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FBI FOIA Request:
May 18, 2005
Federal Bureau of Investigation J. Edgar Hoover Building
935 Pennsylvania Avenue NW, Washington, D.C. 20535-0001
James Finch, Special Agent in Charge, Federal Bureau of Investigation
330 E. Kilbourn Ave, Suite 600, Milwaukee, WI 53202
Re: REQUEST UNDER FREEDOM OF INFORMATION ACT & PRIVACY ACT/Expedited
Processing Requested
This letter constitutes a request under the Freedom of Information Act,
5 U.S.C. § 552 (“FOIA”), and the Department of Justice
implementing regulations, 28 C.F.R. § 16,11, by the American Civil
Liberties Union of Wisconsin and the American Civil Liberties Union of
Wisconsin Foundation (“ACLU”), on its own behalf, and on behalf
of the Islamic Society of Milwaukee, the Wisconsin Coalition to Normalize
Relations with Cuba, Peace Action Wisconsin, the National Lawyers Guild
(Milwaukee Chapter), George Martin, Arthur Heitzer, Steve Watrous and
Karyn Rotker (the “Requesters”).
I. The Requesters
1. The American Civil Liberties Union of Wisconsin and the American Civil
Liberties Union of Wisconsin Foundation (collectively, “ACLU of
Wisconsin”) are the Wisconsin affiliates of the American Civil Liberties
Union and the American Civil Liberties Union Foundation (“ACLU”),
a national organization that works to protect civil rights and civil liberties.
Nationally, the ACLU has challenged the United States government’s
broad targeting and surveillance of innocent people as part of the “war
on terrorism,” the government’s crackdown on criticism and
dissent, the secret and unchecked surveillance powers of the USA PATRIOT
Act, the excessive restriction of government information available through
the Freedom of Information Act, the unfair questioning and targeting of
immigrants, the unfair detention and treatment of people arrested in the
U.S. as part of the war on terrorism, and the unlawful detention and abuse
of prisoners held by the U.S. government in detention facilities overseas.
ACLU attorneys have filed lawsuits challenging three of the most controversial
surveillance provisions of the USA PATRIOT Act: Section 215, which authorizes
the FBI to obtain an unlimited array of personal records about innocent
people through secret court orders; Section 505, which authorizes the
FBI to issue National Security Letters demanding certain kinds of personal
records without court oversight; and Section 218, which greatly expands
the FBI’s power to obtain wiretaps.
ACLU attorneys have also provided direct representation to thousands of
individuals interrogated by the FBI as part of its “voluntary”
interview and special registration programs for Muslims and people of
Arab and South Asian descent. The ACLU has also prepared and distributed
a “Know Your Rights” brochure in English, Spanish, Arabic,
Urdu, Hindi, Punjabi, Farsi, and Somali to educate the public about the
rights of individuals during encounters with the police, the FBI, and
agents of the Department of Homeland Security.
The ACLU regularly holds public membership meetings at which a wide range
of civil liberties issues are discussed and debated. The ACLU also routinely
provides information to the public and the media through print and online
communications about the erosion of civil rights and civil liberties after
September 11, and encourages ACLU members and activists to oppose government
anti-terrorism policies that unnecessarily violate civil rights and civil
liberties.
The FBI has a history of surveillance of the ACLU. For example, declassified
documents, some released pursuant to previous FOIA requests, reveal that
the FBI engaged in extensive spying on the national ACLU and its growing
number of regional affiliates throughout the 1940s, 1950s and 1960s, generating
tens of thousands of pages of information.
Locally, the ACLU of Wisconsin has represented a number of individuals
critical of government policy in the war on terrorism. ACLU of Wisconsin
attorneys have represented anti-war demonstrators and individuals charged
with violating government bans on travel to Iraq and Cuba. The ACLU of
Wisconsin has also sought information on the operation of local Joint
Terrorism Task Forces through state open records act requests and has
encouraged communities to pass resolutions limiting local police involvement
in surveillance activities. The ACLU of Wisconsin has been visited by
FBI officials.
2. The Islamic Foundation of Greater Milwaukee, Inc., d/b/a the “Islamic
Society of Milwaukee,” operates the largest mosque in the Milwaukee
area. The Islamic Society is the largest Islamic organization in Wisconsin
and serves about 10,000 Muslims in the southeastern Wisconsin area. It
was originally incorporated as the Islamic Association of Greater Milwaukee
in 1976 and was reincorporated as the Islamic Foundation of Greater Milwaukee
in 1980. The organization has done business as the Islamic Society of
Milwaukee since 1986. The organization is a non-profit religious organization
operating a mosque for congregational prayer and the Salam School, a private
school for children in grades K-4 through 8th grade, as well as weekend
educational programs for children of the Islamic faith. The Islamic Society
has been visited by local FBI agents on numerous occasions. The FBI has
also contacted many attendees of the mosque individually.
3. The Wisconsin Coalition to Normalize Relations with Cuba (formerly
the Milwaukee Coalition to Normalize Relations with Cuba) was founded
in 1994. It consists of organizations and individuals who support the
normalization of relations with Cuba and increased person-to-person contact
between U.S. citizens and Cubans, and oppose policies that increase the
suffering of the Cuban people, including the ban on travel to Cuba, the
U.S. economic embargo on Cuba and policies that discourage other nations
from trading with Cuba. Several individual members have been prosecuted
for travel to Cuba. The organization and its members have hosted and maintained
contacts with Cuban church and government representatives. The organization
maintains an extensive email list and hosts frequent educational events
open to the public.
4. Peace Action-Wisconsin is a peace and justice organization that works
for a world in which human needs are met, the environment is preserved,
and the threats of war and nuclear weapons have been abolished. Peace
Action is committed to non-violence as a way of life and offers opportunities
for education, lobbying and public witness. Founded as Milwaukee Mobilization
for Survival in March of 1977, the organization was part of a network
of 44 national peace and justice groups organized around the issues of
nuclear weapons, nuclear power, the escalating arms race and the attendant
decline in funding for human needs. National Mobilization for Survival
grew to include over 125 peace and justice groups before its national
office closed in 1992. In January 1996, the Milwaukee group affiliated
with National Peace Action, which had been formed from the merger of SANE
and the Nuclear Freeze Campaign. It is the largest grassroots peace and
disarmament group in the country. In 1999, the organization became Peace
Action-Wisconsin, to reflect its statewide scope and membership. The ACLU
of Wisconsin has obtained, through state open records requests, copies
of "Daily Protest Reports," prepared by members of the Milwaukee
Police Department's "Intelligence Division." These reports record
surveillance of street protests, including surveillance of many protests
organized by Peace Action. Uniformed officers have videotaped and questioned
event organizers. Police officers in the Intelligence Division may also
be assigned to the Joint Terrorism Task Force. Peace Action has also organized
many of the protests when political leaders have come to southeastern
Wisconsin and been told by Milwaukee Police officials, with whom they
were negotiating protest locations and security, that the FBI and/or Secret
Service have ultimate authority over security perimeters and other aspects
of protest monitoring and control.
5. The Milwaukee Chapter of the National Lawyers Guild is affiliated with
the National Lawyers Guild, which was founded in 1937 and seeks to “unite
lawyers, law students, legal workers, and jailhouse lawyers of America
in an organization which shall function as an effective political and
social force in the service of the people, to the end that human rights
shall be regarded as more sacred than property interests.” The Milwaukee
Chapter has trained and provided legal observers for many protests and
coordinates a number of efforts, including a “Justice Watch”
program that helped organize protests when Justice Antonin Scalia spoke
at Marquette Law School and Chief Justice William Rehnquist received an
alumni award from Shorewood High School. A plainclothes U.S. Marshall
attended a planning meeting for the Rehnquist protest, which took place
in the spring of 2002.
6. George Martin is the Program Director for Peace Action Wisconsin. He
has been an active leader nationally in United for Peace and Justice,
the largest anti-war coalition in the country, and currently serves as
one of three national co-chairs for UPJ. He has spoken against the Iraq
war at home and abroad, including speaking engagements in Italy, at the
World Social Forum in Brazil and on a fact-finding mission in Iraq. His
name appears frequently in the Daily Protest Reports compiled by Milwaukee
police. A notarized statement from Mr. Martin authorizing release of the
requested information about him to the ACLU of Wisconsin Foundation and
providing identifying information is enclosed.
7. Arthur Heitzer is a civil rights attorney and long-time activist involved
in Peace Action (currently a steering committee member), the Wisconsin
Coalition to Normalize Relations with Cuba, the National Lawyers Guild
(he is both chair of NLG’s national Cuba Subcommittee and a leader
in the Milwaukee Chapter), and other organizations. In the late 1960s
and early 1970s, he ran a book store that was frequently visited by the
Milwaukee Police Department’s "red squad." A notarized
statement from Mr. Heitzer authorizing release of the requested information
about him to the ACLU of Wisconsin Foundation and providing identifying
information is enclosed.
8. Othman Atta is a Milwaukee attorney and president of the Islamic Society
of Milwaukee. He has had frequent contact with the FBI. He frequently
lectures on Islam, discrimination against Muslims and Middle East peace
and justice. Mr. Atta is also on the ACLU of Wisconsin’s Milwaukee
chapter board. A notarized statement from Mr. Atta authorizing release
of the requested information about him to the ACLU of Wisconsin Foundation
and providing identifying information is enclosed.
9. Stephen Watrous is a long-time Milwaukee activist. He is currently
active in Peace Action-Wisconsin. He is also a member of the steering
committee of the Milwaukee Coalition for a Just Peace, an organization
formed to oppose the military response to the terrorist attacks on New
York and Washington, D.C., in 2001. His name and intercepted emails from
him appeared in FBI files obtained by the ACLU of Colorado. His name appeared
in the FBI’s files in connection with 1999-2000 protests against
Kohl’s Department Stores by members of the Wisconsin Fair Trade
Campaign (now called the Wisconsin Fair Trade Coalition), of which Mr.
Watrous was a leader at the time. A notarized statement from Mr. Watrous
authorizing release of the requested information about him to the ACLU
of Wisconsin Foundation and providing identifying information is enclosed.
10. Karyn Rotker is a staff attorney at the ACLU of Wisconsin Foundation.
Ms. Rotker has been involved in protest activities in Madison and Milwaukee
for many years. She is an active member of the Milwaukee chapter of the
National Lawyers Guild. Her name also appeared in documents obtained by
the Colorado ACLU affiliate, again in connection with the Kohl's Department
Store protests. A notarized statement from Ms. Rotker authorizing release
of the requested information about her to the ACLU of Wisconsin Foundation
and providing identifying information is enclosed.
II. The Request for Information
The Requesters seek disclosure of any records created from January 1,
2000 to the present, that were prepared, received, transmitted, collected
and/or maintained by the FBI, the National Joint Terrorism Task Force,
or any Joint Terrorism Task Force relating or referring to the following:
1. Any records relating or referring to any Requester, including, but
not limited to, records that document any collection of information about,
monitoring, surveillance, observation, questioning, interrogation, investigation
and/or infiltration of the Requester or its activities;
2. Any orders, agreements, or instructions to collect information about,
monitor, conduct surveillance of, observe, question, interrogate, investigate,
and/or infiltrate any Requester;
3. Any records relating or referring to how, why or when any Requester
was selected for collection of information, monitoring, surveillance,
observation, questioning, interrogation, investigation, and/or infiltration;
4. Any records relating or referring to how collection of information
about, monitoring, surveillance, observation, questioning, interrogation,
investigation, and/or in filtration of any Requester was or will be conducted;
5. Any records relating or referring to the names of any other federal,
state, or local government agencies participating in any collection of
information about, monitoring, surveillance, observation, questioning,
interrogation, investigation and/or infiltration of any Requester;
6. Any records relating or referring to the specific role of the National
Joint Terrorism Task Force or any local Joint Terrorism Task Force in
any collection of information about, monitoring, surveillance, observation,
questioning, interrogation, investigation and/or infiltration of any Requester;
7. Any records relating or referring to the specific role of any federal,
state, or local government agency participating in any collection of information
about, monitoring, surveillance, observation, questioning, interrogation,
investigation, and/or infiltration of any Requester;
8. Any records relating or referring to how records about any Requester
have been, will be, or might be used;
9. Any policies or procedures for analyzing records about any Requester;
10. Any policies or procedures for cross-referencing records about any
Requester with information contained in any database;
11. Any policies or procedures for cross-referencing records about any
Requester with information about any other organizations or individuals;
12. Any policies or procedures for cross-referencing records about any
Requester with any other information not covered in numbers 10 and 11
above;
13. Any policies or procedures regarding retention of records about any
Requester;
14. Any records referring or relating to the destruction of records about
any Requester, including any policies permitting or prohibiting the destruction
of records;
15. Any records referring or relating to how records about any Requester
were destroyed or might be destroyed in the future;
16. Any records referring or relating to the recipient(s) of records about
any Requester;
17. Any policies or procedures in place to protect the privacy of records
that refer or relate to the employees, members, and/or board of directors
of any Requester;
18. Any records relating or referring to how, why or when collection of
information about, monitoring, surveillance, observation, questioning,
interrogation, investigation, and/or infiltration of any Requester was
or will be suspended or terminated.
III. Limitation of Processing Fees
The ACLU requests a limitation of processing fees pursuant to 5 U.S.C.
§ 552(a)(4)(A)(ii)(II) (“fees shall be limited to reasonable
standard charges for document duplication when records are not sought
for commercial use and the request is made by ... a representative of
the news media...”) and 28 C.F.R. §§ 16.11(c)(l)(i), 16.11(d)(l)
(search and review fees shall not be charged to “representatives
of the news media.”). As a “representative of the news media,”
the ACLU fits within this statutory and regulatory mandate. Fees associated
with the processing of this request should, therefore, be limited accordingly.
The ACLU meets the definition of a “representative of the news media”
because it is “an entity that gathers information of potential interest
to a segment of the public, uses its editorial skills to turn raw materials
into a distinct work, and distributes that work to an audience.”
National Security Archive v. Department of Defense, 880 F.2d 1381, 1387
(D.C. Cir, 1989).
The ACLU and ACLU of Wisconsin are dedicated to the defense of civil rights
and civil liberties. Dissemination of information to the public is a critical
and substantial component of the ACLU’s mission and work. Specifically,
the ACLU publishes newsletters, news briefings, right-to-know documents,
and other educational and informational materials that are broadly disseminated
to the public. Such material is widely available to everyone, including
individuals, tax-exempt organizations, not-for-profit groups, law students
and faculty, for no cost or for a nominal fee through its public education
department. The ACLU also disseminates information through its web sites:
http://www.aclu.org/ and http://www.aclu-wi.org. The web sites address
civil rights and civil liberties issues in depth, provide features on
civil rights and civil liberties issues in the news, and contain many
documents relating to the issues on which the ACLU is focused. The national
ACLU website specifically includes features on information obtained through
the FOIA. See, e.g., www.aclu.org/patriot_foia; www.aclu.org/torturefoia.
The ACLU also publishes an electronic newsletter, which is distributed
to subscribers by e-mail.
In addition to the national ACLU offices, there are 53 ACLU affiliate
and national chapter offices located throughout the United States and
Puerto Rico. These offices further disseminate ACLU material to local
residents, schools and organizations through a variety of means, including
their own websites, publications and newsletters. Further, the ACLU makes
archived material available at the American Civil Liberties Union Archives,
Public Policy Papers, Department of Rare Books and Special Collections,
Princeton University Library. ACLU publications are often disseminated
to relevant groups across the country, which then further distribute them
to their members or to other parties.
Depending on the results of the Request, the ACLU plans to “disseminate
the information” gathered by this Request “among the public”
through these kinds of publications in these kinds of channels. The ACLU
is therefore a “news media entity.” Cf. Electronic Privacy
Information Ctr. v. Department of Defense, 241 F.Supp. 2d 5, 10-15 (D.D.C.
2003) (finding non-profit public interest group that disseminated an electronic
newsletter and published books was a “representative of the media”
for purposes of FOIA).
Finally, disclosure is not in the ACLU’s commercial interest. The
ACLU is a “non-profit, non-partisan, public interest organization.”
See Judicial Watch Inc. v. Rossotti, 326 F.3d 1309, 1310 (D.C. Cir. 2003).
Any information disclosed by the ACLU as a result of this FOIA will be
available to the public at no cost.
IV. Waiver of all Costs
The ACLU additionally requests a waiver of all costs pursuant to 5 U.S.C.
§552(a)(4)(A)(iii) (“Documents shall be furnished without any
charge ... 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.”). Disclosure in this
case meets the statutory criteria, and a fee waiver would fulfill Congress’s
legislative intent in amending FOIA. See Judicial Watch, Inc. v. Rossotti,
326 F.3d 1309,1312 (D.C. Cir. 2003) (“Congress amended FOIA to ensure
that it be ‘liberally construed in favor of waivers for noncommercial
requesters.’”).
Disclosure of the requested information is in the public interest. This
request will further public understanding of government conduct; specifically,
the FBI’s monitoring, surveillance, and infiltration of organizations
on the basis of national origin, racial and/or ethnic background, religious
affiliation, organizational membership, political views or affiliation,
or participation in protest activities or demonstrations. This type of
government activity concretely affects many individuals and groups and
implicates basic privacy, free speech, and associational rights protected
by the Constitution.
Moreover, disclosure of the requested information will aid public understanding
of the implications of the Department of Justice’s recent decision
to relax guidelines that previously restricted the FBI’s ability
to spy on organizations without a threshold showing of suspected criminal
activity. These restrictions were created in response to the Hoover-era
FBI’s scandalous spying on politically active individuals and organizations,
despite the complete lack of evidence that such individuals and organizations
had been involved in any unlawful behavior. Understanding the current
scope of the FBI’s surveillance and infiltration of law-abiding
organizations is, therefore, crucial to the public’s interest in
understanding the consequences of the Department of Justice’s important
change in policy.
As a nonprofit § 501(c)(3) organization and “representative
of the news media” as discussed in Section III, the ACLU is well-situated
to disseminate information it gains from this request to the general public
as well as to immigrant, religious, politically active, and other targeted
communities, and to groups that protect constitutional rights. Because
the ACLU meets the test for a fee waiver, fees associated with responding
to FOIA requests are regularly waived for the ACLU.
The records requested are not sought for commercial use, and the Requester
plans to disseminate the information disclosed as a result of this FOIA
request through the channels described in Section III. As also stated
in Section III, the ACLU will make any information disclosed as a result
of this FOIA available to the public at no cost.
V. Expedited Processing Request
Expedited processing is warranted because there is “an urgency to
inform the public about an actual or alleged federal government activity”
by organizations “primarily engaged in disseminating information”
28 C.F.R. § 16.5(d)(l)(ii). This request implicates a matter of urgent
public concern; namely, the consequences of a recent change in government
policy that has likely resulted in increased surveillance and infiltration
of political, religious, and community organizations by the FBI. Such
government activity may infringe upon the public’s free speech,
free association, and privacy rights, which are guaranteed by the First,
Fourth, Fifth, and Fourteenth Amendments to the United States Constitution.
Requests for information bearing upon potential Constitutional violations
require an immediate response so that any violations cease, future violations
are prevented, and any chilling effect on public participation in potentially
targeted groups and/or political activity be halted.
In addition, this request deals with potential disparate treatment of
groups on the basis of categories such as religion, nationality and political
viewpoint. Such potential unequal treatment is a matter necessitating
immediate attention. There is also intense public concern, particularly
among potentially targeted groups, about the actual or alleged federal
government activity addressed by this request. This intense public concern
is illustrated by the selection of news coverage detailed in the paragraph
below.
A Requester may also demonstrate the need for expedited processing
by showing that the information sought relates to “a matter of widespread
and exceptional media interest in which there exist possible questions
about the government’s integrity which affect public confidence.”
28 C.F.R. § 16.5(d)(l)(iv). The instant request clearly meets these
standards as the request relates to possible violations of Constitutional
rights by federal law enforcement and potential targeting of groups by
federal law enforcement based on illicit categories of political viewpoint,
race, religion and nationality. The exceptional media interest in this
issue is reflected in widespread news coverage at both the local and national
level. See e.g., Dan Eggen, Coalition Seeks FBI’s Files on Protest
Groups, Washington Post, p. A3, December 3, 2004; Kevin Johnson, Anti-Terrorism
Methods Draw ACLU Scrutiny, USA Today, December 1, 2004; Daily Star Staff,
American Arabs Concerned Over FBI’s ‘October Plan,’
www.dailystar.com.Ib, October 6, 2004; David Shepardson, FBI Agents Hunt
for Terror Leads; Agency Combs Muslim Neighborhoods for Help in Preventing
Election Day Attack, The Detroit News, October 1, 2004; Eric Lichtblau,
Subpoena Seeks Records About Delegate Lists on Web, NY Times, August 30,
2004 at P10; Alex Bradley and John Mayer, The War at Home: Nationwide
Crackdown on Activists Part, www.saveourliberties.com, September 2, 2004;
Eric Lichtblau, Protestors at Heart of Debate on Security vs. Civil Rights,
NY Times, August 27, 2004 at A9; Larry Abramson, FBI Questioning Political
Demonstrators, NPR.org; Susan Greene, Activists Decry Pre-Convention Security
Tactics: Questions by FBI, The Feds Say They ‘re Trying to Avoid
Terror treats, But Many People Say the Steps Veer Toward Intimidation,
The Denver Post, August 26, 2004 at A-08; Eric Lichtblau, F.B.I. Goes
Knocking for Political Troublemakers, NY Times, August 16, 2004 at Al
; Amy Herder, Teaching the Silent Treatment, The Denver Post, August 8,
2004 at C-01; Jayashri Srikantiah, Few Benefits to Questioning Targeted
Groups, San Francisco Chronicle, August 6, 2004; Camille T. Taiara, New
F.B.I Witch-Hunt, San Francisco Bay Guardian, August 4-10, 2004; Kelly
Thornton, F.B.I.’s Home Visits Have Some Muslims Feeling Harassed,
Alienated, Signonsandiego.com, August 4, 2004; Richard Schmitt and Donna
Horowitz, FBI Starts to Question Muslims in U.S. About Possible Attacks,
latimes.com, July 18, 2004; Karen Abbott, FBI’s Queries Rattle Activist,
www.rockymountainnews.com, July 27, 2004; Mary Beth Sheridan, Interviews
of Muslims to Broaden, www.washingtonpost.com, July 17, 2004; Jeff Eckhoff
and Mark Siebert, Group Fights Anti-war Inquiry, The Des Moines Register,
February 7, 2004; Jeff Eckhoff and Mark Siebert, Anti-war Inquiry Unrelated
to Terror, The Des Moines Register, February 10, 2004 at 1A; Jeff Eckhoff
and Mark Siebert, Group Fights Anti-war Inquiry, The Des Moines Register,
February 7, 2004; Monica Davey, An Antiwar Forum in Iowa Brings Federal
Subpoenas, NY Times, February 10, 2004 at A14; Monica Davey, Subpoenas
on Anti-war Protest Are Dropped, NY Times, February 11, 2004 at Al 8;
Michelle Goldberg, A Thousand J. Edgar Hoovers, www.salon.com, February
12, 2004; Michelle Goldberg, Outlawing Dissent, www.salon.com, February
11, 2004; Kern Ginis, Peace Fresno Seeks Damages, The Fresno Bee, February
28, 2004; Eric Lichtblau, F.B.I. Scrutinizes Antiwar Rallies, www.nytimes.com,
November 23, 2003.
The potential targeting of individuals and groups by the federal government
on the basis of group membership, religion, political protest, nationality,
and other similar categories raises many questions about the government’s
integrity and affects public confidence in a profound way. The government’s
- and particularly the FBI’s - treatment of persons on the basis
of their political viewpoints is a critical issue with a long history
dating back to the founding of the nation. Questions about the government’s
integrity in these areas substantially affect the public’s confidence
in the government’s ability to protect all of its citizens, and
in law enforcement and the legal system. This issue has been of concern
to lawmakers, including members of the House of Representatives. See,
e.g., Eric Lichtblau, Inquiry into F.B.I. Question Is Sought, NY Times
A16, August 18, 2004.
Finally, pursuant to applicable regulations and statute, the ACLU expects
the determination of this request for expedited processing within 10 calendar
days and the determination of this request for documents within 20 days.
See 28 C.F.R. 16.5(d)(4); 5 U.S.C. § 552(a)(6)(A)(i).
If this request is denied, in whole or in part, we ask that you justify
all deletions by reference to specific exemptions to FOIA. The ACLU expects
the release of all segregable portions of otherwise exempt material. The
ACLU reserves the right to appeal a decision to withhold any information
or to deny
a waiver of fees.
Thank you for your prompt attention to this matter. Please furnish all
applicable records to:
Laurence J. Dupuis
Legal Director
American Civil Liberties Union of Wisconsin Foundation
207 E. Buffalo St., #325
Milwaukee, WI 53202
telephone: (414) 272-4032, ext. 12
facsimile: (414) 272-0182
I affirm that the information provided supporting the request for expedited
processing is true and correct to the best of my knowledge and belief.
Sincerely,
Laurence J. Dupuis
Legal Director
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