FOIA Page

Christian Patriot
777 Patriot Way, ,
Mellow Woods, Ca 94063,

IN PRO SE

                                  SUPERIOR COURT OF CALIFORNIA
                                  COUNTY OF MELLOW WOOD

_____________________
                Christian Patriot,
                                                                                           Case No.: _______
     Plaintiff/Petitioner,                                        }

                  v
________________________
              California Department
                    of Consumer
                  Affairs, Kat Hamm

    Defendant/Respondent

                                                                     VERIFIED COMPLAINT AND PETITION                                                                                             FOR DECLARATORY AND
                                                                                            INJUNCTION RELIEF AND
                                                                                            ALTERNATIVE WRIT OF MANDATE
                                                                                            UNDER THE CALIFORNIA PUBLIC                                                                                             RECORDS ACT.

[C.C.P. § 1085; Gov't Code § 6250, et seq]

To the above Court:

Plaintiff/Petitioner Christian Patriot, brings this Verified Complaint for a declaratory judgment, and a temporary, preliminary and permanent injunction order and,
alternatively, petitions this Court, pursuant to California Code of Civil Procedure Section 1085 et seq. and the California Public Records Act (Government
Code Section 6250 et seq.), for a writ of mandate directed to Defendants/Respondents Department of Consumer Affairs commanding them to obey the California Public Records Act ("CPRA"), and alleges as
follows:

JURISDICTION AND VENUE

1. The relief sought by the Plaintiff/Petitioner is authorized by Government Code (GOV.) Sections 6258 and 6259 and California Code of Civil Procedure (C.C.P.)
Section 1085. The Plaintiff/Petitioner is a natural born citizen of the state of California and a consumer residing in Mellow Woods, California, and,
therefore, that venue in Mellow County is appropriate.

THE PARTIES

2. Plaintiff/Petitioner Christian Patriot is a natural person and at all times mentioned herein was a resident of San Mateo County, California. Plaintiff/Petitioner is a "person" authorized to bring this action under the California Public Records Act,
GOV. § 6252(c).

3. Defendant/Respondent Department of Consumer Affairs (DCA) is, and at all times mentioned herein, was an agency of the California government, which is an
agency in charge of promoting and protecting the interests of the people as consumers, and is a "state agency" within the meaning of GOV. §6252(a).

4. Defendant/Respondent Kat Hamm is at all times mentioned herein was the Director of the California Department of Consumer Affairs.

5. Plaintiff/Petitioner is ignorant of the true names and capacities of defendants sued herein as Does 1 -20, inclusive, and therefore sues these defendants by such fictitious names. Plaintiff will amend this complaint to allege their true names and capacities when these are ascertained. Plaintiff is informed and believes and thereon alleges that each of the fictitiously named defendants is responsible in some manner for the occurrences herein alleged, and that plaintiffs damages as herein alleged were proximately caused by the conduct of such fictitiously named defendants.

FACTS GIVING RISE TO CLAIMS

5. Plaintiff/Petitioner has reason to believe that Defendant/Respondent state agency DCA maintains the records of oaths or affirmations of allegiance of public employees for which the DCA is the appointing power. Pursuant to GOV. §3101, all public employees, including those of state agencies, are disaster service workers. Pursuant to GOV. §3102(a), all disaster service workers shall, before they enter upon the duties of their employment, take and subscribe to the oath or affirmation. Pursuant to GOV. §3104, the oath or affirmation of any disaster service worker may be taken before his appointing power or before any person authorized in writing by his appointing power. Pursuant to Business and Professions Code §306, the Director of DCA, in accordance with the State Civil Service Act, may appoint and fix the compensation of such clerical or other personnel as may be necessary
to carry out the provisions of this chapter, and all such personnel shall perform their respective duties under the supervision and the direction of the director of DCA. Pursuant to GOV. §18153 The State Personnel Board shall prepare and furnish printed forms of the oath. According to the Oath of Allegiance forms prescribed by the State Personnel Board, the oath is to be filed in the official employee file.

6. On February 15, 2003, Plaintiff/Petitioner completed and mailed with proof of service by means of the United States Postal Service a written request to Defendant/Respondent DCA to receive copies of the following public records:

a. Notarized oaths of office of the staff members of the California Chiropractor Board who have been employed in that office in the period of January 1,
2000 to the present, including but not limited to:

Jan Bledge, staff member of the Chiropractor Board;
Christie Dobbins, staff member of the Board; Chiropractor

b. Plaintiff/Petitioner also requested to receive a copy of the notarized oath of office of

James Praclet, Senior Investigator, Department of Consumer Affairs;
Kat Hamm, Director of the Department of Consumer Affairs.
(A true and correct copy of the letter is lodged concurrently with the Verified Petition/Complaint as Exhibit A).

7. Plaintiff/Petitioner’s request reasonably described the aforementioned records and was made in accordance with the DCA’s Policy and Procedure – Guidelines for Access to Public Records, Policy No. LGL 02-01 issued on May 1, 2002.

8. Defendant/Respondent DCA had maintained these records at the agency office in Sacramento, California.

9. The information contained in the aforementioned records is not personal or confidential.

10. On March 13, 2003, on having not received any response from the Defendant/Respondent agency 26 days after the original request, Plaintiff/Petitioner
completed and mailed with proof of service by means of the United States Postal Service Express Mail No. ET700936674US a written follow-up request to the
Defendant/Respondent agency to receive copies of the above named records. The Plaintiff/Petitioner included a notice of intent to seek relief from the court if no
response from DCA was forthcoming in 5 days. (A true and correct copy of the letter is lodged concurrently with the Verified Petition/Complaint as Exhibit B).

10. To date, Plaintiff/Petitioner has received no response from DCA to his public records request.

11. Plaintiff/Petitioner was at all times mentioned ready to tender fees and costs for locating, duplicating and reviewing the documents and information requested, and so stated in his original request for the public records. (see Exhibit A)

FIRST CAUSE OF ACTION
Writ of Mandate

12. Plaintiff/Petitioner incorporates paragraphs 1 through 11, inclusive, as if fully set forth herein.

13. Plaintiff/Petitioner has a clear, present and beneficial interest in Defendants/ Respondents' compliance with the Public Records Act, GOV. § 6250 et
seq., enforceable through this action under GOV. §§ 6258 and 6259. Plaintiff/Petitioner has no other plain, speedy or adequate remedy in the normal course of law. As a result of Defendants/Respondents' refusal
to release the aforementioned reports, the Plaintiff/Petitioner sustained and will continue to be denied access to information regarding matters of fundamental public interest concerning the requirement of public employees’ oath of allegiance.

14. By the acts set forth the Plaintiff/Petitioner has exhausted its administrative remedies in this matter, and has fulfilled all preconditions to filing this Verified Complaint and Petition.

15. Defendants/Respondents have a clear, present and ministerial duty to provide copies of the requested oaths of allegiance. Failure to do so is an abuse of
discretion correctable by issuance of a writ of mandate from this Court or, in the alternative, by issuance of an order from this Court granting Plaintiff's/Petitioner's request for injunctive relief. Defendants/Respondents have abused their discretion in responding to the Plaintiff's/Petitioner's Public Records Act request by failing to promptly provide copies of the oaths of allegiance as specified in GOV. § 6252.

SECOND CAUSE OF ACTION
Declaratory Relief

16. Plaintiff/Petitioner hereby incorporates paragraphs 1 through 11 inclusive, as if fully set forth herein.

17. An actual controversy exists between the Plaintiff/Petitioner and DCA in that the Plaintiff/Petitioner contends that the copies of oaths requested are public records which must be promptly released to the Plaintiff/Petitioner. DCA has
repeatedly ignored the Plaintiff/Petitioner’s Public Records Act requests for access to these public documents. Therefore, the Plaintiff/Petitioner and the public are, and will continue to be, unable to obtain access to the public records sought due to
Defendants/Respondents' acts. Accordingly, the Plaintiff/Petitioner is entitled to an order pursuant to GOV. § 6258 declaring the records sought are subject to disclosure pursuant to the Public Records Act.

18. The Plaintiff/Petitioner has incurred, and will incur, attorneys' fees in pursing in this Court, the relief sought.

19. The Plaintiff/Petitioner alleges that the access to copies of oaths of allegiance of public employees is of substantial interest and benefit to the public. The Plaintiff/Petitioner further alleges that it is, therefore, entitled to recover its attorneys' fees and other litigation costs, pursuant to GOV. § 6259.

WHEREFORE, Plaintiff/Petitioner prays for:

1. An Order requiring DCA to show cause, if any, why it should not be enjoined as hereinafter set forth during the pendency of this action;

2. A temporary, preliminary and permanent injunction compelling Defendants/Respondents, and each of them and their agents, servants, and employees, and all persons acting under, in concert with, or for defendants to provide Plaintiff/Petitioner with copies of the aforementioned records on payment of a fee covering the costs to DCA of providing such copies;

3. Alternatively, that this Court issue an alternative writ of mandate commanding DCA to provide copies of the aforementioned records requested by the
Plaintiff/Petitioner, or to show cause before this Court at a time specified by Court order why it should not be done and why a peremptory writ should not issue;

4. On the return of the alternative writ and hearing on the order to show cause, a peremptory writ of mandate should issue under seal of this Court compelling DCA to immediately provide copies to all public records sought by the Plaintiff/Petitioner.

5. For a declaration that the aforementioned records are subject to disclosure under the Public Records Act [GOV. § 6253] and that disclosure is not prohibited
under the public interest exemption [GOV. § 6255].

6. For attorneys' fees and costs in this action according to proof pursuant to GOV. § 6259;

7. That this Court grant such other relief as may be just and proper.

VERIFICATION
I verify under penalties of perjury that the facts alleged in the foregoing complaint are true and correct to the best of my information, knowledge
and/or belief.

Dated: _______________

_____________________
Christian Patriot

STATE OF SOUTH CAROLINA ) COURT OF COMMON PLEAS FOR
COUNTY OF AIKEN
                                                              )       THE SECOND JUDICIAL CIRCUIT
                                                              )
REBEKAH E. SUTHERLAND            )

                                                              )

              Plaintiff,
                                                               )                      CIVIL ACTION

                                                                )                     FILE NO: 00-CP02-702

CITY OF AIKEN, SC and )
MR. ADMINISTRATOR and
BRAITH SMITH, P.A.


Defendant

COMPLAINT

COME NOW. Sutherland files her Complaint in the above- referenced case and respectfully shows this Court the following:

1. Plaintiff Sutherland is a South Carolina citizen and resident.

2. Plaintiff Gary H. Smith, III, is an individual citizen and resident of the State of South Carolina. He is an attorney for the City of Aiken, working out of the Braith Smith, P.A. office.

3. The City of Aiken, South Carolina, Administrative office is run by the appointed City Administrator, Mr LeDuck. It is a public body under the South Carolina Freedom of Information Act, S.C. Code Ann. Section 30-4-10 et seq., and is subject to the jurisdiction and venue of this Court pursuant to S.C. Code Ann. Section 30-4-20 (a) and Section 30-4-100, and may be served with summons, process and copy of this Complaint upon Roger LeDuck, Manager, at 214 Park
Avenue, S.W., Aiken, South Carolina 29801.
4. Jurisdiction and venue are proper in this Court.

5. Part of Defendant's responsibilities are to respond to Freedom of Information Requests sent to the City of Aiken.

6. Pursuant to the South Carolina Freedom of Information Act, S.C. Code Ann. Section 30-4-10 et seq., any person has a right to inspect and copy any public record of a public body, such as Defendant, unless such records are specifically
prohibited by law from being open to the public, in accordance with reasonable rules concerning the time and place of access.

7. On July 6, 1999, Sutherland requested that the Defendant release all documents known as invoices which record the cost accrued by the City of Aiken to post billboards around the City of Aiken promoting the "Character First" program and displaying the required character trait for each month from the date of its inception.

8. By letter dated July 6, 1999, . Sutherland requested a written request under both the state and federal Freedom of Information Act to request the public record described in the preceding paragraph on Defendant. A true and correct copy of that request is attached hereto as Exhibit "A".

9. Defendant is in control of the above-described requested documents with access to the public City of Aiken Offices in which these documents are public records under South Carolina law.

10. In response to the above-described requests by Sutherland, Defendant arbitrarily, wrongfully, illegally, and repeatedly refused to release thee
above described and requested public records and has failed to release any
documents or portions of any documents related to or constituting any grievance report to the Plaintiff.

11. On July 16, 1999, a written response was sent on behalf of
Defendant to the Plaintiffs, saying that the research for the FOIA letter had been
fulfilled by the city staff; however, the information was never placed into the envelope which was mailed to the Plaintiff. It is noted that in the letter, the omission of the word "Enclosures" indicates there never intent to send any information to the Plaintiff. A true and correct copy of this response is attached hereto as Exhibit "B".

12. On July 18, 1999, the Plaintiff sent a response back to the Defendant to notify him that the information was missing from the envelope, and that the FOIA request remained active, awaiting reply. A true and correct copy of this response is attached hereto as Exhibit "C".

13. On July 20, 1999 again a written response was sent to the Plaintiff in which the Defendant erroneously denies any participation of the City of Aiken in the Character First program. He stated the program was developed by the Mayor Cavanaugh, and that the City of Aiken had not spent money on the program. A true and certified copy of this response is attached hereto as Exhibit "D".

14. The Plaintiff had in her possession a copy of the City of Aiken Minutes dated March 8, 1999 in which the Aiken City Council voted to participate in the Character First program. The minutes state: "The City of Aiken will be the first city within South Carolina developing this program . . . " A copy of the minutes as given to the Plaintiff by the City secretary is attached hereto as Exhibit "E".

15. On August 6, 1999, a written response arrived from the Defendant stating, ". . . the City has expended funds to support the `Character First' resolution and the goals adopted by City Council . . ." However, the requested information about the cost of the Character First billboards was omitted for the third time. A true and certified copy of this response is attached hereto as Exhibit "F".

16. The above-described and requested documents are public records of a public body under South Carolina law, are not prohibited from disclosure by order of any court, and are not specifically exempted by law from being open to the public for inspection and, accordingly, must be made available for inspection and copying by the general public and to the Plaintiffs by Defendant.

17. The City of Aiken violated the FOIA in a previous instance; and therefore, has a record of noncompliance with the FOIA. The Aiken City Council Minutes dated July 14, 1997 (pages 379, 385, and 386) reveal that a local newspaper had to use the Court to access public records from the Public Safety Office. Gary Smith was the City Attorney who handled the case. A copy of these minutes are attached hereto as Exhibit "G".

18. The Defendant was responsible for responding to the 1997 FOIA request and to the Plaintiff's request in 1999 on behalf of the City of Aiken.

19. Based upon the facts set forth above, this Court should enter an order, declaring that the above-described documents are public records under South Carolina law and that such records should be made available to the public for inspection and copying as provided by law.

COUNT II
20. The allegations of paragraphs one (1) through seventeen (18) are incorporated by reference as if fully and specifically set out herein.

21. The Plaintiffs, a citizen of the City of Aiken and the State of South Carolina has no adequate remedy at law, and require an injunction to obtain access to the above-described public records, and will be irreparably harmed and denied their right of oversight over the government as provided by South Carolina law, unless an injunction, compelling the release of the above-described public records, is issued.

COUNT III

22. The allegations of paragraphs on (1) through (19) above are incorporated as if fully and specifically set out herein.

23. The Plaintiff is a person seeking injunctive relief in this case, and if she prevails in this case, in whole or, in part, she should be awarded her reasonable legal fees and costs of litigation pursuant to S.C. Code Ann. Section 30- 4-100.

24. Based upon the facts set forth above, this Court should enter an order awarding the Plaintiff her legal fees and other litigation expenses incurred in this
case pursuant to S.C. Code Ann. Section 30-4-100.

25. Based upon the facts set forth above, this Court should consider punitive measures to stop the repeated abuses of the Freedom of Information Act by the City of Aiken, its administrators, and its attorneys.

WHEREFORE, the Plaintiff respectfully prays to this Court for the following:
a. That this Court issue an order declaring that the above described documents are public records under South Carolina law and that such records should be made available for inspection and copying to the Plaintiffs as provided by law;

b. That this Court issue an injunction compelling Defendant to perform its official duty by permitting the Plaintiffs to inspect and copy the above-described public records as provided by law;

c. That this Court order Defendant to pay the Plaintiff her reasonable attorney fees other litigation expenses incurred in pursuing this case pursuant to S.C. Code Ann. Section 30-4-100;

d. That this Court set down at the earliest possible time a hearing on the matters set forth in this Complaint; and

e. For all other and further relief that this Court deems just and proper.

Respectfully submitted, this 23rd day of June, 2000.
Sutherland,
Holder in
Due Course
Sui Juris

Top

FEDERAL RESERVE SUED BY NATIONALLY KNOWN CONSTITUTIONALIST

Robert Clarkson, an Anderson, South Carolina Constitutional advocate, has filed a Freedom of Information Act (FOIA) lawsuit in U.S. District Court in Washington, DC against the Federal Reserve System; the Governor and Board of Governors of the Federal Reserve; and Federal Reserve Banks in Richmond and Atlanta. The lawsuit is intended to force the Fed and its branches to reveal certain documents under the FOIA. The FOIA, Title 5 United States Code 552, requires Federal agencies to produce all documents requested in writing under the FOIA. Clarkson made a number of written requests for documents. Federal Reserve officials refused his requests because they claimed the Fed is not a federal agency.

Documents Clarkson has requested include:
a) a list of stockholders of the Federal Reserve broken down by race, creed and national citizenship;
b) account of the Fed's donations to political parties and candidates;
c) copy of the audit of the Fed;
d) minutes of meetings of the Open Market Committee; authorization to issue Federal Reserve Notes;
f) documents on losses from foreign currency transactions. Clarkson said in a prepared statement: "The purpose of this lawsuit is to expose the Federal Reserve and bring public attention to the fact that the Federal Reserve Bank is a private institution making vast profits for its private owners.

We will ask the Federal Courts to decide whether the Fed is covered by the FOIA law and thereby an agency of the U.S. Government. We expect to lose on that issue, though."

Robert Clarkson is a graduate of Clemson University in Economics (1969) and of University of South Carolina Law School (1974). He served in Vietnam in 1970-71 with the 25th Infantry Division, 22nd Infantry Regiment. He is a recognized authority on the Federal Reserve and the Freedom of Information Act/Privacy Act. Clarkson has filed many prior FOIA-PA lawsuits and is currently suing the Air Force under the FOIA for their records of their own outrageous political activities.

The Lawsuit

FREEDOM OF SPEECH DEFENSE COMMITTEE PRESS RELEASE
WHITE HOUSE SUED FOR ILLEGAL DOCUMENT.

The White House Counsel--Executive office of the President was sued under the Freedom of Information Act (FOIA) in U.S. District Court in Greenville, S.C. by longtime conservative activist Attorney Robert B. Clarkson.

The FOIA request and lawsuit seeks all records and documents of the White House Counsel office which show legal work by taxpayer-paid attorneys and their staff for benefit of Hillary Rodham Clinton, a private citizen, and President William Clinton for non-official legal work.

Clarkson only seeks evidence of use of public funds, lawyers and their resources being used to represent and defend Mrs. Rodham-Clinton, a non-government employee and President Clinton for private unofficial representation for various investigations including that known as Whitewater, private law suits or Paula Jones case, investigation by Independent counsel Kenneth Starr.

Clarkson specifically states he did not request and does not want any documents dealing with official government or presidential business or lawful governmental activity.

Pursuant to a subpoena enforcement case by Independent Counsel Starr, the U.S. Supreme Court and the Eighth Circuit Court of Appeals ruled in May and June of 1997 that these records were public documents and are not protected by any privilege because Mrs. Rodham-Clinton is a private individual.

Dr. Robert B. Clarkson is a graduate from Clemson University 1969, served in Vietnam with the 25th Infantry Division and graduated from U.S.C. law school in 1974. Clarkson is the founder and leader of the Carolina Patriots, a tax reform organization, editor of The Patriot Cannon, and publisher or Clarkson's Offshore Banking News. He has filed dozens of previous FOIA and Privacy Act lawsuits.

Clarkson was recently quoted as saying, "The Clintons' use of government attorneys, their staffs and supplies in private legal matters is a clear misuse of taxpayers' funds. Clinton a Vietnam-era draft dodger, is accustomed to dodging the law but sooner or later he must account for his actions."

The FOIA law is a frequently used "Private Attorney General" law, less charitably known as a "Federal Bounty Hunter" law, to help enforce federal laws and collect expenses, attorney fees, etc.

__________See Lawsuit below__________________

Complaint for Declaratory and Injunctive Relief

UNITED STATES DISTRICT COURT
DISTRICT OF SOUTH CAROLINA

ROBERT CLARKSON                            }
                                                                              Docket #___________
             vs.                                                }
                                                                               Complaint for Declaratory
White House Counsel -                                              and Injunctive Relief
Executive Office of
the President )                                                              (Jury Trial Demanded)

1. This is a complaint under the Freedom of Information Act (FOIA) 5 USC § 552
as amended, to order the production of documents and records requested by
Plaintiff that are held by Defendant federal agency.

2. Plaintiff Robert Clarkson is a citizen and legal resident of the state of South Carolina and this District. Defendant is a federal agency that can be sued in the District, according to FOIA 552(a)(4)(B), where Plaintiff resides.

Defendant has possession and control over the records and documents sought by Plaintiff. Defendant has refused to comply with Plaintiff’s lawful request and to obey the clear mandate of the FOIA.

3. This Court has jurisdiction over this action pursuant to FOIA 5 USC § 552
(a)(4)(B) and 28 USC 1361, and 1402.

4. On 26 May 1997, Plaintiff Clarkson requested from Defendant all records and
documents from Defendant pertaining to

A. The notes of White House Counsel pertaining to the activities of H. R. Clinton pertaining to the death of Deputy Counsel Vincent Foster.

B. The notes of White House Counsel pertaining to the discovery of missing Rose Law Firm billing receipts found in the White House. These requested documents are the same records under subpoena by Independent Counsel Kenneth Starr and subject to decisions of the Eighth Circuit Court of Appeals and the U.S. Supreme Court.

Said FOIA request is attached as Exhibit A and incorporated by reference herein.

5. Defendant failed to comply and on 30 June 1997, Clarkson filed his administrative appeal, and again on 7 July 1997.

6. On 9 July 1997 Clarkson filed his second FOIA Request for Documents (Exhibit B), which is an expanded version of his earlier request. Defendant Agency failed to comply and on 2 Sept. 1997, Clarkson filed his administrative appeal.

Plaintiff requests only copies of documents dealing with unlawful and wrongful actions of the Office of the White House Counsel in providing free legal services and resources to Mrs. H. R. Clinton, a non-government employee, and to President W. J. Clinton for non-official legal matters such as dealing with private lawsuits and investigations by Independent Counsel Kenneth Starr.

Plaintiff specifically did not request and does not want any documents dealing with official governmental or presidential business or lawful government activities.

7. Plaintiff has a statutory right to the requested records and Defendant has no legal basis for its refusal to disclose them to him. Defendant agency has acted in a wrongful, intentional and willful manner and Plaintiff was damaged as a result of Defendant’s refusal and failure. Plaintiff has exhausted his administrative remedies, and Plaintiff is entitled pursuant to law, to inspect and copy the requested documents.

Plaintiff is entitled to sanctions against Defendant, damages, attorney’s fees, out-of-pocket expenses and cost.

WHEREFORE, Plaintiff prays that this Court:

1. Declare that the Defendant’s refusal to disclose the requested records is unlawful.

2. Order the Defendant to make the requested records available to Plaintiff
Clarkson.

3. Declare that records of the unlawful or illegal activities of the federal agencies are not protected by any exemption of the FOIA.

4. Award Plaintiff costs, fees, out-of-pocket expenses, and attorney's fees in this action.

5. Grant such other and further relief which is just and proper.

Date: 30 November, 1997                                              ________________________
                                                                                       Robert B. Clarkson
                                                                                       515 Concord Avenue
                                                                                       Anderson, SC 29621
                                                                                       864/225-3061

__________________________________________

FOIA Request Exhibit A

TO: The White House Counsel FROM: Robert B Clarkson
The White House
1600 Pennsylvania Ave 864/225-3061
Washington, DC 20002

1. This is a request under the Freedom of Information Act, 5 usc 552 and the Privacy Act, 5 USC 552a. I agree to pay costs and fees of locating and copying the below requested
documents.

2. This request is in the public interest because the requested materials pertains to the public at large and not to any particular person. Also, my funds are not unlimited and I may be a person eligible to receive federal benefits. Therefore I request that you waive fees and costs, but if you do not, please send the requested materials and do not let the request for waiver delay this FOIA request. You can consider this a firm agreement to pay fees.

3. If some of my requests are exempt from release, send me those portions “reasonably
segregatable”, and provide me with an indexing, itemization and detailed justification
concerning information which you are not releasing.

4. Please send me the following documents:

A. The notes by White House Associate Counsel Miriam R Nemetz dated July 11, 1995, on the activities of Mrs Hillary R Clinton pertaining to the death of Deputy Counsel Vincent Foster.

B. The notes of White House Special Counsel Jane Sherburne dated January 26, 1996, pertaining to the discovery of missing Rose Law

Firm billing records found in the White House living quarters.

These requested documents are the same records under subpoenas of Independent Counsel Kenneth Starr and mentioned in the recent decision of the 8th US Court of Appeals.

Date: 26 May 1997 __________________
Yours, Robert Clarkson

Exhibit B

TO: Mr. Charles Ruff FROM: Robert Clarkson

Attn: Robert Schroeder FROM;
The White House Counsel
1600 Pennsylvania Ave
Washington. DC 20002

1. This is a request under the Freedom of Information Act, 5 USC §552 and the Privacy Act, 5 Usc §552a.
I agree to pay costs and fees of locating and copying the documents requested below.

2. This request is in the public interest because the requested materials pertain to the public at large and not to any particular person. Also, my funds are limited and I may be a person eligible to receive federal benefits. Therefore, I request that you waive fees and costs, but if you do not, please send the requested materials and do not let the request for waiver delay this FOIA request. You can consider this a firm agreement to pay fees. I request fee waiver because no commercial use is intended and disclosure will contribute to public
understanding of the activities of the government.

3. If some of my requests are exempt from release, send me those portions “reasonably segregatable,” and provide me with an indexing, itemization and detailed justification concerning information which you are not releasing.

4.Please send me the following documents: computer disc or tapes, written material,
A. The notes and related documents by White Associate Counsel Miram R Nemetz
dated July 11, 1995, on the activities of Mrs. Hillary H Clinton about and pertaining to the death of Deputy Counsel Vincent Foster and Ms Nemetz’s legal representation of or legal work for Mrs. Clinton.

B. The notes and related documents of White House Special Counsel Jane Sherburne dated January 26, 1996, pertaining to the discovery of missing Rose Law Firm billing records found in the White House living quarters. These above requested documents are the same records under subpoena of Independent Counsel Kenneth Starr and mentioned in the recent decisions of the 8th US Court of Appeals and the US Supreme Court.

C. All rules and regulations pertaining to the private or unofficial, not job related use of government personnel especially attorneys, their staff, government equipment and Supplies, in particular those in the Department of Justice and Office of Counsel to the President by important government officials as President William J Clinton, and the spouse of important officials as Mrs. Hillary H Clinton, for assistant, advice, legal work, appearances in non-official lawsuits, civil or criminal investigations grand jury or congressional appearances that are not related to official work.

D. All rules and regulation pertaining to the use of the time, staff and supplies of the attorneys in your office by non-government employees as Mrs. Hillary R Clinton for non official legal work as representation in civil lawsuits, Criminal investigation and appearances before grand juries and congressional committees.

E. Copies of all records, written material and computer records pertain to the use, advise and counsel to Mrs. Hillary R Clinton by any government attorney, his staff and equipment, from the White House Counsel Office or Department of Justice or any department of the US government, in any matter 1990, in particular the legal work about the many legal problems commonly referred to as" Whitewater", in particular any investigation by Independent Counsel Kenneth Starr, grand jury appearances, discovery and any Congressional investigation. This request includes copies of all work done for Mrs. Clinton by any government attorney for any reason since 1990, and related documents, notes, legal research, pleadings, etc for any non—official work but only for the private benefit of the said Mrs. Clinton.

F.. All records, written material and computer files pertaining to the use, advice & counsel to President William J Clinton by any government attorney or his staff and advisors from any department especially The Office of Counsel to The President in any private, personal, non—governmental matter since 1990, in particular the records on any legal matter or legal problem as commonly referred to as ’Whitewater” , in particular concerning any
investigation by the said Independent Counsel, grand jury appearances, congressional investigations, depositions, discovery or any civil or criminal proceeding pertaining to President or Mrs. Clinton and their staff and advisors, and more especially legal assistance in the civil lawsuit by Ms Paula Jones.

I especially request documentation pertaining to the use of government attorneys and resources for private, non—governmental legal assistance or representation to President and Mrs. Clinton on non— official matters outside the scope of his office. I do not request copies of any records to official business or governmental activities.
G. Copies of all records, computer files, etc, of any legal work, pleadings, legal research, legal advice or plan given or prepared for the benefit of the said President and Mrs. Clinton on any private, non-governmental, non-official legal or other matter, case or investigation whether civil or criminal including assistance in any congressional, grand jury or criminal investigation . In other words, please send me a copy of all paper or computer work done by your office on private legal problems of the said President and his wife since 1990, as long as it is of course, not official governmental work. And, send me a copy of all work for Mrs. Clinton, a non governmental employee.
-----------------------------------------------

U.S. AIR FORCE SUED UNDER FOIA OVER ANTI-AMERICAN BRIEFINGS

The United States Air Force has been sued in U.S. District Court for South Carolina, Docket #8:97-1882 under the Freedom of Information Act (FOIA) by national patriotic leader Robert Clarkson.

Clarkson filed suit against the USAF Special Operations Command (AFSOC) at Hurlbut Field, Florida and other locations over a military training course called "Dynamics of International Terrorism." The course is based on materials purchased from Morris Dees and Joe Roy of the Southern Poverty Law Center (SPLC) of Montgomery, Alabama. Although the materials are more fundraisers for the SPCL than educational materials, Dees and Roy have with full government approval distributed them to various military bases where they have been used to dangerously misinform American troops.

Among SPLC items distributed are the booklet "False Patriots" and a brochure, "Keeping Watch." Both documents include fund raising requests for the SPLC, a well-known private political organization of extreme left-wing orientation.

In response to a FOIA request by Clarkson, the AF SOC released the class materials including records of payment for them. However, none of the released material had anything to do with any "international" operations, and nothing about real terrorism by international groups. The booklet and pamphlet were strictly leftist-oriented scare propaganda targeting religious and political organizations, many of whom call for a return to government accountability.

"False Patriots" encourages the public to trust the Clinton administration.

Since the military failed to produce anything documenting the "international terrorism" it associates with these patriotic organizations, Clarkson filed an administrative appeal to the Secretary of the Air Force under the FOIA, filed a barrage of supplemental FOIA requests for release of documents and finally the FOIA lawsuit. With it he plans to put a stop to programs which teach American soldiers to treat innocent people as terrorists.

About Robert Clarkson

Robert Clarkson graduated from Clemson University in 1969 and from University of South Carolina Law School in 1974. He served in Vietnam with the 22nd Infantry Regiment, 25th Infantry Division as a 1Lt infantry platoon leader.

Robert Clarkson is Executive Director of the Carolina Patriots, a Constitutional study group which is libeled in the SPLC booklet. Clarkson is a nationally recognized expert on the Freedom of Information Act, Privacy Act and tax procedure law. He has written several books and is editor of The Patriot Cannon, a tax reform magazine. He was co-founder of the both the Libertarian Party and the U.S. Taxpayers Party in South Carolina.

For 20 years, Dr. Clarkson has been speaking and writing about the United States Constitution, the Bill of Rights and the Declaration of Independence, plus the danger to our rights and liberties from the IRS,income tax and Federal Reserve.

In the SPLC suit, Clarkson is making use of what are known as the "sunshine" laws because they give citizens access to what government is doing as financed by taxpayers. The Freedom of Information Act, Title 5 US. Code 552, was passed by Congress in 1966 and requires that federal agencies release records and documents upon request. Requesters can file suit when they discover something improper and collect costs and attorneys' fees for calling the government to account. The FOIA is a "private attorney general" statute. Dr. Clarkson needs more patriots to participate and send in FOIA forms.

For information on the AF SOC class on "international terrorism," contact Col. Eugene Ronsick, USAF SOC, Hurlbut Field, FL 32544. For a copy of the lawsuit and other information, write the Patriot Network, POB 2368, Care of Robert Clarkson, Anderson, S.C. 29622. Phone 864/225-0882
____________________________________________________________________

UNITED STATES DISTRICT COURT
DISTRICT OF SOUTH CAROLINA

ROBERT B. CLARKSON                            }
                                                                                       Docket #__________________
               vs

                                                                                       COMPLAINT FOR DECLARATORY
                                                                                                                                AND INJUNCTIVE RELIEF
UNITED STATES AIR FORCE
SPECIAL OPERATIONS COMMAND a
DEPARTMENT OF DEFENSE                                                   (Jury Trial Demanded)

1. This is a complaint under the Freedom of Information Act (FOIA) 5 USC § 552 as
amended, to order the production of documents and records requested by Plaintiff
that are held by Defendant federal agencies.

2. Plaintiff, Robert B. Clarkson, is a citizen and legal resident of the state of South
Carolina and this District.. Defendants are federal agencies that can be sued in the
District, according to FOIA 552(a)(4)(B), where Plaintiff resides.

Defendants have possession and control over the records and documents sought by
Plaintiff.

Defendants have refused to comply’ with Clarkson’s lawful request and to obey the
clear mandate of the FOIA.

3. This Court has jurisdiction over this action pursuant to FOIA 5 USC § 552 (a)(4)(B)
and 28 USC §1391 and 1402.

4. On October 6,1996, Plaintiff Clarkson requested from Defendants all records and
documents from Defendants pertaining to a course called “Dynamics of International
Terrorism” taught at the United States Air Force SOC by Morris Dees and Joe Roy of
the Southern Poverty Law Center (SPLC) and related material as listed in his FOIA
Request of October 6,1996 Attached as Exhibit “A” and incorporated by reference
herein. Defendants failed to comply and on December 1,1996, Clarkson filed his
administrative appeal.

5. On October 24, 1996, Clarkson filed his FOIA Request for Documents (Exhibit B),
which is identical to his October 6,1996 request except for different addressee.

On November 22, 1996, Colonel Eugene Ronsick, Director of USAF-SOC responded
and released to Clarkson various political and fundraising pamphlets of the SPLC, but
not one single word pertaining to “International Terrorism”. The released material was
nothing except political literature of extreme left-wing variety which attacked various
political groups accused of being right-wing, plus an appeal for funds for Dees’ anti-
American political group.

Colonel Ronsick also released the payment records to SPLC but these were
unreadable and on December 3,1996, Clarkson wrote Colonel Ronsick to request a
readable copy, which was refused. Copy of letter attached as Exhibit C.

Since Colonel Ronsick refused to comply with Plaintiffs FOIA request and only
distributed extreme liberal political and fundraising material, Clarkson filed his
administrative appeal dated December 1, 1996, which was denied.

6. From October 6,1996 to present, Clarkson sent the UASF and its various
departments a large number of FOIA Requests for Documents which were similar to the
above-mentioned request but expanded.

Defendants refused to comply and Clarkson filed his administrative appeals. These
requests, their dates, addresses, and date of appeals are listed below. Copies of these
requests which are hereby incorporated by reference herein, are attached to Clarkson’s
pleading “List of Exhibits” to be filed shortly.

Clarkson made the following requests on the following dates:

Exhibit       Date              Addressee                         Response                 Date of Appeal
D              1/25/97          Secretary of the Air Force   None                          2/26/97
E               1/25/97          HQ AFSOC/SCMS           Refused
F               3/10/97          USSOC, MacDill AFB       Refused                       4/7/97
C              3/25/97          USSOC, MacDill AFB       None                           4/7/97
H              1/31/97          Joint SOC, Ft. Bragg          Refused                      4/7/97
I                1/31/97          USSOC, Pentagon               None                          4/7/97

7. Plaintiff has a statutory right to the requested records and Defendants have no legal
basis for their refusal to disclose them to him.

WHEREFORE, Plaintiff prays that this Court:

1. Declare that, the Defendant’s refusal to disclose the requested records is unlawful.

2. Order the United States Air Force, the Special Operations Command and the

Department of Defense to make the requested records available to Plaintiff Clarkson.

3. Award Plaintiff costs, fees, out-of-pocket expenses, and attorney’s fees in this

action.

4. Grant such other and further relief which is just and proper.

Date: 4 June, 97                                                          _________________________
                                                                                   Robert B. Clarkson
                                                                                   515 Concord Avenue
                                                                                   Anderson, SC 29621
                                                                                   864/225-3061

FOIA REQUEST Exhibit A

FOIA Request

TO: USAF Special Operations School                        FROM: Robert Clarkson
USAFSOS                                                                              515 Concord Ave
Hurlburt Field

Freedom of Information Act
&
Privacy Act

FOIA LAWSUIT AGAINST IRS

FEDERAL RESERVE SUED BY NATIONALLY KNOWN CONSTITUTIONALIST

FREEDOM OF SPEECH DEFENSE COMMITTEE PRESS RELEASE
WHITE HOUSE SUED FOR ILLEGAL DOCUMENT.

U.S. AIR FORCE SUED UNDER FOIA OVER ANTI-AMERICAN BRIEFINGS

About Robert Clarkson

Freedom of Information Act & Privacy Act

FOIA LAWSUIT AGAINST IRS

FEDERAL RESERVE SUED BY NATIONALLY KNOWN CONSTITUTIONALIST

FREEDOM OF SPEECH DEFENSE COMMITTEE PRESS RELEASE WHITE HOUSE SUED FOR ILLEGAL DOCUMENT.

U.S. AIR FORCE SUED UNDER FOIA OVER ANTI-AMERICAN BRIEFINGS

About Robert Clarkson

Freedom of Information Act
&
Privacy Act

FREEDOM OF SPEECH DEFENSE COMMITTEE PRESS RELEASE
WHITE HOUSE SUED FOR ILLEGAL DOCUMENT.