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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
______________________________________
)
CENTER FOR NATIONAL SECURITY STUDIES, )
ET AL., )
Plaintiffs, )
)
v. ) Civil Action
) No. 01-2500
UNITED STATES DEPARTMENT OF JUSTICE, )
) Judge Kessler
Defendant. )
______________________________________)
DEFENDANT'S STATEMENT OF MATERIAL FACTS
Defendant, United States Department of Justice, by and through its undersigned
counsel, submits the following statement of material facts as to which there
is no genuine issue.
1. Plaintiffs submitted three October 29, 2001 FOIA requests to the Department
of Justice, sending the first to the INS, a second to the FBI, and a third to
the Office of Information and Privacy ("OIP"). Declaration of Scott
A. Hodes ("Hodes Dec.") ** 2, 4; Declaration of Raymond Holmes ("Holmes
Dec.") * 6; Declaration of Melanie Ann Pustay ("Pustay Dec.")
* 3.
2. INS acknowledged receipt of the request on November 1, 2001. Holmes Dec.
* 7. It further responded on November 23, approving expedited treatment but
indicating that completing a response would be an "enormous undertaking."
Id. It therefore asked plaintiffs to narrow the scope of their broad request
so that fewer records would have to be retrieved and reviewed. Id. Plaintiffs
failed to respond or to narrow their request and instead filed this lawsuit.
Id.
3. On November 1, 2001, the FBI informed plaintiffs that it was withholding
material responsive to their requests pursuant to Exemption 7(A) of the Freedom
of Information Act ("FOIA"), 5 U.S.C. * 552(b)(7)(A). Hodes Dec. *
4. Plaintiffs appealed, but, on December 10, the FBI affirmed its original denial
under both Exemption 7(A) and 7(C), 5 U.S.C. * 552(b)(7)(A), (C). Hodes Dec.
* 4.
4. Because of the enormity of the investigation and the vast FBI resources
it is consuming, the FBI could not spare the personnel necessary to comb through
the thousands of pages of documents responsive to plaintiffs* FOIA request without
harming the progress of the investigation. Hodes Dec. * 9.
5. OIP acknowledged receipt of plaintiffs* request and granted expedited processing
on November 1, 2001. Pustay Dec. * 4. OIP was still processing the request at
the time plaintiffs filed this suit on December 5. Id.
6. Following the events of September 11, 2001, the United States government
launched an extensive, broad based and world-wide investigation into those terrorist
attacks and into threats, conspiracies, and attempts to perpetrate terrorist
acts against United States citizens and interests. Declaration of James S. Reynolds
("Reynolds Dec.") * 2. Since September 11, DOJ has actively been conducting
the investigation in conjunction with other federal, state and local agencies.
Id. Four thousand FBI agents are engaged with their international counterparts
in an unprecedented worldwide effort to prevent further attacks by apprehending
those responsible for the September 11 attacks and by detecting, disrupting,
and dismantling terrorist organizations. Id. This is an open and ongoing investigation;
the FBI is continuing to follow leads and conduct interviews at this time. Id.
7. As part of this investigation, law enforcement has questioned over one thousand
individuals about whom concern had arisen. Reynolds Dec. * 3.
8. The concerns related to some of these individuals were resolved by the interviews
and no further action was taken related to them. Reynolds Dec. * 4. Other interviews
resulted in a decision to take individuals into custody. Id. Those detainees
fall into three general categories. Id. First, some were arrested for alleged
violations of federal criminal law. Id. Second, those who have violated immigration
laws have been detained by INS for immigration violations. Id. Third, some individuals
who were believed to have information material to the events of September 11
were taken into custody under material witness warrants pursuant to 18 U.S.C.
* 3144. Reynolds Dec. * 4.
9. Plaintiffs seek information about all of these individuals. Reynolds Dec.
* 5. The information they seek is contained in DOJ records created as a result
of these investigations. Id. DOJ and its components, including INS and FBI,
have opened and maintained these files. Id. These files pertain to the ongoing
immigration proceedings of the detainees and related investigations. Id.
10. Specifically, plaintiffs' FOIA requests seek the following four items of
information regarding individuals "arrested or detained" in the wake
of the September 11 attacks on the World Trade Center and Pentagon:
a. (1) their names and citizenship status; (2) the location where each individual
was arrested or detained initially and the location where they are currently
held; (3) the dates they were detained or arrested, the dates any charges were
filed, and the dates they were released, if they have been released; and (4)
the nature of any criminal or immigration charges filed against them or other
basis for detaining them, including material witnesses warrants and the disposition
of such charges or warrants.
b. The identity of any lawyers representing any of these individuals, including
their names and addresses.
c. The identities of any courts, which have been requested to enter order sealing
any proceedings in connection with any of these individuals, any such orders
which have been entered, and the legal authorities that the government has relied
upon in seeking any such secrecy orders.
d. All policy directives or guidance issued to officials about making public
statements or disclosures about these individuals or about the sealing of judicial
or immigration proceedings.
Reynolds Dec. * 6.
11. The Department of Justice has already released publicly a significant amount
of information sought by plaintiffs, varying according to the category of the
detainee. Reynolds Dec. * 7. First, for INS detainees, DOJ has already disclosed
to plaintiffs (1) their place of birth, (2) citizenship status, (3) the immigration
charges brought against them, and (4) the date charges were filed. Id. With
respect to citizenship status, none of the INS detainees is a United States
citizen; each is in removal proceedings, subject to administrative removal,
or subject to a final order of removal. Id. All of this information was broadly
disseminated to the general public prior to the filing of this lawsuit. Id.
12. Second, for those persons being held on federal criminal charges whose
cases are not under seal, DOJ has already disclosed to plaintiffs (1) their
names, (2) the dates any charges were filed, (3) the date the defendant was
released, if released, (4) the nature of the criminal charges filed against
them, and (5) their lawyer's identity. Reynolds Dec. * 8. Prior to the filing
of this lawsuit, DOJ also released to the public the district where the complaint
or indictment was filed, whether the defendant was the subject of a complaint
or an indictment, and the Assistant United States Attorney assigned to the prosecution.
Id.
13. Nevertheless, DOJ has withheld certain information on the three categories
of detainees identified in paragraph 4. Reynolds Dec. * 9. The scope of the
withheld information has been narrowly tailored to protect the integrity and
efficacy of the ongoing investigations, to ensure the safety of the detainees
and U.S. citizens, and to prevent the invasion of the personal privacy of the
detainees and other individuals associated with them. Id.
INS DETAINEES
14. The first category of detainees are persons being held on immigration-related
charges by INS. Reynolds Dec. * 10. These individuals were originally questioned
because there were indications that they might have connections with, or possess
information pertaining to, terrorist activity against the United States including
particularly the September 11 attacks and/or the individuals and organizations
who perpetrated them. Id. For example, they may have been questioned because
they were identified as having interacted with the hijackers, or were believed
to have information relating to other aspects of the investigation. Id. In the
course of questioning them, law enforcement agents determined, often from the
subjects themselves, that they were in violation of federal immigration laws,
and, in some instances also determined that they had links to other facets of
the investigation. Id.
15. Regarding the INS detainees, DOJ has withheld the following information:
(1) the names of the INS detainees, (2) their citizenship status, (3) the location
where they were initially arrested or detained, (4) the location where they
are currently being held, (5) the date of their arrest or detention, and (6)
their lawyer's identity. Reynolds Dec. * 11.
16. Information regarding the INS detainees is being withheld pursuant to Exemption
7 (A), 7(C) and 7(F) of FOIA, 5 U.S.C. * 552(b)(7). Reynolds Dec. * 12. Exemption
7(A) protects from disclosure "records or information compiled for law
enforcement purposes" if their production "could reasonably be expected
to interfere with enforcement proceedings." Reynolds Dec. * 12; 5 U.S.C.
* 552(b)(7)(A). Exemption 7(C) protects law enforcement information the disclosure
of which "could reasonably be expected to constitute an unwarranted invasion
of personal privacy." Reynolds Dec. * 12; 5 U.S.C. * 552(b)(7)(C). Exemption
7(F) protects information compiled for law enforcement purposes, the disclosure
of which could reasonably be expected to endanger the life or physical safety
or an individual. Reynolds Dec. * 12; 5 U.S.C. * 552(b)(7)(F).
Exemption 7(A) of FOIA
17. As long as these investigations remain open and active, disclosing the
information in question could result in significant harm to the interests of
the United States and compromise the September 11 and other ongoing terrorism-
related investigations. Reynolds Dec. * 13. Indeed, releasing this information
could pave the way for additional terrorist activities in that it would undermine
the ability of the United States to obtain cooperation from knowledgeable witnesses,
thereby hampering follow up on investigative leads. Id.
18. First, disclosing the names of the detainees who may be revealed to have
knowledge of or a connection to terrorism could lead to the public identification
of individuals associated with them, other investigative sources, and potential
witnesses. Reynolds Dec. * 14. Terrorist organizations that discover the identities
of these individuals could subject them to intimidation or harm, thereby discouraging
or preventing them from supplying valuable information or further leads. Id.
19. Second, divulging the detainees' identities may deter them from cooperating
with the Department of Justice once they are released from custody and impair
their usefulness to the ongoing investigation. Reynolds Dec. * 15. As a result
of their public identification, terrorist organizations with whom they have
a connection may refuse to deal further with them. Id. This could eliminate
valuable sources of information for the investigation. Id. It would similarly
impair the government's ability to infiltrate terrorist organizations engaged
in ongoing criminal activities. Id. Moreover, a detainee who knows his name
will be made public may be deterred from cooperating now or in the future for
fear of retaliation by terrorist organizations against him or his family and
associates. Id.
20. Third, releasing the names of the detainees who may be associated with
terrorism and their place and date of arrest would reveal the direction and
progress of the investigations by identifying where DOJ is focusing its efforts.
Reynolds Dec. * 16. In effect, it would allow terrorist organizations to map
the progress of the investigation and thereby develop the means to impede them.
Id. Even disclosing the identities of those detainees who have been released
may reveal details about the focus and scope of the investigation and thereby
allow terrorists to counteract it. Id. This may cause terrorists, who learn
that their associates or even people who know their associates have been detained,
to alter their plans in a way that presents an even greater threat to the United
States. Id. Official verification that a member has been detained and therefore
can no longer carry out the plans of his terrorist organization may enable the
organization to find a substitute who can achieve its goals more effectively,
thereby thwarting the government's ability to frustrate ongoing conspiracies.
Id. For example, upon learning that a particular terrorist cell has been compromised
through the detention of some or all of its members or affiliated persons, terrorists
may switch to an alternative cell, thereby retaining the ability to mount future
terrorist attacks. Id.
21. Fourth, the public release of names, and place and date of arrest, of detainees
who may have knowledge of or connections to terrorism, could allow terrorist
organizations and others to interfere with the pending proceedings by creating
false or misleading evidence. Reynolds Dec. * 17. As a consequence, the investigations
will be hindered by unnecessary and burdensome confusion. Id. Similarly, revealing
the location of the detainees may facilitate contact between detainees and members
of terrorist organizations. Id.
22. The rationale that underlies the withholding of the names of the detainees
similarly supports the nondisclosure of their lawyers' identities under 5 U.S.C.
* 552(b)(7)(A) and (F). Reynolds Dec. * 18. Although some attorneys may voluntarily
reveal the names of their clients, such sporadic, piecemeal disclosures are
qualitatively different from DOJ's publication of a comprehensive list of all
lawyers' names. Id. Release of such a list may facilitate the identification
of the detainees themselves and the harms described above could ensue. Id.
Exemption 7(C) of FOIA
23. The detainees have a substantial privacy interest in their names and the
requested personal information connected with their status as detainees. Reynolds
Dec. * 19. All of these individuals were originally detained because of their
possible connection to terrorism, particularly to the worst terrorist attack
ever committed on United States soil. Id. Although they may eventually be found
to have no connection to terrorist activity, release of their names and personal
information at this time would forever connect them to the September 11 attacks.
Id. Given the nature of these investigations, the mere mention of their name
in connection with these investigations would cause the detainees embarrassment,
humiliation, risk of retaliation, harassment and possibly even physical harm
in the United States and in their home countries, if they are eventually deported.
Id. They could be stigmatized by being viewed as "guilty by association."
Id. The viciousness of the attacks of September 11 is unprecedented. Id. The
interests of these detainees in not being connected with such activity is overwhelming.
Id.
24. In their requests plaintiffs state that "there is an overriding public
interest in knowing the activities of the government in detaining people in
connection with the September 11 attack." Reynolds Dec. * 20. This assertion
of generalized public interest is not linked to the specific information that
has been requested. Id. The Department of Justice has already released much
information about "the activities of the government in detaining people,"
such as the number of people detained and the charges brought against them.
Id. The disclosure of their names and their current location * which could lead
to their identification * would pose the risks discussed in paragraphs 14-17
while not adding significantly to the public's understanding of the overall
activities of the government. Id. As a result, when the strong privacy interests
of the detainees are balanced against any public interest in disclosure, the
privacy interests in protection outweigh any perceived public interest in release.
Id.
25. Moreover, all of these individuals have been charged with immigration violations
which are at various stages of the administrative process. Reynolds Dec. * 21.
Many detainees have retained counsel and all detainees have that right. Id.
No one has been denied their right to talk to an attorney. Id. INS has provided
each of the persons detained on immigration violations with information about
available pro bono representation. Id. Persons with criminal charges filed against
them and material witnesses have been assigned counsel at government expense
if they cannot afford one. Id.
26. While these proceedings are usually public, see 8 C.F.R. * 240.10(b) (with
various exceptions, see 8 C.F.R. * 3.27), the Department of Justice has ordered
them sealed if they involve a detainee originally taken into custody in connection
with the terrorist investigation. Reynolds Dec. * 22. Identifying information
has been kept confidential to avoid stigmatizing the detainee through the implication
that he is associated with terrorism. Id.
27. If the detainees wish to disclose their names they may do so. Reynolds
Dec. * 23. For the Department of Justice to publish a list of potential or actual
immigration violators, however, would violate their personal privacy interests,
which are protected by 5 U.S.C. * 552(b)(7)(C). Reynolds Dec. * 23. Release
of this information would not contribute meaningfully to the public*s understanding
of the inner workings of the government. Id.
Lawyers of the Detainees
28. The names of the detainees' lawyers are also being withheld pursuant to
FOIA Exemption 7(C). Reynolds Dec. * 24. In reaching our determination to withhold
this information, we balanced the privacy interests of these individuals against
any public interest in disclosure. Id. While there may be some other public
interest * not applicable under the FOIA * in ensuring that the detainees are
properly represented, that interest is not vindicated here. Id. In fact, we
can discern no public interest cognizable under the FOIA in the identities of
the individual private attorneys that have been retained. Id.
29. Any public interest that may exist is far outweighed by the strong privacy
interests at stake here. Reynolds Dec. * 25. Unlike more routine immigration
cases where attorneys readily, and openly represent clients, these particular
lawyers are representing individuals who have been apprehended in connection
with the investigation emanating from what has been described as an act of war
against the United States. Id. The overwhelming grief and anger felt by the
American people could be directed at these attorneys even more strongly than
at the detainees themselves. Id. While all people have a right to counsel in
this country, some individuals may view the attorneys' representation of the
detainees negatively because of the severity of the attacks on our nation. Id.
30. Indeed, some attorneys may have been dissuaded from representing individuals
in this context. Reynolds Dec. * 26. Those that do, run the risk that they will
be subjected to harassment or retaliation in their personal as well as professional
lives. Id. Revealing the identities of these lawyers may also subject them to
unwanted scrutiny by the public or the media that could distract them from effective
representation of their clients. Id. They have a strong privacy interest in
not having the government facilitate such harms by publicly identifying them
to all the world. Id. Those attorneys who wish to come forward and identify
themselves voluntarily are free to do so, but the government should not be forced
to reveal a comprehensive list of all their identities thereby forcibly exposing
those that chose to remain obscure to the risks described above. Id.
DETAINEES CHARGED WITH FEDERAL CRIMES
31. The second category of detainees consists of 117 individuals who have been
held on federal criminal charges. Reynolds Dec. * 27. One individual, Zaccharias
Moussaui, has been charged with violations of federal criminal laws in connection
with the September 11 attacks. Id. Like the INS detainees, these individuals
were originally apprehended by federal, state, or local law enforcement as a
result of the federal investigation emanating from the September 11 attacks.
Id. These individuals face federal criminal charges. Id. They remain a potential
source of relevant or probative information. Id.
32. The following information has not been disclosed: (1) their citizenship
status, (2) the location where they were initially arrested or detained, (3)
the location where they are currently being held, and (4) the date of their
arrest or detention. Reynolds Dec. * 28. This information was withheld pursuant
to 5 U.S.C. * 552(b)(7)(A), 7(C) and 7(D). Reynolds Dec. * 28. The release of
this information would assist terrorist organizations in tracking the flow and
progress of the investigation and to develop a strategy to counteract it, as
described above. Id. Accordingly, it was properly withheld to prevent the possible
compromise of this most sensitive investigation. Id.
33. Information pertaining to the detainees charged with federal crimes is
also exempt from release under Exemption 7(C). Reynolds Dec. * 29. Because of
these individuals' association with the terrorist investigation, disclosing
their detention location could subject them to possible harassment, intimidation
and even physical harm. Id. It is not unusual for other prisoners in a facility
to attempt to harm or harass those they believe have been involved in particularly
heinous crimes. Id. If prisoners learn that an individual who was detained as
a result of the investigation emanating from the September 11 attacks is in
their own prison facility, some may try to retaliate against this individual.
Id.
34. In addition, the detention location is an item of information about each
of these individuals. Id. The detainees have no voice in the determination as
to where they are detained. Id.
MATERIAL WITNESSES
35. The third category of detainees consists of persons who have been the subject
of a material witness warrant issued by a federal court. Reynolds Dec. * 31.
Plaintiffs have requested the names of these detainees, their citizenship status,
the location where they were arrested or detained, the location where they are
being held, the dates they were arrested or detained, the date any charges were
filed, the date they were released, if released, the nature of any charges against
them, and their lawyers' names. Id. All information sought in the FOIA request
regarding these detainees has been withheld. Id.
36. The United States District Courts before which the material witnesses have
appeared have issued sealing orders prohibiting the government from releasing
any information about these proceedings. Reynolds Dec. * 32. Hence, this information
is not under the control of the Department of Justice, which therefore cannot
release it to plaintiffs. Id.
37. Moreover, this information is also protected from disclosure by Exemption
3 of the FOIA, 5 U.S.C. * 552(b)(3). Reynolds Dec. * 33. This exemption protects
information exempted from disclosure by statute. Id. In this case, information
pertaining to material witnesses was withheld pursuant to Federal Rule of Criminal
Procedure 6(e). Reynolds Dec. * 33.
38. Rule 6(e) prohibits the disclosure of information that would reveal the
inner workings of the grand jury. Reynolds Dec. * 34. This prohibition includes
the identities of witnesses and the substance of testimony, as well as information
that would reveal the scope, focus and direction of the grand jury proceedings.
Id. To reveal any information pertaining to the material witnesses, including
their identities and any information which would lead to their identities, would
violate Rule 6(e) by revealing witness names as well as the scope and direction
of the grand jury proceedings. Reynolds Dec. * 34.
39. Disclosure of this information about material witnesses could also reveal
the strategy or direction of the investigation as described above. Reynolds
Dec. * 35. These justifications are particularly compelling for the material
witnesses, as they are believed to have evidence directly relevant to acts of
terrorism. Id. Therefore the information is also being withheld pursuant to
5 U.S.C. * 552(b)(7)(A). Reynolds Dec. * 35.
40. Those individuals who are being held on material witness warrants also
have a substantial privacy interest in their names and the requested personal
information connected with their status as a material witness. Reynolds Dec.
* 36. As with the INS detainees, these individuals were apprehended as a result
of the terrorist investigation and they have a strong interest in not being
identified with the investigation. Id. Even more significantly, these material
witnesses would be assumed by many people to have significant information relevant
to the events of September 11. Id. In fact, it may turn out that these individuals
have no information useful to the investigation or that they are innocent people
who are able to assist the government in its investigations. Id. To reveal their
identities in connection with these investigations could stigmatize them and
subject them to harassment and possibly even retaliation. Id. Defendant can
discern no public interest that outweighs their strong privacy interests. Id.
Exemption 7(F) of the FOIA
41. FOIA Exemption 7(F), 5 U.S.C. * 552(b)(7)(F) also protects the identities
of the INS detainees, the identities of those being held on material witness
warrants, the detention location of those who have been charged with a federal
crime, and the identities of the detainees* lawyers. Reynolds Dec. * 37. Exemption
7(F) protects information the disclosure of which "could reasonably be
expected to endanger the life or physical safety of any individual." Reynolds
Dec. * 37. As discussed above, all of the detainees were apprehended in connection
with the investigation emanating from the September 11 attacks. Id. Revealing
their identities could subject them to physical danger both in the United States
and in their home countries if they are deported. Id. Detainees who are, in
fact affiliated with a terrorist group may be perceived by such groups as informants
for the United States and be killed to preclude their future cooperation. Id.
In addition, the detainees* family members and friends could face threats of
physical violence by terrorists to deter the detainees from cooperating. Id.
Moreover, revealing the detention facilities where these individuals are being
detained could place at risk not only those detainees, but the facilities themselves
and their employees.
42. For these same reasons, attorneys who are representing the detainees could
also face physical harm if their identities are revealed. Reynolds Dec. * 38.
Some might construe the attorneys as working against the interests of the United
States and seek to retaliate against them. Id. Also, members of terrorist organizations
may fear that detainees are supplying their attorneys with too much information
and, lacking the ability to get at the detainees while they are imprisoned,
may instead choose to harm their attorneys. Id. In light of the brutality of
the acts committed against the United States, even the mere possibility of retaliation
against these lawyers justifies withholding their identities. Id.
PLAINTIFFS' FOIA REQUEST NO. 3 (COMPLAINT * 29(c))
43. DOJ has denied plaintiffs' request for the identity of any courts which
have been requested to enter orders sealing any proceedings in connection with
individuals arrested or detained in the wake of the September 11 attack, any
such orders which have been entered, and the legal authorities that the government
has relied upon in seeking any such secrecy orders. Reynolds Dec. * 39. Nationwide,
there are ten orders responsive to plaintiffs' request. Id. However, neither
the orders nor any of the other information requested is under DOJ's control.
Id. Rather, the orders have been sealed by the relevant United States District
Courts and prohibit the government from releasing any information. Id. Thus,
the Department of Justice cannot properly provide the information plaintiffs
request. Id.
44. Even if the information could be disclosed, it is exempt from disclosure
pursuant to 5 U.S.C. * 552(b)(7)(A). Reynolds dec. * 40. Publicizing this information
would reveal investigative strategy or an unusual level of law enforcement interest
in a detainee which would impair investigative efforts, as further described
herein. Id.
45. As has been described above, the Department of Justice has made every effort
to segregate and release all non-exempt information requested by plaintiffs.
Reynolds Dec. * 41. Toward that end, defendant has released entire categories
of information. Id. The information defendant continues to withhold cannot be
disclosed without causing or risking the serious and substantial harms outlined
herein. Id.
Respectfully submitted,
ROBERT D. McCALLUM, JR.
Assistant Attorney General
ROSCOE C. HOWARD
United States Attorney
DAVID J. ANDERSON
ANNE L. WEISMANN
LISA A. OLSON
U.S. Department of Justice
Civil Division, Room 1052
901 E Street, N.W.
Washington, D.C. 20530
Telephone: (202) 514-5633
Facsimile: (202) 616-8470
E-mail:
This e-mail address is being protected from spam bots, you need JavaScript enabled to view it
Dated: Jan. 11, 2002 Counsel for Defendant
CERTIFICATE OF SERVICE
I hereby certify that on January 11, 2002, copies of the Answer, Defendant's
Statement of Material Facts, Defendant's Motion for Summary Judgment, and the
Memorandum in Support of Defendant's Motion for Summary Judgment, with attached
Exhibits were served by hand-delivery, first-class mail, or federal express,
upon plaintiffs' counsel as follows:
David L. Sobel, Esq.
Electronic Privacy Information Center
1718 Connecticut Avenue, N.W.
Suite 200
Washington, D.C. 20009
fax: (202) 483-1248
Arthur B. Spitzer, Esq.
American Civil Liberties Union
of the National Capital Area
1400 20th Street, N.W. #119
Washington, D.C. 20036
fax: (202) 452-1868
Kate Martin, Esq.
Center for National Security Studies
2130 H Street, N.W. S. 701
Washington, D.C. 20037
fax: (202) 994-7005
Steven R. Shapiro, Esq.
Lucan Guttentag, Esq.
American Civil Liberties Union Foundation
125 Broad Street
New York, N.Y. 10004
fax: (212) 549-2651
Ellior M. Mincberg, Esq.
People for the American Way Foundation
2000 M Street, N.W., Suite 400
Washington, D.C. 20036
fax: (202) 293-2672
__________________________
LISA A. OLSON
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