February 5, 2010
Director of Records Management
Federal Emergency Management Agency
Re: Freedom of Information Act Request
To Whom It May Concern:
This office is legal counsel to the
U.S. Citizens Association, a non-profit, tax-exempt organization of citizens working together for better government.
My client is seeking any and all information concerning the establishment of detention centers by FEMA for use in counter-insurgency against American citizens.
Reports exist that as many as 800 detention centers have been established by FEMA to house dissidents or others.
My clients wish to know:
1. Who authorized the construction of these facilities?
2. Under what authority were they constructed?
3. Where are the locations of these faculties?
4. What are the categories of individuals intended for these faculties?
5. Under what circumstances will these facilities be used?
It is also asked that my client be supplied:
1. Any photographs of these facilities.
2. The names and contact information of all persons involved in deciding who will be placed in these facilities.
3. What is “Rex 84”?
4. What is “Operation Cable Splicers”?
5. What is “Operation Garden Plot”?
Any documents explaining the operation of Rex 84, Operation Cable Splicers, and Operation Garden Plot would be appreciated.
It is asked that all costs related to this request be waived. My client has no commercial interests. The use of these documents will be for discussion purposes among the members of my client organization, so that they may make informed decisions about contacting their legislators.
They may decide to publish all or some of the information on their website, promote debate about the issues raised by the information and publish educational essays about the issues,
A copy of my client’s Mission Statement accompanies this request.
May I please hear from you soon?
~~~~~~~~~~~~~~~~~~~~~~~~~~ COMPLAINT ~~~~~~~~~~~~~~~~~~~~~~~~
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF COLUMBIA
Civil Action No.:
U.S. Citizen’s Association )
Suite 200 )
W. Market St. )
Federal Emergency Management Agency )
500 C Street S.W. )
AMENDED COMPLAINT FOR INJUNCTIVE RELIEF
This is an action under the Freedom of Information Act (“FOIA”) 5 U.S.C. S 522. Plaintiff seeks injunctive and other appropriate relief for the processing and release of agency records requested by plaintiff from the Federal Emergency Management Agency (FEMA).
JURISDICTION AND VENUE
This court has both subject matter jurisdiction over this action and personal jurisdiction over parties pursuant to 5 USC SS 552 (a) (4) (B) and 552 (a) (6) (c) (1). This court also has jurisdiction over this action pursuant to 28 USC S 133b. Venue lies in this district under S USC S 552 (a) (4) (b).
U.S. Citizens Association (USCA) is a non-profit public interest advocacy organization and civic league that educates the public about current affairs through newspaper advertisements, a web site and mailings. The USCA is interested in civil liberties and the possible impact on citizens’ rights of certain FEMA plans. It has a usual place of business at
1655 W. Market St., Suite 200,
Defendant Federal Emergency Management Agency is a branch of the United States Department of Homeland Security. It has a usual place of business at
500 C Street S.W.,
Defendant, FEMA, on information and belief, may be involved in the planning and construction of facilities for the detention and internment of American dissidents and others without due process of law.
On or about
February 5, 2010, the plaintiff sent, via Counsel, the letter affixed herein to the defendant, seeking full disclosure about the planning and location of these facilities as well as FEMA’s general intentions concerning these facilities.
The plaintiff also sought to learn the facts about a program called “Rex 84”, Operation Cable Splicers, and Operation Garden Plot, which on information and belief may be related to the imposition of martial law on American civilians.
Twenty days have passed. Thus far the defendant has not acknowledged the plaintiff’s communications.
Defendant has wrongfully withheld the requested records from the plaintiff.
Plaintiff is entitled to injunctive relief with respect to the release and disclosure of the requested documents.
Wherefore, plaintiff prays this Court
Order defendant FEMA to process immediately the requested records in their entirety.
Order defendant, upon completion of such processing to disclose the requested records in their entirety and make copies available to the plaintiff.
Award plaintiff costs and reasonable attorney’s fees.
Grant such other relief as the Court may deem just and proper.
For the plaintiff
By its attorney,
David C. Grossack, Esquire
1320 Centre Street, Suite 103
BBO # 212890
Dated: May 25, 2010