DOCSLIB.ORG

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Case 4:19-cv-00892-HSG Document 168-2 Filed 06/12/19 Page 1 of 142 1 DROR LADIN* NOOR ZAFAR* 2 JONATHAN HAFETZ* HINA SHAMSI* 3 OMAR C. JADWAT* AMERICAN CIVIL LIBERTIES UNION FOUNDATION 4 125 Broad Street, 18th Floor New York, NY 10004 5 Tel: (212) 549-2660 [email protected] 6 [email protected] [email protected] 7 [email protected] [email protected] 8 *Admitted pro hac vice 9 CECILLIA D. WANG (SBN 187782) AMERICAN CIVIL LIBERTIES UNION FOUNDATION 10 39 Drumm Street San Francisco, CA 94111 11 Tel: (415) 343-0770 [email protected] 12 Attorneys for Plaintiffs (Additional counsel listed on following page) 13 14 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 15 SAN FRANCISCO-OAKLAND DIVISION 16 SIERRA CLUB and SOUTHERN BORDER COMMUNITIES COALITION, Case No.: 4:19-cv-00892-HSG 17 Plaintiffs, 18 REQUEST FOR JUDICIAL NOTICE v. IN SUPPORT OF PLAINTIFFS’ 19 MOTION FOR PARTIAL SUMMARY DONALD J. TRUMP, President of the United JUDGMENT 20 States, in his official capacity; PATRICK M. SHANAHAN, Acting Secretary of Defense, in his Date: 21 official capacity; KEVIN K. MCALEENAN, Judge: Honorable Haywood S. Gilliam, Jr. Acting Secretary of Homeland Security, in his Dept: Oakland 22 official capacity; and STEVEN MNUCHIN, Date Filed: June 12, 2019 Secretary of the Treasury, in his official capacity, Trial Date: Not set 23 Defendants. 24 25 26 27 28 PLAINTIFFS’ REQUEST FOR JUDICIAL NOTICE ISO MOTION FOR PARTIAL SUMMARY JUDGMENT CASE NO: 4:19-cv-00892-HSG Case 4:19-cv-00892-HSG Document 168-2 Filed 06/12/19 Page 2 of 142 1 Additional counsel for Plaintiffs: 2 SANJAY NARAYAN (SBN 183227)** GLORIA D. SMITH (SBN 200824)** 3 SIERRA CLUB ENVIRONMENTAL LAW PROGRAM 2101 Webster Street, Suite 1300 4 Oakland, CA 94612 Tel: (415) 977-5772 5 [email protected] [email protected] 6 **Counsel for Plaintiff SIERRA CLUB 7 MOLLIE M. LEE (SBN 251404) CHRISTINE P. SUN (SBN 218701) 8 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF NORTHERN CALIFORNIA, INC. 9 39 Drumm Street San Francisco, CA 94111 10 Tel: (415) 621-2493 Fax: (415) 255-8437 11 [email protected] [email protected] 12 DAVID DONATTI* 13 ANDRE I. SEGURA (SBN 247681) AMERICAN CIVIL LIBERTIES UNION FOUNDATION 14 OF TEXAS P.O. Box 8306 15 Houston, TX 77288 Tel: (713) 325-7011 16 Fax: (713) 942-8966 [email protected] 17 [email protected] *Admitted pro hac vice 18 19 20 21 22 23 24 25 26 27 28 ii PLAINTIFFS’ REQUEST FOR JUDICIAL NOTICE ISO MOTION FOR PARTIAL SUMMARY JUDGMENT CASE NO: 4:19-cv-00892-HSG Case 4:19-cv-00892-HSG Document 168-2 Filed 06/12/19 Page 3 of 142 1 REQUEST FOR JUDICIAL NOTICE 2 Plaintiff Sierra Club and Plaintiff Southern Border Communities Coalition (together, 3 “Plaintiffs”) hereby respectfully request, pursuant to Federal Rule of Evidence 201, that the Court 4 take judicial notice of the following materials in support of Plaintiffs’ Motion for Partial Summary 5 Judgment. 6 1. Attached hereto as Exhibit 1 is a true and correct copy of an excerpt of the transcript of 7 a speech President Trump delivered when he announced his candidacy for president on June 16, 8 2015. 9 2. Attached hereto as Exhibit 2 is a true and correct copy of an excerpt of the Office of 10 Management and Budget’s “Budget of the U.S. Government for Fiscal Year 2018: A New 11 Foundation for American Greatness” (2017), available on the official White House website at 12 https://www.whitehouse.gov/wp-content/uploads/2017/11/budget.pdf. 13 3. Attached hereto as Exhibit 3 is a true and correct copy of an excerpt of The WALL Act 14 of 2018, S. 3713, 115th Cong. (2018). No action was taken on the bill after referral to the Senate 15 Committee on Finance. As of April 4, 2019, the complete text of the bill is posted on the United 16 States Congress’s official website, at https://www.congress.gov/115/bills/s3713/BILLS- 17 115s3713is.pdf; and the history of the bill is posted on Congress’s official website, at 18 https://www.congress.gov/bill/115th-congress/senate-bill/3713/all-actions 19 4. Attached hereto as Exhibit 4 is a true and correct copy of the 50 Votes for the Wall Act, 20 H.R. 7073, 115th Cong. (2018). No action was taken on the bill after referral to the House 21 Subcommittee on Border and Maritime Security. As of April 4, 2019, the complete text of the bill is 22 posted on the United States Congress’s official website, at https://www.congress.gov/115/bills/ 23 hr7073/BILLS-115hr7073ih.pdf; and the history of the bill is posted on Congress’s official website, 24 at https://www.congress.gov/bill/115th-congress/house-bill/7073/all-actions. 25 5. Attached hereto as Exhibit 5 is a true and correct copy of an excerpt of the Build the 26 Wall, Enforce the Law Act of 2018, H.R. 7059, 115th Cong. (2018). No action was taken on the bill 27 after referral to the House Subcommittee on Trade. As of April 4, 2019, the complete text of the bill 28 is posted on the United States Congress’s official website, at https://www.congress.gov/115/ 1 PLAINTIFFS’ REQUEST FOR JUDICIAL NOTICE ISO MOTION FOR PARTIAL SUMMARY JUDGMENT CASE NO: 4:19-cv-00892-HSG Case 4:19-cv-00892-HSG Document 168-2 Filed 06/12/19 Page 4 of 142 1 bills/hr7059/BILLS-115hr7059ih.pdf; and the history of the bill is posted on Congress’s official 2 website, at https://www.congress.gov/bill/115th-congress/house-bill/7059/all-actions. 3 6. Attached hereto as Exhibit 6 is a true and correct copy of an excerpt of the Fund and 4 Complete the Border Wall Act, H.R. 6657, 115th Cong. (2018). No action was taken on the bill 5 after referral to the House Subcommittee on Immigration and Border Security. As of April 4, 2019, 6 the complete text of the bill is posted on the United States Congress’s official website, at 7 https://www.congress.gov/115/bills/hr6657/BILLS-115hr6657ih.pdf; and the history of the bill is 8 posted on Congress’s official website, at https://www.congress.gov/bill/115th-congress/house- 9 bill/6657/all-actions. 10 7. Attached hereto as Exhibit 7 is a true and correct copy of an excerpt of the American 11 Border Act, H.R. 6415, 115th Cong. (2018). No action was taken on the bill after referral to the 12 House Subcommittee on Immigration and Border Security. As of April 4, 2019, the complete text 13 of the bill is posted on the United States Congress’s official website, at https://www.congress.gov/ 14 115/bills/hr6415/BILLS115hr6415ih.pdf; and the history of the bill is posted on Congress’s official 15 website, at https://www.congress.gov/bill/115th-congress/house-bill/6415/all-action. 16 8. Attached hereto as Exhibit 8 is a true and correct copy of an excerpt of the Border 17 Security and Immigration Reform Act of 2018, H.R. 6136, 115th Cong. (2018). On June 27, 2018, 18 this bill failed in the House of Representatives by a recorded vote of 121 – 301. As of April 4, 2019, 19 the complete text of the bill is posted on the United States Congress’s official website, at 20 https://www.congress.gov/115/bills/hr6136/BILLS-115hr6136ih.pdf; and the history of the bill is 21 posted on Congress’s official website, at https://www.congress.gov/bill/115th-congress/house- 22 bill/6136/all-actions. 23 9. Attached hereto as Exhibit 9 is a true and correct copy of an excerpt of the Securing 24 America’s Future Act of 2018, H.R. 4760, 115th Cong. (2018). On June 21, 2018, this bill failed in 25 the House of Representatives by a recorded vote of 193 – 231. As of April 4, 2019, the complete 26 text of the bill is posted on the United States Congress’s official website, at 27 https://www.congress.gov/115/bills/hr4760/BILLS115hr4760ih.pdf; and the history of the bill is 28 2 PLAINTIFFS’ REQUEST FOR JUDICIAL NOTICE ISO MOTION FOR PARTIAL SUMMARY JUDGMENT CASE NO: 4:19-cv-00892-HSG Case 4:19-cv-00892-HSG Document 168-2 Filed 06/12/19 Page 5 of 142 1 posted on Congress’s official website, at https://www.congress.gov/bill/115th-congress/house- 2 bill/4760/all-actions. 3 10. Attached hereto as Exhibit 10 is a true and correct copy of an excerpt from the Fiscal 4 Year 2019 White House Budget Request, dated February 2018, available on the official White 5 House website at https://www.whitehouse.gov/wp-content/uploads/2018/02/budget-fy2019.pdf. 6 11. Attached hereto as Exhibit 11 is a true and correct of a declaration signed by Paul 7 Arcangeli, Staff Director of the House Armed Services Committee, and filed as ECF No. 44-1 in 8 House v. Mnuchin, et al., Case No. 19-cv-969 (D.D.C. May 15, 2019). 9 12. Attached hereto as Exhibit 12 is a true and correct copy of an excerpted transcript of a 10 May 23, 2019 hearing in House v. Mnuchin, Case No. 19-cv-969 (D.D.C.). 11 13. Attached hereto as Exhibit 13 is a true and correct copy of a Letter from Acting Director 12 of the Office of Budget and Management Russell T.
Load more

Recommended publications
  • Innovative Federal Strategies,Llc
    INNOVATIVE FEDERAL STRATEGIES, LLC Comprehensive Government Relations MEMORANDUM To: SBVMWD Board of Directors – Policy Workshop From: Letitia White, Jean Denton, Drew Tatum, and Sarah Persichetti Date: June 30, 2021 Re: June Monthly Legislative Update Administration, Senators Announce Bipartisan Deal on Infrastructure President Biden on Thursday, June 24 announced he had reached an infrastructure deal with a group of Republican and Democratic senators, saying both sides gave up some things they wanted to get a rare accord in a bitterly divided Washington, D.C. Biden acknowledged the deal would not include proposals he has made for spending to help American families, but firmly endorsed the deal on infrastructure in unusual remarks just outside the White House with the bipartisan group of senators looking on. “We have a deal,” Biden told reporters. “I think it’s really important, we’ve all agreed that none of us got all that we wanted. I clearly didn’t get all I wanted. They gave more than I think maybe they were inclined to give in the first place,” he said. “But this reminds me of the days we used to get an awful lot done in the United States Congress, we actually worked with one another,” Biden said, putting his hand on Senator Rob Portman’s (R-OH) shoulder. “Bipartisan deal means compromise.” The agreement was reached after weeks of negotiations, and with progressive Democrats repeatedly calling on the White House to back away from the talks, which some liberals fear could prevent a much larger package from moving forward. Biden said he did intend to continue to look for a larger package on spending through a budget reconciliation measure, which would allow it to pass the Senate with just Democratic votes.
    [Show full text]
  • The Chief Management Officer of the Department of Defense: an Assessment
    DEFENSE BUSINESS BOARD Submitted to the Secretary of Defense The Chief Management Officer of the Department of Defense: An Assessment DBB FY 20-01 An assessment of the effectiveness, responsibilities, and authorities of the Chief Management Officer of the Department of Defense as required by §904 of the FY20 NDAA June 1, 2020 DBB FY20-01 CMO Assessment 1 Executive Summary Tasking and Task Force: The Fiscal Year (FY) 2020 National Defense Authorization Act (NDAA) (Public Law (Pub. L. 116-92) required the Secretary of Defense (SD) to conduct an independent assessment of the Chief Management Officer (CMO) with six specific areas to be evaluated. The Defense Business Board (DBB) was selected on February 3, 2020 to conduct the independent assessment, with Arnold Punaro and Atul Vashistha assigned to co-chair the effort. Two additional DBB board members comprised the task force: David Walker and David Van Slyke. These individuals more than meet the independence and competencies required by the NDAA. Approach: The DBB task force focused on the CMO office and the Department of Defense (DoD) business transformation activities since 2008 when the office was first established by the Congress as the Deputy Chief Management Officer (DCMO), and in 2018 when the Congress increased its statutory authority and elevated it to Executive Level (EX) II and the third ranking official in DoD. The taskforce reviewed all previous studies of DoD management and organizations going back twenty years and completed over ninety interviews, including current and former DoD, public and private sector leaders. The assessments of CMO effectiveness since 2008 are focused on the performance of the CMO as an organizational entity, and is not an appraisal of any administration or appointee.
    [Show full text]
  • Directory of Public Officials Outagamie County Wisconsin 2021 - 2022
    DIRECTORY OF PUBLIC OFFICIALS OUTAGAMIE COUNTY WISCONSIN 2021 - 2022 Outagamie County Government Center 320 South Walnut Street Appleton, Wisconsin 54911 Web: http://www.outagamie.org THOMAS NELSON County Executive JEFF NOOYEN Chairperson TRAVIS J. THYSSEN Vice Chairperson Compiled by the Office of the County Clerk JEFF KING County Clerk OFFICE HOURS 8:00 a.m. - 4:30 p.m. (Year-Round) (Check with individual offices for varied hours.) - Closed Saturdays - LEGAL HOLIDAYS New Year’s Day Good Friday Memorial Day th July 4 Labor Day Thanksgiving Day & the day after Christmas Eve Day Christmas Day New Year’s Eve Day If a holiday falls on a Sunday the succeeding Monday is the holiday. If a holiday falls on a Saturday the preceding Friday is the holiday. TABLE OF CONTENTS Courthouse Complex Directory .................................................78 Office Hours/ Legal Holidays ...................................................... 2 Federal Government .................................................................... 4 State Government ........................................................................ 6 Supreme Court of WI & Appeals Court, Dist. 3 .......................... 7 Legislative Officials .................................................................... 8 Tax Officials ............................................................................. 12 Div. of Community Corrections/Probation & Parole ................. 12 County Government .................................................................. 12 Judicial Department
    [Show full text]
  • IN the SENATE of the UNITED STATES Sitting As a Court of Impeachment in Re IMPEACHMENT of PRESIDENT DONALD J. TRUMP TRIAL MEMORA
    IN THE SENATE OF THE UNITED STATES Sitting as a Court of Impeachment In re IMPEACHMENT OF PRESIDENT DONALD J. TRUMP TRIAL MEMORANDUM OF THE UNITED STATES HOUSE OF REPRESENTATIVES IN THE IMPEACHMENT TRIAL OF PRESIDENT DONALD J. TRUMP United States House of Representatives Adam B. Schiff Jerrold Nadler Zoe Lofgren Hakeem S. Jeffries Val Butler Demings Jason Crow Sylvia R. Garcia U.S. House of Representatives Managers TABLE OF CONTENTS INTRODUCTION ........................................................................................................................................... 1 BACKGROUND .............................................................................................................................................. 9 I. CONSTITUTIONAL GROUNDS FOR PRESIDENTIAL IMPEACHMENT .................................................... 9 II. THE HOUSE’S IMPEACHMENT OF PRESIDENT DONALD J. TRUMP AND PRESENTATION OF THIS MATTER TO THE SENATE .............................................................................................................. 12 ARGUMENT ................................................................................................................................................... 16 I. THE SENATE SHOULD CONVICT PRESIDENT TRUMP OF ABUSE OF POWER .................................. 16 A. President Trump Exercised His Official Power to Pressure Ukraine into Aiding His Reelection ...................................................................................................................................
    [Show full text]
  • Unions Credit NOAA Leadership for Efforts During Pandemic Officials from Three Maritime Unions the Officials Continued, “It Has Been a Recently Wrote to U.S
    VolumeVolumeVolume 12 1 • 1 ISSUE • ISSUE 21 1 FebruaryApril-JuneFebruary 20212012 2012 Unions Credit NOAA Leadership for Efforts During Pandemic Officials from three maritime unions The officials continued, “It has been a recently wrote to U.S. Secretary of Com- time of unprecedented challenge within merce Gina Raimondo to give credit the maritime industry. Senior NOAA where it’s due. leadership demonstrated ingenuity and SIU Vice President Government Ser- real concern for their employees in ad- vices Kate Hunt, MM&P Representative dressing the many difficult situations Randi Ciszewski and MEBA Represen- which arose over the past year. Through- tative Jack Menendez signed off on the out it all, NOAA worked with the mari- letter, which credits the “admirable and time labor Unions representing the dedicated work performed by the lead- NOAA crews and kept us advised and up ership of NOAA’s Office of Marine & to date on all efforts. Those efforts con- Aviation Operations (OMAO) in assuring tinue today as we all work together to get the health and safety of crew members the crews vaccinated and move on suc- working aboard NOAA’s fleet of sur- cessfully with NOAA’s many important vey, oceanographic research and fisheries missions.” vessels during the Covid-19 pandemic.” The letter concluded, “We are very ap- (The Department of Commerce oversees preciative of this true Labor/Management SIU Government Services Division members sail aboard numerous NOAA vessels in- cluding the Pisces, shown in a file photo taken in Pascagoula, Mississippi. NOAA.) Partnership!” Urgent Push to Advance, Enact Vital PRO Act Continues Nationwide Demands for passage of the Protecting the Right to along party lines.
    [Show full text]
  • Congressional Record United States Th of America PROCEEDINGS and DEBATES of the 113 CONGRESS, SECOND SESSION
    E PL UR UM IB N U U S Congressional Record United States th of America PROCEEDINGS AND DEBATES OF THE 113 CONGRESS, SECOND SESSION Vol. 160 WASHINGTON, THURSDAY, MAY 1, 2014 No. 64 House of Representatives The House met at 9 a.m. and was ANNOUNCEMENT BY THE SPEAKER about 50 million people, 13 million who called to order by the Speaker. The SPEAKER. The Chair will enter- are children, living below poverty in f tain up to five requests for 1-minute the greatest country in the world. We speeches on each side of the aisle. know we must expand economic oppor- PRAYER tunity to have a strong middle class, The Chaplain, the Reverend Patrick f who are the backbone of this great J. Conroy, offered the following prayer: GENTRY FIRE DEPARTMENT 100TH country. We know that getting every Eternal God, through Whom we see ANNIVERSARY American working will add to not only who we are and what we can become, our tax base, but also reduce the deficit thank You for giving us another day. (Mr. WOMACK asked and was given and debt and eliminate poverty. Send Your spirit upon the Members permission to address the House for 1 So the question is, Madam Speaker, of this people’s House to encourage minute.) why aren’t we doing it? Where are the them in their official tasks. Be with Mr. WOMACK. Mr. Speaker, I rise in visionaries? Where is the President’s them and with all who labor here to celebration of the Gentry Arkansas American Jobs Act of 2013 or the 21st serve this great Nation and its people.
    [Show full text]
  • House Leadership Pitches Shalanda Young for OMB Director
    https://www.rollcall.com/2021/03/03/house-leadership-pitches-young-for-omb-director/ House leadership pitches Shalanda Young for OMB director Support for former House Appropriations aide grows after Neera Tanden's nomination was pulled By Jennifer Shutt Posted March 3, 2021 at 12:14pm The top three House Democrats on Wednesday urged President Joe Biden to nominate Shalanda Young as his budget director. Young, a longtime Democratic aide on the House Appropriations Committee, won praise from Republican and Democratic Senate Budget members during her confirmation hearing on Tuesday for the No. 2 slot at the Office of Management and Budget. And the top job at OMB is officially open now that Neera Tanden is out of the running. Young's “legislative prowess, extensive knowledge of federal agencies, incisive strategic mind and proven track record will be a tremendous asset to the Biden-Harris Administration," Speaker Nancy Pelosi, Majority Leader Steny H. Hoyer and Majority Whip James E. Clyburn said in a joint statement. Young's name has come up frequently in connection with the top job at OMB, with calls growing louder after the White House pulled Tanden's nomination on Tuesday night. Tanden, who runs the left-leaning Center for American Progress, withdrew herself from consideration after running into resistance from virtually all Senate Republicans and at least one Democrat, West Virginia's Joe Manchin III. Young, who was the top Democratic aide on Appropriations since 2017 and a staffer on the panel since 2007, would be the first Black woman to lead OMB. Pelosi, Hoyer and Clyburn said in their statement that her leadership at the OMB "would be historic and would send a strong message that this Administration is eager to work in close coordination with Members of Congress to craft budgets that meet the challenges of our time and can secure broad, bipartisan support." Young is scheduled to testify before the Senate Homeland Security and Governmental Affairs Committee on Thursday.
    [Show full text]
  • Key Officials September 1947–July 2021
    Department of Defense Key Officials September 1947–July 2021 Historical Office Office of the Secretary of Defense Contents Introduction 1 I. Current Department of Defense Key Officials 2 II. Secretaries of Defense 5 III. Deputy Secretaries of Defense 11 IV. Secretaries of the Military Departments 17 V. Under Secretaries and Deputy Under Secretaries of Defense 28 Research and Engineering .................................................28 Acquisition and Sustainment ..............................................30 Policy ..................................................................34 Comptroller/Chief Financial Officer ........................................37 Personnel and Readiness ..................................................40 Intelligence and Security ..................................................42 VI. Specified Officials 45 Cost Assessment and Program Evaluation ...................................45 General Counsel of the Department of Defense ..............................47 Inspector General of the Department of Defense .............................48 VII. Assistant Secretaries of Defense 50 Acquisition ..............................................................50 Health Affairs ...........................................................50 Homeland Defense and Global Security .....................................52 Indo-Pacific Security Affairs ...............................................53 International Security Affairs ..............................................54 Legislative Affairs ........................................................56
    [Show full text]
  • Reagan National Defense Forum Peace Through Strength in an Era of Competition
    REAGAN NATIONAL DEFENSE FORUM PEACE THROUGH STRENGTH IN AN ERA OF COMPETITION NOVEMBER 30 - DECEMBER 1, 2018 THE RONALD REAGAN PRESIDENTIAL LIBRARY SIMI VALLEY, CALIFORNIA Confirmed Speakers and Guests Subject to change Mr. John D. Heubusch Mr. Gordon Lubold Senator Jeanne Shaheen Ms. Kathy Warden The Honorable James N. Mattis Executive Director, The Ronald Reagan National Security and Pentagon Reporter, The Wall Street Journal U.S. Senate, New Hampshire President and COO, Northrop Grumman Corporation Presidential Foundation and Institute U.S. Secretary of Defense Mr. Palmer Luckey Ms. Barbara Starr The Rt. Honourable Gavin Williamson CBE MP The Honorable Kathleen Hicks Founder, Anduril Industries Pentagon Correspondent, CNN Minister of Defence for the United Kingdom SVP; Henry A. Kissinger Chair; Congressman Don Bacon Mr. Jonathan Cheng Director, Int'l Security Program, Center for Strategic & Int'l Studies The Honorable Susan R. McCaw Congresswoman Elise Stefanik The Honorable Heather Wilson U.S. House of Representatives, Nebraska Seoul Bureau Chief, The Wall Street Journal Former U.S. Ambassador to the Republic of Austria; U.S. House of Representatives, New York Secretary of the Air Force Mr. Raanan I. Horowitz Board Member, The Ronald Reagan Presidential Foundation and Institute; Mr. Bret Baier Mr. Eric Chewning President and CEO,Elbit Systems of America LLC President, COM Investments The Honorable Andrea L. Thompson Congressman Joe Wilson Chief Political Anchor, Fox News Deputy Assistant Secretary of Defense, Industrial Policy Under Secretary of State for Arms Control and International Security U.S. House of Representatives, South Carolina The Honorable Jeh Johnson Congressman Paul Mitchell Congressman Jim Banks Congressman Jim Cooper Former U.S.
    [Show full text]
  • January 7, 2020 VIA EMAIL U.S. Department of Defense OSD/JS
    January 7, 2020 VIA EMAIL U.S. Department of Defense OSD/JS FOIA Requester Service Center Office of Freedom of Information 1155 Defense Pentagon Washington, DC 20301-1155 whs.mc-alex.esd.mbx.osd-js-foia-requester-service-center@mail.mil Re: Expedited Freedom of Information Act Request Dear FOIA Officer: Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. § 552, and the implementing regulations of your agency, American Oversight makes the following request for records. On January 2, 2020, the United States carried out a military strike in Iraq that killed Qasem Soleimani, commander of the Iranian Islamic Revolutionary Guard Corps Quds Force.1 The targeting of one of Iran’s most senior officials immediately ratcheted up tensions with Iran, and subsequent U.S. actions—such as President Trump’s threats to target Iranian cultural sites—suggest no efforts to deescalate.2 American Oversight seeks records with the potential to shed light on the administration’s extraordinarily weighty decisions regarding military action against Iran. 1 Mustafa Salim et al., In Major Escalation, American Strike Kills Top Iranian Commander in Baghdad, WASH. POST (Jan. 3, 2020, 3:02 AM), https://www.washingtonpost.com/world/national-security/defense-secretary-says-iran- and-its-proxies-may-be-planning-fresh-attacks-on-us-personnel-in- iraq/2020/01/02/53b63f00-2d89-11ea-bcb3-ac6482c4a92f_story.html. 2 Seung Min Kim & Philip Rucker, Trump Threatens to Strike Iranian Cultural Sites and Impose ‘Very Big’ Sanctions on Iraq as Tensions Rise, WASH. POST (Jan. 5, 2020, 10:47 PM), https://www.washingtonpost.com/politics/trumps-threats-against-iranian-sites-raise- questions-about-the-potential-for-war-crimes/2020/01/05/c03d8de8-2ff2-11ea-898f- eb846b7e9feb_story.html.
    [Show full text]
  • In the United States District Court for the Western District of Louisiana
    Case 2:21-cv-01074 Document 1 Filed 04/22/21 Page 1 of 57 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF LOUISIANA THE STATE OF LOUISIANA, By and through its Attorney General, JEFF LANDRY; THE STATE OF ALABAMA, By and through its Attorney General, STEVE MARSHALL; THE STATE OF FLORIDA, CIVIL ACTION NO. _______________ By and through its Attorney General, ASHLEY MOODY; THE STATE OF GEORGIA, By and through its Attorney General, CHRISTOPHER M. CARR; THE COMMONWEALTH OF KENTUCKY, By and through its Attorney General, DANIEL CAMERON; THE STATE OF MISSISSIPPI, By and through its Attorney General, LYNN FITCH; THE STATE OF SOUTH DAKOTA, By and through its Governor, KRISTI NOEM; THE STATE OF TEXAS, By and through its Attorney General, KEN PAXTON; THE STATE OF WEST VIRGINIA, By and through its Attorney General, PATRICK MORRISEY; THE STATE OF WYOMING, By and through its Attorney General, BRIDGET HILL, PLAINTIFFS, v. Case 2:21-cv-01074 Document 1 Filed 04/22/21 Page 2 of 57 PageID #: 2 JOSEPH R. BIDEN, JR. in his official capacity as President of the United States; CECILIA ROUSE, in her official capacity as Chairwoman of the Council of Economic Advisers; SHALANDA YOUNG, in her official capacity as Acting Director of the Office of Management and Budget; KEI KOIZUMI, in his official capacity as Acting Director of the Office of Science and Technology Policy; JANET YELLEN, in her official Capacity as Secretary of the Treasury; DEB HAALAND, in her official capacity as Secretary of the Interior; TOM VILSACK, in his official capacity as Secretary of Agriculture; GINA RAIMONDO, in her official capacity as Secretary of Commerce; XAVIER BECERRA, in his official capacity as Secretary of Health and Human Services; PETE BUTTIGIEG, in his official capacity as Secretary of Transportation; JENNIFER GRANHOLM, in her official capacity as Secretary of Energy; BRENDA MALLORY, in her official capacity as Chairwoman of the Council on Environmental Quality; MICHAEL S.
    [Show full text]
  • Biden Cabinet Candidates and Senior White House Positions 4835-4287-3297 V.4.Xlsx
    Nominated/Appointed Favored Department Name Description Rep. Cheri Bustos Congresswoman from Illinois; former member of East Moline, Ill. City Council Rep. Marcia Fudge Congresswoman from Ohio; former mayor of Warrensville Heights, Ohio Krysta Harden Former Deputy Agriculture Secretary Senior Fellow in International and Public Affairs at Brown University’s Watson Institute; former senator from North Dakota; former North Dakota attorney Heidi Heitkamp general Amy Klobuchar Minnesota senator; former prosecutor in Minneapolis and candidate for the Democratic nomination AGRICULTURE Kathleen Merrigan Former deputy Agriculture Secretary Collin Peterson Representative from Minnesota and House Agriculture Committee Chairman Chellie Pingree Representative from Maine Karen Ross Former Chief of Staff to Obama Secretary of Agriculture Michael Scuse Delaware Agriculture Secretary Tom Vilsack Former Iowa governor who served as agriculture secretary for Mr. Obama Xavier Becerra California attorney general; former California congressman and state Assembly member Preet Bharara Former US Attorney for the Southern District of NY Merrick Garland Federal appeals court judge Jeh Johnson Former Obama Homeland Security Secretary ATTORNEY GENERAL/ Doug Jones Alabama senator; former U.S. attorney for the Northern District of Alabama JUSTICE Lisa Monaco Former chief counterterrorism and homeland security advisor to Obama Deval Patrick Former Massachusetts Governor Tom Perez Chair of the Democratic National Committee; former secretary of Labor; former assistant attorney general for civil rights Sally Yates Partner, King and Spalding; former acting attorney general and deputy attorney general; former U.S. attorney in the Northern District of Georgia CIA David Cohen Former Deputy CIA Director CLIMATE ENVOY John Kerry Former Secretary of State Jared Bernstein Biden Economic Advisor Heather Boushey Economist Rep.
    [Show full text]