciplinary
measures,* or any successor system, indicating that an FBI
employee was the
subject of an oral reprimand, letter of censure, suspension,
demotion,
removal, or any other adverse or non-adverse action for

 Case 1:19-cv-03773-ABJ
1-18or Filed
12/18/19
Page
removal, or any Document
other adverse
non adverse
action
for5 of 6
alleged misconduct
relating to positive statements he or she had made about
Donald J. Trump.
This request is for documents dating from November 20, 2011,
to the present.
We are not requesting the names or any other personally
identifiable
information about the subjects of these notices and do not
object if such
information is redacted. We do not believe this request falls
within the
scope of any existing FOIA exemptions. See Department of the
Air Force v.
Rose, 425 U.S. 352 (1976).
We also request any records describing the processing of this
request,
including records sufficient to identify search terms used and
locations and
custodians searched and any tracking sheets used to track the
processing of
this request. If your agency uses FOIA questionnaires or
certifications
completed by individual custodians or components to determine
whether they
possess responsive materials or to describe how they conducted
searches, we
also request any such records prepared in connection with the
processing of
this request.
If you make a determination that any responsive record, or any
segment
within a record is exempt from disclosure, we ask that you
provide an index
of those records at the time you transmit all other responsive
records. In
the index, please include a description of the record and the
reason for
exclusion with respect to each individual exempt record or
exempt portion of
a record, as provided by Vaughn v. Rosen, 484 F.2d 820 (D.C.
Cir. 1973),
cert. denied, 415 U.S. 977 (1974). When you deem a portion of
a record
exempt, we ask that the remainder of the record to be
provided, as required
by 5 U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).
* In a May 2009 report entitled “Review of the Federal
Bureau of
Investigation’s Disciplinary System†(available at
https://oig.justice.gov/reports/FBI/e0902/final.pdf), the Justice
Department’s Office of the Inspector General described the
FBI’s use of the
Case Management System as follows: “The FBI implemented the
Case Management
System to track allegations, investigations, adjudications,
and appeals in a
database in November 2004. One section of the Case Management
System tracks
precedent decisions for each offense.†(p. 28)

 Case 1:19-cv-03773-ABJ Document 1-18 Filed 12/18/19 Page 6 of 6

Expedite
Expedite Reason

FOIA provides for expedited processing where a requestor
“demonstrates a
compelling need.†5 U.S.C. § 552(a)(6)(E)(i). It defines
“compelling needâ€
to include situations where a “request [is] made by a person
primarily
engaged in disseminating information†and there exists an
“urgency to inform
the public concerning actual or alleged Federal Government
activity.†Id. §
552(a)(6)(E)(v).
Lawfare is an organization primarily engaged in the
dissemination of
information. If FBI personnel are being disproportionately
punished due to
their political opinions, then this risks compromising a range
of important
law enforcement and national security investigations. There is
an urgent
need to inform the public whether these allegations are
accurate so that
they may encourage their political leaders to correct this
behavior and
avoid further compromising any ongoing investigations.

**
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request
may be directed to foipaquestions@fbi.gov. If you have received a FOIPA request number, please include this in all
correspondence concerning your request. Please note eFOIPA requests are processed in the order that they are
received. If you have not received a FOIPA request number, your request is in the process of being opened at which time
it will be assigned a FOIPA request number and correspondence will be forthcoming.
**
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI’s electronic
FOIA Library (The Vault) on the FBI’s public website, http://vault.fbi.gov by clicking on the ‘Check Status of Your
FOI/PA Request tool’ link. Status updates are performed on a weekly basis. If you receive a comment that your
FOIPA request number was not located in the database, please check back at a later date.

 Case Document 1-19 Filed 12/18/19 Page 1 of 3

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-19 Filed 12/18/19 Page 2 of 3
U.S. Department of Justice

Federal Bureau of Investigation
Washington, D.C. 20535
August 28, 2019
MR. SCOTT ANDERSON
LAWFARE
POST OFFICE BOX 33226
WASHINGTON, DC 20033
FOIPA Request No.: 1445323-000
Subject: FBI Employees Reprimanded for
Negative/Positive Statements about Elected
Candidates
(November 20, 2011 – August 26, 2019)
Dear Mr. Anderson:
This acknowledges receipt of your Freedom of Information/Privacy Acts (FOIPA) request to the
FBI. Below you will find check boxes and informational paragraphs about your request, as well as specific
determinations required by these statutes. Please read each one carefully.
Your request has been received at FBI Headquarters for processing.
You submitted your request via the FBI’s eFOIPA system.
We have reviewed your request and determined it is consistent with the FBI
eFOIPA terms of service. Future correspondence about your FOIPA request will
be provided in an email link unless the record’s file type is not supported by the
eFOIPA system.
We have reviewed your request and determined it is not consistent with the FBI
eFOIPA terms of service. Future correspondence about your FOIPA request will
be sent through standard mail.
The subject of your request is currently being processed and documents will be released
to you upon completion.
Release of responsive records will be posted to the FBI’s electronic FOIA Library (The
Vault), http:/vault.fbi.gov, and you will be contacted when the release is posted.
Your request for a public interest fee waiver is under consideration and you will be advised
of the decision if fees are applicable. If your fee waiver is not granted, you will be
responsible for applicable fees per your designated requester fee category below.
For the purpose of assessing any fees, we have determined:
As a commercial use requester, you will be charged applicable search, review,
and duplication fees in accordance with 5 USC § 552 (a)(4)(A)(ii)(I).
As an educational institution, noncommercial scientific institution or
representative of the news media requester, you will be charged applicable
duplication fees in accordance with 5 USC § 552 (a)(4)(A)(ii)(II).
As a general (all others) requester, you will be charged applicable search and
duplication fees in accordance with 5 USC § 552 (a)(4)(A)(ii)(III).

 Case 1:19-cv-03773-ABJ Document 1-19 Filed 12/18/19 Page 3 of 3
Please check the status of your FOIPA request at www.fbi.gov/foia by clicking on FOIPA Status
and entering your FOIPA Request Number. Status updates are adjusted weekly. The status of newly
assigned requests may not be available until the next weekly update. If the FOIPA has been closed the
notice will indicate that appropriate correspondence has been mailed to the address on file.
For questions regarding our determinations, visit the www.fbi.gov/foia website under “Contact Us.”
The FOIPA Request number listed above has been assigned to your request. Please use this number in all
correspondence concerning your request.
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you
may submit an appeal through OIP's FOIA online portal by creating an account on the following web
site: https://www.foiaonline.gov/foiaonline/action/public/home. Your appeal must be postmarked or
electronically transmitted within ninety (90) days from the date of this letter in order to be considered timely.
If you submit your appeal by mail, both the letter and the envelope should be clearly marked “Freedom of
Information Act Appeal.” Please cite the FOIPA Request Number assigned to your request so it may be
easily identified.
You may seek dispute resolution services by contacting the Office of Government Information
Services (OGIS). The contact information for OGIS is as follows: Office of Government Information
Services, National Archives and Records Administration, 8601 Adelphi Road-OGIS, College Park, Maryland
20740-6001, e-mail at ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile
at 202-741-5769. Alternatively, you may contact the FBI’s FOIA Public Liaison by emailing
foipaquestions@fbi.gov. If you submit your dispute resolution correspondence by email, the subject
heading should clearly state “Dispute Resolution Services.” Please also cite the FOIPA Request Number
assigned to your request so it may be easily identified.

Sincerely,

David M. Hardy
Section Chief,
Record/Information
Dissemination Section
Information Management Division

 Case Document 1-20 Filed 12/18/19 Page 1 of 3

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-20 Filed 12/18/19 Page 2 of 3
U.S. Department of Justice

Federal Bureau of Investigation
Washington, D.C. 20535

August 28, 2019
MR. SCOTT ANDERSON
LAWFARE
POST OFFICE BOX 33226
WASHINGTON, DC 20033
FOIPA Request No.: 1445323-000
Subject: FBI Employees Reprimanded for
Negative/Positive Statements about Elected
Candidates
(November 20, 2011 – August 26, 2019)
Dear Mr. Anderson:
This is in reference to your letter to the FBI, in which you requested expedited processing for the abovereferenced Freedom of Information/Privacy Acts (FOIPA) request. Under Department of Justice (DOJ) standards,
expedited processing can only be granted in the following situations.
You have requested expedited processing according to:
28 C.F.R. §16.5 (e)(1)(i): “Circumstances in which the lack of expedited treatment could reasonably
be expected to pose an imminent threat to the life or physical safety of an individual.”
28 C.F.R. §16.5 (e)(1)(ii): “An urgency to inform the public about an actual or alleged federal
government activity, if made by a person primarily engaged in disseminating information.”
28 C.F.R. §16.5 (e)(1)(iii): “The loss of substantial due process of rights.”
28 C.F.R. §16.5 (e)(1)(iv): “A matter of widespread and exceptional media interest in which there
exist possible questions about the government’s integrity which affect public confidence.”
You have not provided enough information concerning the statutory requirements for expedition; therefore,
your request is denied.
For questions regarding our determinations, visit the www.fbi.gov/foia website under “Contact Us.”
The FOIPA Request number listed above has been assigned to your request. Please use this number in all
correspondence concerning your request.
You may file an appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Suite 11050, 1425 New York Avenue, NW, Washington, D.C. 20530-0001, or you
may submit an appeal through OIP's FOIA online portal by creating an account on the following web
site: https://www.foiaonline.gov/foiaonline/action/public/home. Your appeal must be postmarked or electronically
transmitted within ninety (90) days from the date of this letter in order to be considered timely. If you submit your
appeal by mail, both the letter and the envelope should be clearly marked “Freedom of Information Act Appeal.”
Please cite the FOIPA Request Number assigned to your request so it may be easily identified.

 Case 1:19-cv-03773-ABJ Document 1-20 Filed 12/18/19 Page 3 of 3
You may seek dispute resolution services by contacting the Office of Government Information Services
(OGIS). The contact information for OGIS is as follows: Office of Government Information Services, National
Archives and Records Administration, 8601 Adelphi Road-OGIS, College Park, Maryland 20740-6001, e-mail at
ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile at 202-741-5769. Alternatively,
you may contact the FBI’s FOIA Public Liaison by emailing foipaquestions@fbi.gov. If you submit your dispute
resolution correspondence by email, the subject heading should clearly state “Dispute Resolution Services.” Please
also cite the FOIPA Request Number assigned to your request so it may be easily identified.

Sincerely,

David M. Hardy
Section Chief
Record/Information
Dissemination Section
Information Management Division

 Case Document 1-21 Filed 12/18/19 Page 1 of 3

Exhibit 

Case 1:19-cv-03773-ABJ Document 1-21 Filed 12/18/19 Page 2 of 3

eFOIPA Request System
Welcome to the FBI’s eFOIPA submission portal. This site is designed to make it easier for the
public to submit Freedom of Information and Privacy Act (FOIPA) requests to the FBI.
Requesters that use this system to submit their eFOIPA requests will be able to receive future
correspondence and releases electronically from the FBI.

eFOIPA files
Submission: 07396d0 (2 files)
Submission: 9891a48 (3 files)

Submitted Forms
04/04/2019(ID: 9891a48)
08/14/2019(ID: 872ffce)
08/14/2019(ID: a864b0b)
08/19/2019(ID: f1bee79)
08/19/2019(ID: 2e7b61c)
08/19/2019(ID: 51df75b)
08/19/2019(ID: 25ebe7b)
08/19/2019(ID: b82bfbb)
08/19/2019(ID: 8e6a33b)
08/19/2019(ID: b27bb00)
08/19/2019(ID: 68b08c9)
08/19/2019(ID: 07396d0)
08/19/2019(ID: 5099f8f)
08/19/2019(ID: a6dadfd)

 Case 1:19-cv-03773-ABJ Document 1-21 Filed 12/18/19 Page 3 of 3

Submitted Forms
08/19/2019(ID: 3eed912)
08/19/2019(ID: d54a59f)
08/19/2019(ID: 6f6564f)
08/19/2019(ID: e991399)
08/19/2019(ID: 9a866e6)
08/19/2019(ID: 4039bd4)
08/19/2019(ID: e729fce)

New eFOIPA Submission
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An Organization →

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 Case 1:19-cv-03773-ABJ Document 1-22 Filed 12/18/19 Page 1 of 2
CIVIL COVER SHEET
JS-44 (Rev. 6/17 DC)

I. (a) PLAINTIFFS

DEFENDANTS

Benjamin Wittes and Scott R. Anderson

U.S. Federal Bureau of Investigation

11001

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _____________________
(IN U.S. PLAINTIFF CASES ONLY)

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF _____________________
(EXCEPT IN U.S. PLAINTIFF CASES)
(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED

ATTORNEYS (IF KNOWN)

Robert S. Litt , Morrison & Foerster LLP
2000 Pennsylvania Avenue, NW Suite 6000
Washington, DC 20006
(202) 887-1588
II. BASIS OF JURISDICTION

III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX FOR

(PLACE AN x IN ONE BOX ONLY)

o
o

1 U.S. Government
Plaintiff
2 U.S. Government
Defendant

o
o

3 Federal Question
(U.S. Government Not a Party)
4 Diversity
(Indicate Citizenship of
Parties in item III)

PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!
PTF
DFT

Citizen of this State
Citizen of Another State
Citizen or Subject of a
Foreign Country

o1 o1
o2 o2
o3 o3

Incorporated or Principal Place
of Business in This State
Incorporated and Principal Place
of Business in Another State
Foreign Nation

PTF

DFT

o4 o4
o5 o5
o6 o6

IV. CASE ASSIGNMENT AND NATURE OF SUIT
(Place an X in one category, A-N, that best represents your Cause of Action and one in a corresponding Nature of Suit)

o

A. Antitrust
410 Antitrust

o

o

o

B. Personal Injury/
Malpractice
310 Airplane
315 Airplane Product Liability
320 Assault, Libel & Slander
330 Federal Employers Liability
340 Marine
345 Marine Product Liability
350 Motor Vehicle
355 Motor Vehicle Product Liability
360 Other Personal Injury
362 Medical Malpractice
365 Product Liability
367 Health Care/Pharmaceutical
Personal Injury Product Liability
368 Asbestos Product Liability

E. General Civil (Other)

Real Property
210 Land Condemnation
220 Foreclosure
230 Rent, Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
Personal Property
370 Other Fraud
371 Truth in Lending
380 Other Personal Property
Damage
385 Property Damage
Product Liability

C. Administrative Agency
Review
151 Medicare Act

Social Security
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
Other Statutes
891 Agricultural Acts
893 Environmental Matters
890 Other Statutory Actions (If
Administrative Agency is
Involved)

OR
Bankruptcy
422 Appeal 27 USC 158
423 Withdrawal 28 USC 157
Prisoner Petitions
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Conditions
560 Civil Detainee – Conditions
of Confinement
Property Rights
820 Copyrights
830 Patent
835 Patent – Abbreviated New
Drug Application
840 Trademark

o

o

D. Temporary Restraining
Order/Preliminary
Injunction

Any nature of suit from any category
may be selected for this category of
case assignment.
*(If Antitrust, then A governs)*

F. Pro Se General Civil
Federal Tax Suits
870 Taxes (US plaintiff or
defendant)
871 IRS-Third Party 26 USC
7609
Forfeiture/Penalty
625 Drug Related Seizure of
Property 21 USC 881
690 Other
Other Statutes
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
430 Banks & Banking
450 Commerce/ICC
Rates/etc.
460 Deportation

462 Naturalization
Application
465 Other Immigration
Actions
470 Racketeer Influenced
& Corrupt Organization
480 Consumer Credit
490 Cable/Satellite TV
850 Securities/Commodities/
Exchange
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of State
Statutes
890 Other Statutory Actions
(if not administrative agency
review or Privacy Act)

 Case 1:19-cv-03773-ABJ Document 1-22 Filed 12/18/19 Page 2 of 2

o

G. Habeas Corpus/
2255

o

K. Labor/ERISA
(non-employment)
710 Fair Labor Standards Act
720 Labor/Mgmt. Relations
740 Labor Railway Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Empl. Ret. Inc. Security Act

*(If pro se, select this deck)*

*(If pro se, select this deck)*

o

o

L. Other Civil Rights
(non-employment)
441 Voting (if not Voting Rights
Act)
443 Housing/Accommodations
440 Other Civil Rights
445 Americans w/Disabilities –
Employment
446 Americans w/Disabilities –
Other
448 Education

o

I. FOIA/Privacy Act
895 Freedom of Information Act
890 Other Statutory Actions
(if Privacy Act)

442 Civil Rights – Employment
(criteria: race, gender/sex,
national origin,
discrimination, disability, age,
religion, retaliation)

530 Habeas Corpus – General
510 Motion/Vacate Sentence
463 Habeas Corpus – Alien
Detainee

o

o

H. Employment
Discrimination

152 Recovery of Defaulted
Student Loan
(excluding veterans)

o

M. Contract
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of
Judgment
153 Recovery of Overpayment
of Veteran’s Benefits
160 Stockholder’s Suits
190 Other Contracts
195 Contract Product Liability
196 Franchise

J. Student Loan

N. Three-Judge
Court
441 Civil Rights – Voting
(if Voting Rights Act)

V. ORIGIN

o 1 Original o 2 Removed o 3 Remanded
Proceeding

from State
Court

from Appellate
Court

o 4 Reinstated o 5 Transferred o 6 Multi-district o 7 Appeal to
or Reopened

from another
district (specify)

Litigation

o 8 Multi-district

District Judge
from Mag.
Judge

Litigation –
Direct File

VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)

5 USC § 552 (FOIA violations: failure to respond within statutorily prescribed time limit; unlawfully withholding records)
VII. REQUESTED IN
COMPLAINT

CHECK IF THIS IS A CLASS
ACTION UNDER F.R.C.P. 23

DEMAND $
JURY DEMAND:

VIII. RELATED CASE(S)
IF ANY

(See instruction)

YES

12/18/2019
DATE: _________________________

NO

Check YES only if demanded in complaint

YES

✘

NO

✘

If yes, please complete related case form

/s/ Robert S. Litt
SIGNATURE OF ATTORNEY OF RECORD _________________________________________________________
INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44
Authority for Civil Cover Sheet

The JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and services of pleadings or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the
Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed.
Listed below are tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the cover sheet.
I.

COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff if resident
of Washington, DC, 88888 if plaintiff is resident of United States but not Washington, DC, and 99999 if plaintiff is outside the United States.

III.

CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction
under Section II.

IV.

CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the category you select that best
represents the primary cause of action found in your complaint. You may select only one category. You must also select one corresponding
nature of suit found under the category of the case.

VI.

CAUSE OF ACTION: Cite the U.S. Civil Statute under which you are filing and write a brief statement of the primary cause.

VIII.

RELATED CASE(S), IF ANY: If you indicated that there is a related case, you must complete a related case form, which may be obtained from
the Clerk’s Office.

Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form.

 Case 1:19-cv-03773-ABJ Document 1-23 Filed 12/18/19 Page 1 of 2
FOIA Summons

1/13

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

Benjamin Wittes and Scott R. Anderson
Plaintiff
v.

U.S. Federal Bureau of Investigation
Defendant

)
)
)
)
)
)
)

CLEAR FORM

Civil Action No.

SUMMONS IN A CIVIL ACTION
To:

(Defendant’s name and address)

U.S. Federal Bureau of Investigation
935 Pennsylvania Avenue, NW
Washington, D.C. 20535

A lawsuit has been filed against you.
Within 30 days after service of this summons on you (not counting the day you received it) you must
serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of
Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and
address are:
Robert S. Litt
MORRISON & FOERSTER LLP
2000 Pennsylvania Avenue, NW
Suite 6000
Washington, DC 20006
(202) 887-1588
rlitt@mofo.com

If you fail to respond, judgment by default may be entered against you for the relief demanded in the
complaint. You also must file your answer or motion with the court.

ANGELA D. CAESAR, CLERK OF COURT

Date:

12/18/2019
Signature of Clerk or Deputy Clerk

 Case 1:19-cv-03773-ABJ Document 1-23 Filed 12/18/19 Page 2 of 2
FOIA Summons (1/13) (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

’ I personally served the summons on the individual at (place)
on (date)

; or

’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

’ I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

’ I returned the summons unexecuted because

; or

’ Other (specify):
.

My fees are $

for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.
Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

Print

Save As...

Reset

.

 Case 1:19-cv-03773-ABJ Document 1-24 Filed 12/18/19 Page 1 of 2
FOIA Summons

1/13

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

Benjamin Wittes and Scott R. Anderson
Plaintiff
v.

U.S. Federal Bureau of Investigation
Defendant

)
)
)
)
)
)
)

CLEAR FORM

Civil Action No.

SUMMONS IN A CIVIL ACTION
To:

(Defendant’s name and address)

Attorney General William P. Barr
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, D.C. 20530

A lawsuit has been filed against you.
Within 30 days after service of this summons on you (not counting the day you received it) you must
serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of
Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and
address are:
Robert S. Litt
MORRISON & FOERSTER LLP
2000 Pennsylvania Avenue, NW
Suite 6000
Washington, DC 20006
(202) 887-1588
rlitt@mofo.com

If you fail to respond, judgment by default may be entered against you for the relief demanded in the
complaint. You also must file your answer or motion with the court.

ANGELA D. CAESAR, CLERK OF COURT

Date:

12/18/2019
Signature of Clerk or Deputy Clerk

 Case 1:19-cv-03773-ABJ Document 1-24 Filed 12/18/19 Page 2 of 2
FOIA Summons (1/13) (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

’ I personally served the summons on the individual at (place)
on (date)

; or

’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

’ I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

’ I returned the summons unexecuted because

; or

’ Other (specify):
.

My fees are $

for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.
Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

Print

Save As...

Reset

.

 Case 1:19-cv-03773-ABJ Document 1-25 Filed 12/18/19 Page 1 of 2
FOIA Summons

1/13

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

Benjamin Wittes and Scott R. Anderson
Plaintiff
v.

U.S. Federal Bureau of Investigation
Defendant

)
)
)
)
)
)
)

CLEAR FORM

Civil Action No.

SUMMONS IN A CIVIL ACTION
To:

(Defendant’s name and address)

Jessie K. Liu
U.S. Attorney for the District of Columbia
United States Attorney's Office
555 4th Street, N.W.
Washington, D.C. 20530

A lawsuit has been filed against you.
Within 30 days after service of this summons on you (not counting the day you received it) you must
serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of
Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and
address are:
Robert S. Litt
MORRISON & FOERSTER LLP
2000 Pennsylvania Avenue, NW
Suite 6000
Washington, DC 20006
(202) 887-1588
rlitt@mofo.com

If you fail to respond, judgment by default may be entered against you for the relief demanded in the
complaint. You also must file your answer or motion with the court.

ANGELA D. CAESAR, CLERK OF COURT

Date:

12/18/2019
Signature of Clerk or Deputy Clerk

 Case 1:19-cv-03773-ABJ Document 1-25 Filed 12/18/19 Page 2 of 2
FOIA Summons (1/13) (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

.

’ I personally served the summons on the individual at (place)
on (date)

; or

’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individual’s last known address; or
, who is

’ I served the summons on (name of individual)
designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

’ I returned the summons unexecuted because

; or

’ Other (specify):
.

My fees are $

for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.
Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

Print

Save As...

Reset

.