UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
BRENNAN CENTER FOR JUSTICE et al.,
Plaintiffs,
v.

17 Civ. 
us. DEPARTMENT or JUSTICE et al.,



Defendants.

SUPPLEMENTAL DECLARATION OF C.T. MONICA CHYN

I, C.T. Monica Chyn, Division Director for the Office of Privacy and Disclosure in
the Office ofthe General Counsel at the Social Security Administration (SSA), do hereby
declare, based upon my personal knowledge and review ofagency records. as follows:

1. I am employed at SSA in Baltimore, Maryland as the Division Director for
the Of?ce ofPrivacy and Disclosure (OPD). OPD is the of?ce at SSA that processes and
responds to Freedom of Information Act (FOIA) requests. As such, I have personal
knowledge of the procedures that SSA employs in handling FOIA requests for records
pursuant to 5 U.S.C. 552. Specifically, I was involved in handling of Brennan
Center?s FOIA request, dated October 18, 2017 and assigned the tracking number SSA-
2018?000222, for records concerning the Presidential Advisory Commission on Election
Integrity (PACEI), and Brennan Center?s appeal to SSA's response.

2. This supplemental declaration discusses response to the part of the
Court?s April 30, 2019 Order requiring SSA to ?ask relevant employees ifthey used private
email accounts relating to the business and, if so, to produce the documents.?

In response to that directive, SSA asked all relevant staff to report if they had any

1

potentially responsive agency records outside of agency records systems. On June 4, 2019,
SSA circulated a notice to relevant staffdirecting those employees to report if they had any
records potentially responsive to the FOIA request that were located outside of agency
systems, such as in a personal email account.

3. SSA speci?cally directed this notice to Senior Executives with a reasonable
likelihood, based on their duties and responsibilities, of maintaining records responsive to
Plaintiffs? October 18, 2017 FOIA request. Senior Executives to which SSA directed this
inquiry included agency executives from the Of?ce of the Commissioner, Office of the
General Counsel, Of?ce of Communications. Of?ce of Operations, Of?ce of Systems,
Office of Legislation and Congressional Affairs (OLCA), and what was then known as the
Of?ce ofData Exchange and Policy Publications (ODEPP).

4. Given the data exchange responsibilities of ODEPP and high?level
communications responsibilities of OLCA, SSA also asked the Senior Executives at these
components to identify any employees within their components that may have responsive
records and sent the notice to those employees as well. SSA determined it was not
reasonably likely that non-Senior Executive staff from other agency components would
have responsive records, based on the duties and responsibilities of each component.

5. No employee who received the June 4, 2019 notice reported any potentially

responsive records located outside of agency systems.

Pursuant to 28 U.S.C. 1746, I declare under penalty ol? perjury that the foregoing
is true and correct.





0142

Executed on July 2019
Springfield, Illinois

 


CT. Monica Chy?ii
Division Director
Of?ce of Privacy and Disclosure
Social Security Administration