\

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

--------------------------------------------------------------------)(
SHAWN MUSGRAVE,

NOTICE OF PETITION
Petitioner,
-againstNEW YORK CITY POLICE DEPARTMENT, and
THE CITY OF NEW YORK,
Respondents.

--------------------------------------------------------------------)(

PLEASE TAKE NOTICE that upon the affirmation of Gillian Cassell-Stiga of

Rankin & Taylor, PLLC, sworn to on November

lJ_, 2014, and the attached exhibits, the

undersigned petitioner will request this Court, at 9:30 in the forenoon on the

day of

located at 60 Centre Street, New York, New York, in the Motion Support Courtroom, IAS Part
Room 130, for an Order and Judgment grariting the following relief to the undersigned
petitioner:

2.

Ordering the respondents pay the reasonable litigation costs

fees pursuant to Public Officers Law Article 6 89(4)c; and

3.

Other such relief as the Court finds just and proper.

. Dated:

ID1<:tl8'1118f.t~Mri~i~...

New York, New York

.J

November

l ~, 2014
Respectfully submitted,

illian Cassell-Stiga
Rankin & Taylor, PLLC
11 Park Place, Suite 914
New York, New York 10007
t: 212-226-4507
f: 212-658-9480
e: gillian@drmtlaw.com
To:
New York City Police Department
One Police Plaza, Room 1406
New York, New York 10038
The City of New York
100 Church Street
New York, New York 10007
Supreme Court, State of New York
County of New York
Motion Submission Term, Room 130
60 Centre Street
New York, New York 10007

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

---------------------------------~----------------------------------){
SHAWN MUSGRAVE,
Petitioner,
-againstNEW YORK CITY POLICE DEPARTMENT, and
THE CITY OF NEW YORK,

VERIFIED PETITION PURSUANT

TO ARTICLE 78 OF THE NEW
YORK PRACTICE LAW AND
RULES
'
J
IndexNo. ~-----f

Respondents.

--------------------------------------------------------------------){
I, GILLIAN CASSELL-STIGA, an attorney duly licensed to practice law in the Courts of
the State of New York, does hereby verify and affirm, under the penalties of perjury, that the
following is true and accurate:
PRELIMINARY STATEMENT

1.

Pursuant to the Freedom of Information Law ("FOIL") and Article 78 of the New

York Civil Law and Rules, the undersigned, petitioner Shawn Musgrave ("Mr. Musgrave"),
seeks an order directing respondents New York City Police Department ("NYPD") and The City
of New York ("CITY") to disclose all NYPD documents and correspondence concerning
remotely piloted aircraft, unmanned aerials, unmanned aerial vehicles, and/or unmanned aerial
systems.
2.

Since respondent NYPD has steadfastly refused to respond to the Mr. Musgrave's

FOIL request, and since Mr. Musgrave has exhausted all available administrative remedies, the
Mr. Musgrave respectfully requests the Court order respondents to produce the documents
sought in the Request.

BACKGROUND
3.

On June 9, 2014, Mr. Musgrave sent a FOIL request to the FOIL Unit within the

NYPD. See Request from Shawn Musgrave dated June 9, 2014 to the NYPD FOIL Unit,
attached hereto as Exhibit A.
4.

The Request sought disclosure of memorandum, e-mails, correspondence, and

other documents or records related to agency use of aerial drones, remotely piloted vehicles
(RPVs), remotely piloted aircraft (RPAs), unmanned aerials (UAs), unmanned aerial vehicles
(UAVs), and/or unmanned aerial systems (UASs) (hereinafter "drones") from January, 2005
unto the present. This Request includes, but is not limited to, documents concerning or related to
the policy, acquisition, use, and training of personnel. See Request, Exhibit A, at 1-5.
5.

June 24th, 2014, Mr. Musgrave received a letter from the NYPD Records Access

Officer Lieutenant Richard Mantellino ("Office Mantellino") acknowledging the receipt of his
request, assigning it file nun1ber LBF #14PL105084, and informing him further review would be
required and a response estimated in the next 20 days. See Acknowledgment from Officer
Mantellino dated June 24th, 2014, attached hereto as Exhibit B.
6.

July 18, 2014, Mr. Musgrave then received a letter from Officer Mantellino

informing him the request was denied. See Letter Denial from Officer Mantellino dated July 18,
2014, attached hereto as Exhibit C.

The letter stated that Mr. Musgrave could appeal the

decision in writing within 30 days of the date of the letter. See Letter Denial, Exhibit C.
7.

August 5, 2014, In compliance with the NYPD's internal procedures, Mr.

Musgrave sent a letter to Jonathan David, Records Access Appeals Officer for NYPD,

administratively appealing the denial and requesting the production of the documents sought. See
Administrative Appeal to respondent NYPD dated August 5, 2014, attached hereto as Exhibit D.
8.

August 22, 2014, Mr. Musgrave received a letter from Officer David stating that

his appeal was denied.

See Appeal Denial from Officer David dated September 19, 2014,

attached hereto as Exhibit E.

9.

Respondent NYPD

should have made a determination regarding the

Administrative Appeal within 10 business days of receipt by the agency. See 34 R.C.N.Y. 106(d). Further, the NYPD's blanket denial of Mr. Musgrave's request sweepingly claims the
applicability of exemptions without providing a justification of the required specificity.
10.

The NYPD has failed to provide a single document in response to Mr. Musgrave' s

request.
JURISDICTION AND VENUE
11.

This proceeding pursuant to Article 78 of the Civil Practice Law and Rules is the

proper mechanism for seeking judicial review of a state agency's determination with respect to a
FOIL request. N.Y. Pub. Off. 89(4)(b).
12.

Respondent NYPD is a state agency subject to the FOIL. It is also an agency of

respondent CITY.
13.

The undersigned has exhausted respondent NYPD's internal appeals process, and

the instant petition has been filed within the four-month period thereafter specified in C.P .L.R.

217(1). See su:gra ifif 3-10.

14.

Both respondents NYPD and CITY have their central offices located in the

County ofNew York. Venue therefore is proper in this Court. C.P.L.R. 7804(a), 506(b).

BASIS FOR RELIEF

15.

When a State or municipal agency makes a determination which is arbitrary and

capricious, the aggrieved party may challenge that determination in

an Article 78 petition.

C.P.L.R. 7803(3).
16.

In rejecting both the original request and Mr. Musgrave's appeal, the NYPD has

failed to provide an "articulation of a particularized and specific justification for denying access"
as required to establish the applicability of an exemption, instead merely reciting the statutory
phrasing of the exemption. Capital Newspapers Div. of Hearst Corp. v. Burns, 67 N.Y.2d 562
(N.Y. 1986); DJL Restaurant Corp. v. Department of Bldgs., 273 A.D.2d 167 (N.Y. App. Div.
1st Dep't 2000) ("affidavits merely repeating the statutory phrasing of an exemption are
insufficient to establish the requirement of particularity").
17.

Where the good faith invocation of the statue is called into question, the court

should make an in camera inspection of the requested documents. City ofNewarkv. Law Dep't of

NY., 305 A.D.2d 28 (N. Y. App. Div. 1st Dep't 2003).

REQUEST FOR RELIEF

WHEREFORE, the undersigned petitioner respectfully requests this Court enter
an Order either directing respondent NYPD to disclose all documents within the scope of the
Request or directing respondent NYPD to submit for in camera inspection copies of all
documents within the scope of the Request, for determination by the Court as to the propriety of
exempting or disclosing saine under the FOIL; awarding the undersigned his legal fees and

expenses incurred in making the instant petition for relief; and awarding such other and further
relief as the Court may deem just and proper.
Dated:

New York, 1-f~Y' York

November J..j, 2014
Respectfully submitted,

Giiran Cassell-Stiga
Rankin & Taylor, PLLC
11 Park Place, Suite 914
New York, New York 10007
t: 212-226-4507
f: 212-658-9480
e: gillian@drmtlaw.com
To:
New York City Police Department
One Police Plaza, Room 1406
New York, New York 10038
The City of New York
100 Church Street
New York, New York 10007
Supreme Court, State of New York
County of New York
Motion Submission Term, Room 130
60 Centre Street
New York, New York 10007

ATTORNEY'S VERIFICATION
I, Gillian Cassell-Stiga, an attorney duly admitted to practice before the Courts of the
State of New York, affirm the following to be true under the penalties of perjury:
I am the attorney of record for the Petitioner.
I have read the annexed Petition and know the contents thereof, and the same are true to my
knowledge, except those matters therein which are stated to be alleged upon information and
belief, and as to those matters I believe them to be true. My beliefs, as to those matters therein
not stated upon knowledge, are based upon facts, records, and other pertinent information

contained in my files.
This verification is made by me because Petitioner does not reside in the county where I
maintain my offices.

Dated:

New York, New York

November / 201.4

q,

Records Access Officer

NYC Police Department
F.0.1.L. Unit - Legal Bureau
One Police Plaza, Room 110-C
New York, New York I 0038

June 9, 2014
To Whom It May Concern:
Pursuant to the New York State Freedom of lnfonnation Law ( 1977 N. Y. Laws ch. 933), J hereby request the
following records:
All documents created from January 2005 to the date this request is processed related to the agency's use of aerial
drones, remotely piloted vehicles (RPVs), remotely piloted aircraft (RPAs), unmanned aerials (UAs), unmanned
aerial vehicles (UAVs), and/or unmanned aerial systems (UASs)(hereinafter "drones").
Please note that this is the third time we have submitted a FOIL request for this type of documentation (see 20 I3PL-100448 and 20 I 3-PL-7978). Previously, the NYPD FOIL Unit has invoked "personal privacy" as well as
disclosure of law enforcement techniques to justify rejections. However, the NYPD's recent statements to the City
Council's Public Safety Committee eliminate both considerations: the Commissioner very publicly confirmed that
the department is researching drones, and Deputy Commissioner Miller indicaK'<l that NYPD officers were looking
into "what's on the market, what's available."
A December 20 l 0 email from a detective in the Counterterrorism Division to the FAA (first reported in August
2011:
) indicated that as of that time, the department
was "in the basic stages of investigating the possible use of UAV's as a law enforcement tool."
Please search specifically for the below document categories, and respond to each of the categories and items:
I) Acquisition documents:
i) requests for proposals (RFPs), proposals/quotes submitted by vendors, contracts, leases, budget requests, project/
equipment budgets, cost allocations or reimbursements for the purchase of drone equipment;
ii) Grant applications and award letters for drone equipment purchases;
iii) Insurance contracts for all drone equipment;
iv) Communications (including electronic communications) between the agency head or agency quartennaster (or
individual responsible for equipment purchases and maintenance) and drone vendors, manufacturers or retailers;
v) Communications (including electronic communications) between the agency head and agency quartermaster (or
individual responsible for equipment purchases and maintenance) regarding acquisition, lease or use of drone
equipment;
vi) Communications (including electronic communications) between the agency head and the governor, mayor and
city/town manager regarding the acquisition of drones;

vii) Applications (including all components and support documentation) for Certificates of Waiver/Authorization
(COA) from the Federal Aviation Administration, as well as COA grant notifications and final agreement;
viii) Contracts for services related to drones, such as data storage, data analysis, image storage, image analysis,
video storage, video analysis, operation, maintenance;
2) Equipment logs:
i) lnventories/logs/lists/databases of all drones owned, leased or operated hy or for the agency;

ii) Maintenance logs for all drones owned, leased or otherwise operated by or for the agency;

3) Policy documents:
i) Policies, guidelines, protocols, manuals and/or instructions on the use/operation of drones and usage of data,
images and video obtained from drone flights;
ii) Communications from the agency head, quartennaster (or individual responsible for overseeing equipment
purchases and maintenance) on approved uses for drones;
iii) Memorandums of understanding (MOUs), memorandums of agreement (MO As) or any other agreements or
contracts with other government agencies, private corporations, organizations or individuals to share drone
equipment, data, images or video or to operate drones on behalf of the agency;

4) Training documents:
i) Curriculum used to train drone operators and observers;
ii) Training log for all drone operators and observers;
iii) Certifications of training completion for all drone operators and observers;
iv) Contracts, purchase orders, budget requests or reimbursement orders for training sessions for all drone operators
and observers;

5) Usage documents:
i) Flight logs for all drone flights, including training flights;
ii) Flight logs transmitted to the Federal Aviation Administration pursuant to Certificate of Waiver/Authorization
(COA) requirements;
iii) Reprimands relating to drones, including misuse of equipment and failure to properly maintain equipment.

I also request that, if appropriate, fees be waived as l believe this request is in the public interest. 111e requested
documents will be made available to the general public free of charge as part of the public infonnation service at
MuckRock.com, processed by a representative of the news media/press and is made in the process of news gathering
and not for commercial usage.
In the event that fees cannot be waived, l would be grateful if you would infom1 me of the total charges in advance
of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CDROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to
this request within 5 business days, as the statute requires.
Sincerely,
Shawn Musgrave

Filed via MuekRock.eom

E-mail (Preferred): 11991
For mailed responses, please address (see note):
MuckRock News
DEPT MR 11991
PO Box 55819
Boston, MA 02205-5819
PLEASE NOTE the new address as well as the fact that improperly addressed (i.e., with the requester's name rather
than MuckRock News) requests might be returned by the USPS as undelivernble.

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Room I IOC
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)(g).

Jonathan David
Records Access Appeals Officer
New York City Police Department
One Police Plaza - Room 1406
New York., NY I 0038-1497

August 5, 2014

Mr. David,
This is an appeal for the blanket rejection of FOIL l4PLl05084.
Despite the NYPD FOIL Unit's now third assertion, at bare minimum a portion of the requested documents are
squarely within the public domain. The remaining justifications for denying the request are irrelevant, lack factual
grounding and are asserted without substantiation.
Foremost, that I have submitted related FOIL requests in the past has no bearing on the present request for material,
particularly given that the current request incorporates additional information regarding the department's research
into unmanned aerial vehicles. In particular, I cited the Commissioner's recent statements before the City Council's
Public Safety Committee, with which the Commissioner confirmed that the NYPD is investigating UAVs for
department use. This additional guiding information clearly sets this request as distinct from previous requests.
Furthermore, the NYPD's justification for rejecting my request has evolved substantially with each subsequent
request. Beginning with a puzzling determination that "personal privacy" barred releasing documents in response to
my first request, the NYPD has rejected my previous two requests on highly suspect grounds, and does so again in
response to my latest request. The appeal determination for my second appeal was grounded foremost in my failure
to file a timely appeal for the first request, rather than on substantive issues. The NYPD FOIL Unit cannot invoke
irrelevant justifications for denying requests.
Similar logical inconsistencies and assertions without justification are at play in this latest request. The foremost
justification for appeal is that this request is "duplicative" of my previous two requests. Given the additional
information, passage of time and procedural issues in filing my first request, this foremost grounds for denial is
utterly irrelevant in the present FOIL request.
Next, Lt. Mantellino relies on the appeal determination for l3PL107978, which again was errantly grounded
primarily in the denial of my first appeal, which was due to procedural rather than substantive concerns.
Next, the request denial indicates that releasing documents would reveal non-routine techniques. As asserted
previously, Mayor Bloomberg and now two NYPD Commissioners have publicly disclosed details of the
department's investigation into unmanned aerial vehicle technology. There is thus very thin justification to assert that
all documents must be withheld in the interest of protecting non-routine information.
Lt. Mantellino asserts without support that disclosing these records might "endanger the life or safety of persons in
New York City." Dozens of other law enforcement agencies across the country have released documents related to
their use of or research into UAVs. This includes federal agencies such as the Bureau of Customs and Border
Protection and the FBI that have already deployed UAVs in operations. The assertion that releasing documents
might endanger safety or lives requires substantial backing and evidence that Lt. Mantellino has utterly failed to
provide.

Finally, the rejection letter indicates that some of the documents constitute "intra-agency materials comprised of
preliminary information and/or assessments that are deliberative and pre-decisional in nature." While this may be
true for portions of the documents, the Mayor and two NYPD Commissioners have publicly stated the department's
intention to pursue UAV technology. This decision has squarely been taken. While some documents may comprise
pre-decisional materials, there is much that would feasibly not fall within this category.
In light of the above, I respectfully insist that this FOIL request be remanded back to the NYPD FOIL Unit for
substantive response and release of responsive documents.
Best,
Shawn Musgrave
MuckRock

POLICE DEPARTMENT
LEGAL BUREAU
F.0.1.L. Unit, Room 11 OC
One Police Plaza
New York, New York 10038

July 18, 2014

Shawn Musgrave
MuckRock News
DEPT MR 7109
P.O. Box 55819
Boston. MA 0220.5
RE:

FREEDOM OF INFORMATION LA\V

REQUEST: LSF #14PLl05084

Dear Mr. Musgrave:

This letter is in further response to your letter dated June 9, 2014, requesting disclosure,
pursuant to the Freedom of Information Law ("FOIL"), of various records related to unmanned
aerial vehicles.

That part of your request covering the time frame from January, 2005 to October 22,
2013 is denied because your instant request is duplicative of your prior requests that were

assigned file numbers 13PL100448 and 13PLI07978.

In addition, your request is denied in its entirety for the reasons that were set forth in the
February 7, 2014 final determination of your appeal under file number 13PL107978, and for the
reasons stated hclow.
Your request is denied under Puhlic Officers I.aw (POL) Section 87(2)(e)(iv), which
exempts from disclosure law cnfon.:erncnt records that re\eal non-routine investigati\c
tcclrniqw.:s or procedures. This exemption applies to lav. enforcement records that descrihc the
workings of noYcl systems that could be used to address public saJcty emergencies. inciuding
possible terrorist attacks and criminal ads. Accordingly. the disclosure you seek. were it to be
made. would enahlc miscreants to tailor their conduct in anticipation of law enforn;ment efforts
to prc\ent criminal activities. and would therefore not be required under FOIL as to any records
that may be in cxistem:e.
In addition. the request is denied under POL Section X7(2)(f) because the disclosure you
seek could endanger thc lit\: or sakty of pt.:rsons in New York ( 'ity.

\1oremer. the request is denied to the extent that responsive records. i r in existence.
would constitute intra-agency materials comprised of preliminary information andior
assessments that are dcliberatin: and pn.:-decisiona! in nature. Accordingly. disclosure is not .
requin..:d pursuant lo POL Section S7{2)(g).

You may appeal this decision in writing, within thirty (30) days of the date of this
letter. Any appeal should he addressed to Mr. Jonathan David, Records Access Appeals
Officer, NYPD, One Police Plaza, Room 1406, New York, NY 10038-1497.
/\

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Richar~ntcllino

Lieutenant
Records Access Officer

On July 22, 2014:

Lt. Mantellino I hereby once again assert my right to receive FOIL responses by electronic mail, rather than by postal mail.
Per 89(3)(b), which states that "All entities shall, provided such entity has reasonable means available, accept
requests for records submitted in the form ofclectronic mail and shall respond to such requests by electronic mail...
to the extent practicable ... .''. this is a legal obligation for NYPD to comply with my request.
Please confirm that responses for this request will be sent by electronic mail.
-Shawn

On July 22, 2014:

Lt. Mantellino Per the attached, NYPD was slated to respond to issue a determination for this request by July 18, 2014. To date, no
such response has been received. Please advise.
Best,
Shawn

On July 19, 2014:

The request has been rejected, with the agency stating that the information or document(s) requested are exempt
from disclosure.

On July 15, 2014:

A letter stating that the request appeal has been rejected.

On July 3, 2014:
Jonathan David
Records Access Appeals Officer
New York City Police Department
One Police Plaza - Room 1406
New York, NY 10038-1497

July 3, 2014

Mr. David:
Under the provisions of the New York Freedom oflnformation Law, Article 6 89(4)(a) of the Public Officers Law, I
hereby request an internal appeal of your failure to respond to my FOIL request dated June 9, 2014. A copy of my

request is attached, along with a letter showing your office received the attached request on June l 6, 2014. The
FOIL Unit did not respond or acknowledge the attached request within the five (5) business days as required by
statute, therefore, the request has been constructively denied and an internal appeal is appropriate.
Please notify me of the results of the appeal without delay.
If for any reason any portion of my request is again denied, please inform me of the reasons for the denial in writing
within the ten (10) days as required by statute.
Sincerely,

Shawn Musgrave
MuckRock

Attachments

On June 24, 2014:

To Whom It May Concern:
I wanted to follow up on the following Freedom of Information request, copied below, and originally submitted on
June 9, 2014. Please let me know when 1 can expect to receive a response, or if further clarification is needed.
Thank you for your help.

On June 24, 2014:

An acknowledgement letter, stating the request is being processed.

On June 9, 2014:
To Whom It May Concern:
Pursuant to the New York State Freedom of Information Law (l 977 N.Y. Laws ch. 933), I hereby request the
following records:
All documents created from January 2005 to the date this request is processed related to the agency's use of aerial
drones, remotely piloted vehicles (RPVs), remotely piloted aircraft (RPAs), unmanned aerials (UAs), unmanned
aerial vehicles (UAVs), and/or unmanned aerial systems (UASs)(hereinafter "drones").
Please note that this is the third time we have submitted a FOIL request for this type of documentation (see 2013PL-l 00448 and 20 I 3-PL-7978). Previously, the NYPD FOIL Unit has invoked "personal privacy" as well as
disclosure of law enforcement technjques to justify rejections. However, the NYPD's recent statements to the City
Council's Public Safety Committee eliminate both considerations: the Commissioner very publicly confirmed that
the department is researching drones, and Deputy Commissioner Miller indicated that NYPD officers were looking
into "what's on the market, what's available."
A December 2010 email from a detective in the Counterterrorism Division to the FAA (first reported in August
2011:
) indicated that as of that time, the department
was "in the basic stages of investigating the possible use ofUAV's as a law enforcement tool."

Please search specifically for the below document categories, and respond to each of the categories and items:
I) Acquisition documents:
i) requests for proposals (RFPs), proposals/quotes submitted by vendors, contracts, leases, budget requests, project/
equipment budgets, cost allocations or reimbursements for the purchase of drone equipment;
ii) Grant applications and award letters for drone equipment purchases;
iii) Insurance contracts for all drone equipment;
iv) Communications (including electronic communications) between the agency head or agency quartermaster (or
individual responsible for equipment purchases and maintenance) and drone vendors, manufacturers or retailers;
v) Communications (including electronic communications) between the agency head and agency quartermaster (or
individual responsible for equipment purchases and maintenance) regarding acquisition, lease or use of drone
equipment;
vi) Communications (including electronic communications) between the agency head and the governor, mayor and
city/town manager regarding the acquisition of drones;
vii) Applications (including all components and support documentation) for Certificates of Waiver/Authorization
(COA) from the Federal Aviation Administration, as well as COA grant notifications and final agreement;
viii) Contracts for services related to drones, such as data storage, data analysis, image storage, image analysis,
video storage, video analysis, operation, maintenance;
2) Equipment logs:
i) Inventories/logs/lists/databases of all drones owned, leased or operated by or for the agency;
ii) Maintenance logs for all drones owned, leased or otherwise operated by or for the agency;
3) Policy documents:
i) Policies, guidelines, protocols, manuals and/or instructions on the use/operation of drones and usage of data,
images and video obtained from drone flights;
ii) Communications from the agency head, quartermaster (or individual responsible for overseeing equipment
purchases and maintenance) on approved uses for drones;
iii) Memorandums of understanding {MOUs), memorandums of agreement (MOAs) or any other agreements or
contracts with other government agencies, private corporations, organizations or individuals to share drone
equipment, data, images or video or to operate drones on behalf of the agency;

4) Training documents:
i) Curriculum used to train drone operators and observers;
ii) Training log for all drone operators and observers;
iii) Certifications of training completion for all drone operators and observers;

iv) Contracts, purchase orders, budget requests or reimbursement orders for training sessions for all drone operators
and observers;
5) Usage documents:
i) Flight logs for all drone flights, including training flights;

ii) Flight logs transmitted to the Federal Aviation Administration pursuant to Certificate of Waiver/Authorization
(COA) requirements;
iii) Reprimands relating to drones, including misuse of equipment and failure to properly maintain equipment
I also request that, if appropriate, fees be waived as I believe this request is in the public interest. The requested
documents will be made available to the general public free of charge as part of the public information service at
MuckRock.com, processed by a representative of the news media/press and is made in the process of news gathering
and not for commercial usage.

In the event that fees cannot be waived, I would be grateful if you would inform me of the total charges in advance
of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CDROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to
this request within 5 business days, as the statute requires.
Sincerely,
Shawn Musgrave
Filed via MuckRock.com
E-mail (Preferred): 11991
For mailed responses, please address (see note):
MuckRock News
DEPT MR 11991
PO Box 55819
Boston, MA 02205-5819
PLEASE NOTE the new address as well as the fact that improperly addressed (i.e., with the requester's name rather
than MuckRock News) requests might be returned by the USPS as undeliverable.

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