Unreceived COVID Relief Funds

Here's a thread about the missing COVID relief payments. In Texas, they initially denied claims as often as they could, then refused to add folks to PUA/DUA, and wouldn’t even investigate wages for contractors. If you weren't on a payroll, good luck getting anything. This pretty much excluded almost all PUA/DUA claims. When they finally started processing claims, they still refused to cover rent. My wife and I even reached out to the World Health Organization to explain that we couldn’t do laundry for five months due to the CDC declaration. We were surviving on just 400 bucks a month in Food Stamps, while we should’ve received the money owed to us and supported our economy. This situation hurt so many others too, and we’re also seeking compensation for the financial damage. Some folks may have even passed away or faced COVID while missing out on DUA/PUA payments. I’ll drop some links and go into more detail in future posts. After they finally started paying rent, they only managed to help three households in the first month. I waited four months for an appeal to be heard, which was in my favor on April 15, 2021, but I still haven't seen a cent. For the last four months, I've been calling TWC Agents who have no clue what’s going on. Each one has a totally different idea of how this should work. It's been months of my life wasted on the phone with these people. Eventually, I ended up filing a federal lawsuit in the Claims Court because my wife hadn’t received a single dollar, and all my cash was going straight to the landlord while there was money set aside.

This help you understand when they Government has crossed the $200,000 line. https://www.justice.gov/opcl/overview-privacy-act-1974-2020-edition/disclosures-third-parties U.S. flag An official website of the United States government Here’s how you know Here’s how you know The United States Department of Justice You are here Home » About DOJ » Office of Privacy and Civil Liberties » Overview of The Privacy Act of 1974 (2020 Edition) SHARE MENU OVERVIEW OF THE PRIVACY ACT: 2020 EDITION CONDITIONS OF DISCLOSURE TO THIRD PARTIES The general rule under the Privacy Act is that an agency cannot disclose a record contained in a system of records unless the individual to whom the record pertains gives prior written consent to the disclosure.  There are twelve exceptions to this general rule.   A. The “No Disclosure without Consent” Rule “No agency shall disclose any record which is contained in a system of records by any means of communication to any person, or to another agency, except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains [subject to 12 exceptions].”  5 U.S.C. § 552a(b). Comment: Under the Privacy Act’s disclosure provision, agencies generally are prohibited from disclosing records by any means of communication – written, oral, electronic, or mechanical – without the written consent of the individual, subject to twelve exceptions. Federal officials handling personal information are “bound by the Privacy Act not to disclose any personal information and to take certain precautions to keep personal information confidential.”  Big Ridge, Inc. v. Fed. Mine Safety & Health Review Comm’n, 715 F.3d 631, 650 (7th Cir. 2013); see also, e.g., Navy, Navy Exch., Naval Training Station, Naval Hosp. v. FLRA, 975 F.2d 348, 350 (7th Cir. 1992) (noting that “Privacy Act generally prohibits the federal government from disclosing personal information about an individual without the individual’s consent”). A “disclosure” can be by any means of communication – written, oral, electronic, or mechanical.  See OMB 1975  Guidelines, 40 Fed. Reg. at 28,953, https://www.​justice.gov/paoverview_omb-75; Bartel v. FAA, 725 F.2d 1403, 1409 (D.C. Cir. 1984) (concluding that “an absolute policy of limiting the Act’s coverage to information physically retrieved from a record would make little sense in terms of its underlying purpose” and that Privacy Act “forbids nonconsensual disclosure of records “by any means of communication”); see also, e.g., Speaker v. HHS Ctrs. for Disease Control & Prevention, 623 F.3d 1371, 1382 n.11 (11th Cir. 2010) (“Numerous courts have held that the Privacy Act protects against improper oral disclosures.”); Jacobs v. Nat’l Drug Intelligence Ctr., 423 F.3d 512, 517-19 (5th Cir. 2005) (rejecting argument that “the [Privacy Act] only protects against the disclosure of a physical document that is contained in a system of records,” and holding that “damaging information . . . taken from a protected record and inserted into a new document, which was then disclosed without the plaintiff’s consent,” violated subsection (b) because “the new document is also a protected record”); Orekoya v. Mooney, 330 F.3d 1, 6 (1st Cir. 2003) (“The Privacy Act prohibits more than dissemination of records themselves, but also ‘nonconsensual disclosure of any information that has been retrieved from a protected record’” (quoting Bartel v. FAA, 725 F.2d at 1408)); Boyd v. United States, 932 F. Supp. 2d 830, 835 (S.D. Ohio 2013) (“[w]hile the term ‘disclosure’ is not defined by the statute, it has been interpreted broadly”); Cloonan v. Holder, 768 F. Supp. 2d. 154, 163 (D.D.C. 2011) (citing Bartel, 725 F.2d at 1408); Chang v. Navy, 314 F. Supp. 2d 35, 41 n.2 (D.D.C. 2004) (citing Bartel, 725 F.2d at 1408). OMB guidelines, and some, but not all, courts have advised that disclosures can occur by either transferring a record or simply “granting access” to a record. Further, a disclosure under the Privacy Act “may be either the transfer of a record or the granting of access to a record.”  OMB 1975 Guidelines, 40 Fed. Reg. at 28953 (July 9, 1975), https://www.justice.gov/paoverview_omb-75; see also Wilkerson v. Shinseki, 606 F.3d 1256, 1268 (10th Cir. 2010) (interpreting disclosure under the Privacy Act “liberally to include not only the physical disclosure of the records, but also the accessing of private records”).  Regarding actionability, however, the United States Court of Appeals for the District of Columbia Circuit has required that a record actually be retrieved.  Armstrong v. Geithner, 608 F.3d 854, 857 (D.C. Cir. 2010) (quoting Bartel, 725 F.2d at 1408, and holding that, to be actionable, “a disclosure generally must be the result of someone having actually retrieved the ‘record’ from that ‘system of records’; the disclosure of information is not ordinarily a violation ‘merely because the information happens to be contained in the records’”); Lambert v. United States, No. 3:15-CV-147-PLR-HBG, 2016 WL 632461, at *4-5 (E.D. Tenn. Feb. 17, 2016).  But see Atkins v. Mabus, No. 12CV1390-GPC, 2014 WL 2705204, at *4-8 (S.D. Cal. June 13, 2014) (holding unauthorized access not actionable under Privacy Act, even though plaintiff’s declaration provided support for conclusion that defendant’s employees individually improperly accessed plaintiff’s private medical data); Cacho v. Chertoff, No. 06-00292(ESH), 2006 WL 3422548, at *5 (D.D.C. Nov. 28, 2006) (“[A] plaintiff cannot establish a prima facie claim under the Privacy Act simply by showing that the agency official who disclosed a protected record should never have accessed the record in the first place.”); Smith v. VA, No. CIV-06-865-R, 2007 WL 9711018 (W.D. Okla. Sept. 12, 2007) (dismissing claim of improper disclosure under subsection (b) in spite of evidence suggesting agency’s employee had unauthorized access to plaintiff’s personnel file, because agency had complied with all safeguards of Privacy Act, and had not acted intentionally or willfully to disclose, defined as “to ‘open up,’ ‘to expose to view,’ or ‘to make known, . . . especially to reveal in words’” (citations omitted)). A disclosure of information from a non-record source does not violate the Privacy Act’s disclosure provision. The disclosure of information “acquired from non-record sources – such as observation, office emails, discussions with co-workers and the ‘rumor mill’– does not violate the Privacy Act . . . even if the information disclosed is also contained in agency records.”  Lambert v. United States at *5 (quoting Cloonan, 768 F. Supp. 2d. at 164); Thompson v. BOP, No. 1:10-CV-00578-JOF, 2012 WL 13072105, at *5 (N.D. Ga. Jan. 20, 2012) (For “a disclosure to be covered by section 552a(b), there must have initially been a retrieval from the system of records which was at some point a source of the information.” (citations omitted)); Savage v. Geren, No. CV-08-S-2189-NE, 2010 WL 11519448, at *13 (N.D. Ala. Nov. 15, 2010) (“[T]he Privacy Act does not prohibit disclosure of information or knowledge obtained from other sources other than ‘records.’...In particular, it does not prevent federal employees or officials from talking – even gossiping – about anything of which they have non-record-based knowledge.” (citations omitted)). For further discussion of the meaning of “disclosure” of records, see the “Definitions, Systems of Records and Disclosures under Subsection (b)” section above. In one case in which a plaintiff sought relief for alleged wrongful disclosure of items seized during the execution of a search warrant, the court found, “Appellant has failed to show that evidence seized during a search conducted in a criminal investigation constitutes records that are “contained in a system of records” under the Privacy Act.  Matter of Search of 2122 21st Rd. N. Arlington, Virginia, No. 1:17-CR-00236, 2018 WL 534161, at *4 (E.D. Va. Jan. 23, 2018), aff’d sub nom. U.S. v. Sear

Continued... .... The D.C. Circuit’s opinions in Hollis and Pilon, both discussed above, provide some insight into its view of whether the release of information that is already available to the public constitutes a “disclosure” under the Privacy Act.  In Hollis, issued in 1988, the D.C. Circuit had recognized in dictum that other courts had held that the release of previously published material did not constitute a disclosure, and suggested that it might take that approach.  Hollis, 856 F.2d at 1545.  The court had held that a disclosure did not violate the Privacy Act because the recipient of the information already was aware of it, but that “ther courts have echoed the sentiment that when a release consists merely of information to which the general public already has access, or which the recipient of the release already knows, the Privacy Act is not violated.”  However, the D.C. Circuit’s subsequent holding in 1996 in Pilon appears to foreclose such a possibility.  In Pilon, the D.C. Circuit held that even under the narrow Hollis interpretation of “disclose,” the agency would not be entitled to summary judgment because it had “failed to adduce sufficient evidence that [the recipient of the record] remembered and could reconstruct the document’s material contents in detail at the time he received it.”  73 F.3d at 1124-26.  Nevertheless, the D.C. Circuit in Pilon noted that “[t]his case does not present the question of whether an agency may . . . release a document that has already been fully aired in the public domain through the press or some other means” but that “the Privacy Act approves those disclosures that are ‘required’ under the [FOIA] . . . and that under various FOIA exemptions, prior publication is a factor to be considered in determining whether a document properly is to be released.”  Id. at 1123 n.10; see also Barry v. DOJ, 63 F. Supp. 2d 25, 27-28 (D.D.C. 1999) (distinguishing Pilon and finding no disclosure where agency posted Inspector General report on Internet website, after report had already been fully released to media by Congress and had been discussed in public congressional hearing, even though some Internet users might encounter report for first time on website).  Furthermore, though, and consistent with the D.C. Circuit’s note in Pilon, one might argue that to say that no “disclosure” occurs for previously published or public information is at least somewhat inconsistent with the Supreme Court’s decision in DOJ v. Reporters Comm. for Freedom of the Press, 489 U.S 749, 762-71 (1989), which held that a privacy interest can exist, under the FOIA, in publicly available – but “practically obscure” – information, such as a criminal history record.  Cf. Finley v. NEA, 795 F. Supp. 1457, 1468 (C.D. Cal. 1992) (alleged disclosure of publicly available information states claim for relief under Privacy Act; recognizing Reporters Comm.). The United States Court of Appeals for the Fourth Circuit has issued contradictory unpublished decisions on the issue of whether release of publicly available information constitutes a disclosure.  Compare Lee v. Dearment, 966 F.2d 1442 (4th Cir. 1992) (unpublished table case) (upholding district court’s determination that “the Act does not prohibit disclosure of information which is already open to the public, or if the receiver already knew of it” (citing Hollis v. Army, 856 F.2d at 1545)), and Dye, 642 F.2d at 836, with Doe v. Herman, No. 297CV00043, 1999 WL 1000212, at *11 (W.D. Va. Oct. 29, 1999) (magistrate’s recommendation) (agreeing with Quinn v. Stone, 798 F.2d at 134, in dictum and concluding that discussion of social security numbers at public hearing did not free agency to disclose those numbers), adopted in pertinent part & rev’d in other part (W.D. Va. July 24, 2000), aff’d in part, rev’d in part & remanded, on other grounds sub nom. Doe v. Chao, 306 F.3d 170 (4th Cir. 2002) (finding that plaintiff had not established “actual damages” from disclosure), aff’d, 540 U.S. 614 (2004). The Ninth Circuit has applied the “single publication rule,” in which the court limits aggregate, unauthorized disclosures to only one cause of action, where an agency disclosed records on an agency web page. On a related point, the Ninth Circuit held in a subsection (b) case that the “single publication rule” applies to postings on an agency’s web site such that “the aggregate communication can give rise to only one cause of action.”  See Oja v. Army Corps of Eng’rs, 440 F.3d 1122, 1130-33 (9th Cir. 2006) (affirming summary judgment for Army Corps which had posted employees’ personal information on its public website).  However, the court also ruled that with regard to “the same private information at a different URL address [within the same Web site] . . . that disclosure constitutes a separate and distinct publication – one not foreclosed by the single publication rule – and [the agency] might be liable for a separate violation of the Privacy Act.”  Id. at 1133-34. A public filing of records with a court during the course of litigation constitutes a disclosure. The fact that “a court is not defined as an ‘agency’ or as a ‘person’ for purposes of [the Privacy Act],” (see Definitions, infra), indicates the Act was “not designed to interfere with access to information by the courts.”  120 Cong. Rec. 36,967 (1974), reprinted in Source Book at 958-59, https://www.justice.gov/opcl/​paoverview_sourcebook.  Even so, the public filing of records with a court, during the course of litigation, does constitute a subsection (b) disclosure.  See Laningham v. Navy, No. 83-3238, slip op. at 2-3 (D.D.C. Sept. 25, 1984), summary judgment granted (D.D.C. Jan. 7, 1985), aff’d per curiam, 813 F.2d 1236 (D.C. Cir. 1987); Citizens Bureau of Investigation v. FBI, No. 78-60, slip op. at 2-3 (N.D. Ohio Dec. 14, 1979).  Accordingly, any such public filing must be undertaken with written consent or in accordance with either the subsection (b)(3) routine use exception or the subsection (b)(11) court order exception, both discussed below.  See generally Krohn v. DOJ, No. 78-1536, slip op. at 3-11 (D.D.C. Mar. 19, 1984) (finding violation of Privacy Act where agency’s disclosure of records as attachments to affidavit in FOIA lawsuit “did not fall within any of the exceptions listed in Section 552a”), reconsideration granted & vacated in nonpertinent part (D.D.C. Nov. 29, 1984) (discussed below). The Privacy Act disclosure provision does not require heightened discovery requirements. Often during the course of litigation, an agency will be asked to produce Privacy Act-protected information pursuant to a discovery request by an opposing party.  The Privacy Act “does not create a qualified discovery privilege” or “any other kind of privilege or bar that requires a party to show actual need as a prerequisite to invoking discovery,” and courts generally consider whether to allow discovery under “the usual discovery standards” of the Federal Rules of Civil Procedure.”  Laxalt v. McClatchy, 809 F.2d 885, 888 (D.C. Cir. 1987); see also Weahkee v. Norton, 621 F.2d 1080, 1082 (10th Cir. 1980); Garraway v. Ciufo, No. 117CV00533DADGSAPC, 2020 WL 1263562, at *8 (E.D. Cal. Mar. 16, 2020); Pennsylvania v. Navient Corp., 348 F. Supp. 3d 394, 398 (M.D. Pa. 2018); Ala. & Gulf Coast Ry. v. United States, No. CA 10-0352, 2011 WL 1838882, at *3 (S.D. Ala. May 13, 2011); Golez v. Potter, No. 09-cv-965, 2011 WL 6002612, at *1-2 (S.D. Cal. Nov. 29, 2011) (“The exceptions allowed in the Privacy Act of 1974 are not applicable here. . . . Accordingly, the Privacy Act . . . precludes the [agency] from complying with Plaintiff’s discovery request.”); Forrest v. United States, No. 95-3889, 1996 WL 171539, at *2 (E.D. Pa. Apr. 11, 1996); Ford Motor Co. v. United States, 825 F. Supp. 1081, 1083 (Ct. Int’l Trade 1993); Clavir v. United States, 84 F.R.D. 612, 614 (S.D.N.Y. 1979); cf. Baldrige v. Shapiro, 455 U.S. 345, 360-62 (1982) (finding that Census Act conf

Continued... .... The OMB 1975 Guidelines caution that “the consent provision was not intended to permit a blanket or open-ended consent clause, i.e., one which would permit the agency to disclose a record without limit,” and that, “[a]t a minimum, the consent clause should state the general purposes for, or types of recipients [to,] which disclosure may be made.”  40 Fed. Reg. at 28,954, https://www.justice.gov/​paoverview_omb-75.  See also Perry v. FBI, 759 F.2d 1271, 1276 (7th Cir. 1985) (upholding disclosure because release was “not so vague or general that it is questionable whether [plaintiff] knew what he was authorizing or whether the [agency] knew what documents it could lawfully release”), rev’d en banc on other grounds, 781 F.2d 1294 (7th Cir. 1986). Courts generally have approved disclosures made with consent where the consent was broad enough to cover the disclosure. See Elnashar v. DOJ, 446 F.3d 792, 795 (8th Cir. 2006) (observing that plaintiff’s signed release “authoriz[ing] representatives of [human rights organization] to obtain and examine copies of all documents and records contained by the [FBI] . . . pertaining to [plaintiff]” constituted consent for FBI to disclose “that it had records which were responsive to the request for records and that records were contained in the ‘PENTBOMB’ investigation”); United States v. Rogers, No. 10-00088, 2010 WL 5441935, at *1 (S.D. Ala. Dec. 28, 2010) (concluding that “if defendant is willing to make a written request to the BOP for his own records and give written consent for their release to his defense counsel, the Court sees no reason why a[] [court] order is necessary”); Roberts v. DOT, No. 02-CV-4414, 2006 WL 842401, at *8, *2 (E.D.N.Y. Mar. 28, 2006) (maintaining that plaintiff’s signed SF 171, which “explicitly stated that [plaintiff] ‘consent[ed] to the release of information about [his] ability and fitness for Federal employment,’” authorized disclosure of plaintiff’s medical records by agency who previously employed him to employing agency to assist in “assist determining whether the employee is capable of performing the duties of the new position”); Thomas v. VA, 467 F. Supp. 458, 460 n.4 (D. Conn. 1979) (holding consent was adequate because it was both agency- and record-specific); cf. Tarullo v. Def. Contract Audit Agency, 600 F. Supp. 2d 352, 360-61 (D. Conn. 2009) (concluding that “the forms themselves put the Plaintiff on notice that they (and hence their contents) would be disclosed . . . . Yet, the Plaintiff supplied his SSN.  As a result, he voluntarily disclosed his SSN.”); Wiley v. VA, 176 F. Supp. 2d 747, 751-56 (E.D. Mich. 2001) (concluding that plaintiff’s written release for employment application that broadly authorized employer to corroborate and obtain information about plaintiff’s background constituted valid consent under Privacy Act to authorize disclosure of all 466 pages of plaintiff’s VA claims file in connection with union grievance proceeding, even though release was signed eight years prior to disclosure”). On the other hand, courts have found consent clauses with narrower terms than the eventual disclosure to be inadequate to authorize that disclosure.  See Schmidt v. Air Force, No. 06-3069, 2007 WL 2812148, at *8 (C.D. Ill. Sept. 30, 2007) (issuance of press release and posting of complete text of plaintiff’s reprimand on agency website was outside scope of plaintiff’s signed waiver, which was limited to “a press release announcing the conclusion of the case”); Fattahi v. ATF, 186 F. Supp. 2d 656, 660 (E.D. Va. 2002) (consent providing that information on application “may be disclosed to members of the public in order to verify the information on the application when such disclosure is not prohibited by law” was “a mere tautology:  plaintiff consented to no more than that ATF may disclose information except in cases where that disclosure is prohibited”); Doe v. Herman, No. 297CV00043, 1999 WL 1000212, at *9 (W.D. Va. Oct. 29, 1999) (magistrate’s recommendation) (rejecting argument that when plaintiffs provided their social security numbers for purpose of determining eligibility for and amount of benefits payable, they consented to use of those numbers as identifiers on multi-captioned hearing notices sent to numerous other individuals and companies as well as to publication of numbers in compilations of opinions), adopted in pertinent part & rev’d in other part, (W.D. Va. July 24, 2000), aff’d in part, rev’d in part & remanded, on other grounds sub nom.  Doe v. Chao, 306 F.3d 170 (4th Cir. 2002), aff’d, 540 U.S. 614 (2004); AFGE v. U.S. R.R. Ret. Bd., 742 F. Supp. 450, 457 (N.D. Ill. 1990) (SF-86 “release form” held overbroad and contrary to subsection (b)); and Doe v. GSA, 544 F. Supp. 530, 539-41 (D. Md. 1982) (stating that authorization, which was neither record- nor entity-specific, was insufficient under GSA’s own internal interpretation of Privacy Act); cf. Taylor, No. 83-0389, 1983 U.S. Dist. LEXIS 20334, at *6 n.6 (D.D.C. Dec. 5, 1983) (addressing alternative argument, stating:  “It is not unreasonable to require that a written consent to disclosure address the issue of such disclosure and refer specifically to the records permitted to be disclosed.”). One California district court has held that courts cannot create new disclosure exceptions based on state policy. One district court has declined to “recognize a new exception to [subsection (b) of the Privacy Act] based on California public policy to protect persons investigating acts of child abuse.”  Stafford v. SSA, 437 F. Supp. 2d 1113, 1121 (N.D. Cal. 2006).  In Stafford, a Social Security Administration (“SSA”) employee disclosed to California Child Protective Services “the precise diagnosis of mental illness on which the SSA had made its determination that [the suspected child abuser] was disabled and thus eligible for benefits.”  Id. at 1116.  The suspect brought a subsection (b)/(g)(1)(D) claim against the agency, and the agency argued that the court should recognize a new exception because “[t]he public interest in detecting and eradicating child abuse is so strong that under California state law, malicious acts or acts taken without probable cause by investigators such as [the Child Protective Services employee] are immunized.”  Id. at 1121.  The court explained that “Congress enacted the Privacy Act as a limitation on the sharing of private information among government agencies to further what it determined was an important public policy” and stated that “[t]he Court cannot create an exception to a federal statute based on state policy.”  Id.   B. Twelve Exceptions to the “No Disclosure without Consent” Rule As discussed in detail above, the general rule under the Privacy Act is that, without an individual’s written consent, records about that individual maintained in a system of records cannot be disclosed.  There are, however, a number of exceptions to that general rule, or conditions under which information can be disclosed without consent.  Of the twelve exceptions discussed in this section, the most significant and frequently litigated exceptions are the “need to know” exception, disclosures required under FOIA, and the “routine use” exception.  The twelve exceptions are discussed here in turn. Other than disclosures under subsection (b)(2) of the Privacy Act (see “Conditions of Disclosure to Third Parties, 5 U.S.C. § 552a(b)(2) - Required FOIA Disclosure” discussion, below), disclosures under the following exceptions are permissive, not mandatory.  See OMB 1975 Guidelines, 40 Fed. Reg. at 28,953, https://www.justice.gov/paoverview_omb-75. 1. 5 U.S.C. § 552a(b)(1) - Need to Know within Agency “No agency shall disclose any record which is contained in a system of records by any means of communication to any person, or to another agency, except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains unless the di

Continued... .... Although subsection (b)(1) permits disclosure only to “those officers and employees of the agency which maintains the record,” some courts have upheld disclosures to contractors who serve the function of agency employees.  See Mount v. USPS, 79 F.3d at 532-34 (concluding disclosure of plaintiff’s medical files to “a physician under contract with the USPS” who had “responsibilities for making employment and/or disciplinary decisions regarding plaintiff” had some basis in need to know exception); Gard v. Dep’t of Educ., 789 F. Supp. 2d 96, 110 (D.D.C. 2011) (finding permissible intra-agency disclosure to “‘occupational medicine consultant’ under contract with” agency for purposes of evaluating employee’s risk to coworkers); Ciralsky v. CIA, 689 F. Supp. 2d 141, 155 (D.D.C. 2010) (finding permissible intra-agency disclosures to private contractors hired to investigate certain allegations, including plaintiff’s); Sutera v. TSA, 708 F. Supp. 2d 304, 318 (E.D.N.Y. 2010) (finding permissible intra-agency disclosure where medical sample was sent to outside laboratory because “[f]or testing purposes a private laboratory is necessarily treated as part of the agency”); Coakley v. DOT, No. 93-1420, 1994 WL 16953072, at *1-2 (D.D.C. Apr. 7, 1994) (holding that independent contractor serving as EEO investigator for employee’s EEO complaint “must be considered an employee of DOT for Privacy Act purposes” and that DOT’s disclosure to that contractor “in connection with an official agency investigation . . . must be considered an intra-agency communication under the Act”); Hulett v. Navy, No. TH 85-310-C, slip op. at 3-4 (S.D. Ind. Oct. 26, 1987) (discussing disclosure of medical and personnel records to contractor/psychiatrist for purpose of assisting him in performing “fitness for duty” examination), aff’d, 866 F.2d 432 (7th Cir. 1988) (unpublished table decision); cf. Gill v. DOD, 92 M.S.P.R. at 32 n.7 (noting that EEO counselor to whom disclosure was made “was employed by a contractor, rather than directly by the agency [and] . . . was performing an administrative function for which the agency was responsible,” and stating further that “t is clear that, for particular purposes, the Privacy Act provides that any government contractor and any employee of such contractor shall be considered an employee of an agency” (citing 5 U.S.C. § 552a(m))).  Another court, however, has held to the contrary on facts nearly identical to those in Hulett.  Taylor v. Orr, No. 83-0389, 1983 U.S. Dist. LEXIS 20334, at *7-10 (D.D.C. Dec. 5, 1983). Courts generally have found intra-agency disclosures regarding personnel or employment matters as authorized disclosures under the “need to know” disclosure exception. The cases are replete with examples of proper intra-agency “need to know” disclosures.  By far the most frequent “need to know” disclosure that the courts have deemed appropriate is for the purpose of investigating alleged employee misconduct or making disciplinary determinations.  See, e.g., Pippinger v. Rubin, 129 F.3d 519, 529-31 (10th Cir. 1997) (discussing supervisor’s disclosure of identity of person being investigated to staff members assisting in investigation, and to agency attorney defending agency’s actions in related MSPB proceeding against another individual); Mount v. USPS, 79 F.3d 531, 533-34 (6th Cir. 1996) (discussing disclosure of information in plaintiff’s medical records to other employees “with responsibilities for making employment and/or disciplinary decisions regarding plaintiff”; “In light of the questions surrounding plaintiff’s mental stability, each had at least an arguable need to access the information in plaintiff’s medical records.”); Covert v. Harrington, 876 F.2d 751, 753-54 (9th Cir. 1989) (discussing disclosure of security questionnaires to Inspector General for purpose of detecting fraud); Daly-Murphy v. Winston, 837 F.2d 348, 354-55 (9th Cir. 1988) (discussing disclosure of letter suspending doctor’s clinical privileges to participants in peer-review proceeding); Lukos v. IRS, No. 86-1100, 1987 WL 36354, at *1-2 (6th Cir. Feb. 12, 1987) (discussing disclosure of employee’s arrest record to supervisor for purpose of evaluating his conduct and to effect discipline); Howard v. Marsh, 785 F.2d 645, 647-49 (8th Cir. 1986) (discussing disclosure of employee’s personnel records to agency attorney and personnel specialist for purpose of preparing response to discrimination complaint); Hernandez v. Alexander, 671 F.2d 402, 410 (10th Cir. 1982) (discussing disclosure of employee’s EEO files to personnel advisors for purpose of determining whether personnel action should be taken against employee); Grogan v. IRS, 3 Gov’t Disclosure Serv. (P-H) ¶ 82,385, at 82,977-78 (4th Cir. Mar. 22, 1982) (discussing disclosure of questionable income tax returns prepared by professional tax preparer while he was IRS employee to IRS examiners for purpose of alerting them to possible irregularities);  Code v. Esper, 285 F. Supp. 3d 58, 70-71 (D.D.C. 2017) (concluding that Army investigative unit did not violate Privacy Act by disclosing investigative report finding plaintiff committed certain crimes to Defense Finance and Accounting Service for purposes of official debt collecting duties), rev’d and remanded on other grounds sub nom. Code v. McCarthy, 959 F.3d 406 (D.C. Cir. 2020); Lewis v. SSA, No. 9:14-CV-31, 2015 WL 9664967, at *6 (E.D. Tex. Dec. 7, 2015) (discussing disclosure of report containing allegations about plaintiff by SSA employee who had duty “to ‘report threats and harassment against the agency’” to DHS), adopted by 2016 WL 81577 (E.D. Tex. Jan. 1, 2016); Drennon-Gala v. Holder, No. 1:08-CV-321G, 2011 WL 1225784, at *5 (N.D. Ga. Mar. 30, 2011) (discussing disclosure of plaintiff’s workers compensation file to agency officials investigating allegations “directly related to misconduct involving [plaintiff’s] worker’s compensation claim”); Doe v. DOJ, 660 F. Supp. 2d 31, 45-46 (D.D.C. 2009) (discussing disclosure of plaintiff AUSA’s mental state to DOJ security personnel, who “needed . . . to assess his trustworthiness and make related personnel decisions about his eligibility for security clearance,” to acting U.S. Attorney and division chief, who “[a]s plaintiff’s supervisors . . . were responsible for ensuring that the [office] was operating safely,” and to EOUSA attorney, who was “entitled to access the records because he represented DOJ in various pending disciplinary matters against plaintiff at the time” (internal quotation marks omitted)); Gamble v. Army, 567 F. Supp. 2d 150, 156 (D.D.C. 2008) (discussing disclosure to plaintiff’s commanding officer of past allegations of sexual misconduct by plaintiff in context of investigation of new allegations of same); Roberts v. DOJ, 366 F. Supp. 2d 13, 26-28 (D.D.C. 2005) (finding disclosure of results of investigation by OPR to FBI was “expressly permitted” because FBI referred matter to OPR for investigation and because FBI had duty to respond to plaintiff’s complaints; dismissing claim because “OPR was entitled to share information regarding the results of its investigation” with agency that was subject of its investigation); Buckles v. Indian Health Serv., 305 F. Supp. 2d 1108, 1111 (D.N.D. 2004) (finding disclosure of employees’ medical records by employer’s health facility to risk management team – due to concerns that employees were illegally receiving prescription drugs – was proper because it conformed with facility’s protocol to discuss issues of potential wrongdoing with upper management); Abernethy v. IRS, 909 F. Supp. 1562, 1570-71 (N.D. Ga. 1995) (“[Investigatory] panel’s review of Plaintiff’s performance appraisals was not a violation of the Privacy Act because the members had a need to know the contents of the appraisals.”); (finding that member of panel that recommended that plaintiff be removed from management in response to EEO informal class complaint “had a need

Continued... .... Note that President Barack Obama’s FOIA policy on openness in government, see Memorandum for the Heads of Executive Departments and Agencies, Subject:  Freedom of Information Act (Jan. 21, 2009), https://www.​justice.gov/paoverview_agfoia, is inapplicable to information covered by the Privacy Act that also falls under one or more of the FOIA exemptions.  See U.S. Dep’t of Justice, Off. of Info. Pol’y, OIP Guidance: President Obama’s FOIA Memorandum and Attorney General Holder’s FOIA Guidelines (April 17, 2009), https://www.justice.gov/oip/blog/foia-post-2009-creating-new-era-open-government (“For information falling within Exemptions 6 and 7(C), if the information is also protected by the Privacy Act of 1974, it is not possible to make a discretionary release, as the Privacy Act contains a prohibition on disclosure of information not ‘required’ to be released under the FOIA.”). The D.C. Circuit has held that the required FOIA disclosure exception cannot be invoked unless an agency actually has a FOIA request in hand; not all courts agree. The Court of Appeals for the District of Columbia Circuit significantly limited the utility of subsection (b)(2) as a defense by holding that subsection (b)(2) cannot be invoked unless an agency actually has a FOIA request in hand.  Bartel v. FAA, 725 F.2d 1403, 1411-13 (D.C. Cir. 1984); see also Chang v. Navy, 314 F. Supp. 2d 35, 41-42 (D.D.C. 2004) (citing Bartel, and noting that defendant agency conceded that it “had no FOIA request in hand”).  In one case prior to Bartel, it similarly had been held that subsection (b)(2) was not available as a defense for the disclosure of information in the absence of a FOIA request.  Zeller v. United States, 467 F. Supp. 487, 503 (E.D.N.Y. 1979) (finding subsection (b)(2) inapplicable to the “voluntary re-release” of a prior press release (that had been made prior to the effective date of the Privacy Act) as “nothing in the FOIA appears to require such information to be released in the absence of a request therefor”). Other courts have not followed the rule in Bartel, however, and do not require agencies to have a FOIA request in hand to raise a (b)(2) defense.  See Cochran v. United States, 770 F.2d 949, 957-58 & n.14 (11th Cir. 1985) (applying subsection (b)(2) – in absence of written FOIA request – because requested records would not be withholdable under any FOIA exemption); Jafari v. Navy, 728 F.2d 247, 249-50 (4th Cir. 1984) (same); Russo v. United States, 576 F. Supp. 2d 662, 671-72 (D.N.J. 2008) (alternative holding) (expressing reluctance to follow Bartel because subsection (b)(2)’s conditional language of “would be” rather than “is” “casts serious doubt upon Plaintiff’s argument that the exception only applies where the agency is faced with a written FOIA request”); Mudd v. Army, No. 2:05-cv-137, 2007 WL 4358262, at *6 (M.D. Fla. Dec. 10, 2007) (agreeing with agency that “under the circumstances of this case, the balance of plaintiff’s privacy against the public’s right to disclosure weighs in favor of public disclosure, and that the FOIA exception was applicable even without a formal FOIA request”). However, because the D.C. Circuit is the jurisdiction of “universal venue” under the Privacy Act -- i.e., any Privacy Act lawsuit for wrongful disclosure could be filed within that judicial circuit -- see 5 U.S.C. § 552a(g)(5) -- its holding in Bartel is of paramount importance.  See FOIA Update, Vol. V, No. 3, at 2, http://www.justice.gov/oip/foia_updates/Vol_V_3/page2.htm (discussing Bartel).  Note also, though, that the Bartel decision left open the possibility that certain types of information “traditionally released by an agency to the public” might properly be disclosed even in the absence of an actual FOIA request.  725 F.2d at 1413 (dictum).  Reacting to Bartel, OMB issued guidance indicating that records that have “traditionally” been considered to be in the public domain, and those that are required to be disclosed to the public – such as names and office telephone numbers of agency employees – can be released without waiting for an actual FOIA request.  Memorandum from Robert P. Bedell, Deputy Administrator, Office of Information and Regulatory Affairs, for the Senior Agency Officials for Information Resource Management, Privacy Act Guidance – Update (May 24, 1985) [hereinafter OMB Bedell Memo], https://www.justice.gov/pa​overview​_omb-85 (“Records which have traditionally been considered to be in the public domain and are required to be disclosed to the public, such as many of the final orders and opinions of quasi-judicial agencies, press releases, etc. may be released under this provision without waiting for a specific Freedom of Information Act request”); see also OMB Call Detail Guidance, https://www.justice.gov/paoverview_omb-87-cd (applying Bartel to “call detail” programs); OMB 1975 Guidelines, 40 Fed. Reg. at 28,954, https://www.justice.gov/paoverview_omb-75. The District Court for the District of Columbia twice has applied this public domain aspect of Bartel.  In Tripp v. DOD, 193 F. Supp. 2d 229, 236 (D.D.C. 2002), the D.C. District Court held that “the names, titles, salaries, and salary-levels of public employees are information generally in the public domain” and thus that they are not prohibited from disclosure under subsection (b)(2).  In Chang v. Navy, 314 F. Supp. 2d at 42, the District Court found that the Privacy Act was not violated where the Navy disclosed information to the media about plaintiff’s nonjudicial punishment, because the information was “releasable” under the FOIA, and the Navy had asserted that it “traditionally releases information that would be releasable under the FOIA to the press without a formal FOIA request,” and was able to point to a Navy regulation to that effect.  Id; see also Russo, 576 F. Supp. 2d at 670-73 (D.N.J. 2008) (alternative holding) (concluding disclosure of active duty military status did not violate Privacy Act because “duty status is the sort of public-domain information traditionally released to the public in the absence of a FOIA request”). For further analysis of the interplay between the FOIA and the Privacy Act, see “Individual’s Right of Access” section below, particularly the “FOIA/Privacy Act Interface Examples: Access” subsection.   3. 5 U.S.C. § 552a(b)(3) - Routine Uses “No agency shall disclose any record which is contained in a system of records by any means of communication to any person, or to another agency, except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains unless the disclosure would be -- . . . (3) for a routine use as defined in subsection (a)(7) of this section and described under subsection (e)(4)(D).”  5 U.S.C. § 552a(b)(3). Cross-references: Subsection (a)(7) defines the term “routine use” to mean “with respect to the disclosure of a record, the use of such record for a purpose which is compatible with the purpose for which it was collected.” Subsection (e)(4)(D) requires Federal Register publication of “each routine use of the records contained in the system, including the categories of users and the purpose of such use.” Comment: The routine use disclosure exception is broad and was designed to allow disclosures other than intra-agency disclosures. The routine use exception, because of its potential breadth, is one of the most controversial provisions in the Act.  See Privacy Commission Report, at 517-18, https://www.justice.gov/paoverview_ppsc.  The trend in recent cases is toward a narrower construction of the exception.  The White House directed the OMB to issue additional guidance regarding the routine use exception in an executive memorandum on privacy sent to the heads of executive departments and agencies in 1998.  Memorandum on Privacy and Personal Information in Federal Records, 34 Weekly Comp. Pres. Doc. 870 (May 14, 1998), https://www.justice.gov/paoverview

Continued... .... The courts have found, however, that a disclosure does not fall within a compatible routine use if the agency is not sharing with a law enforcement agency in the context of an investigation or prosecution, there is no possible violation of law, or the law enforcement agency head has not specifically requested the record in writing.  For example, a disclosure is not compatible if it is made to agencies other than the appropriate ones.  See Dick v. Holder, 67 F. Supp. 3d 167, 179 (D.D.C. 2014) (holding that FBI’s disclosure of information to law enforcement agencies was not compatible with routine use because information “was not disseminated just to ‘appropriate Federal, State, or local agenc[ies]’”). Similarly, disclosures are not compatible with a routine use if the record does not reveal a potential violation of law.  In Covert, 667 F. Supp. at 736-39, the District Court for the Eastern District of Washington held that a routine use permitting the Department of Energy’s Inspector General to disclose to the DOJ relevant records when “a record” indicates a potential violation of law did not permit the disclosure of personnel security questionnaires submitted by the plaintiffs because such questionnaires, on their face, did not reveal potential violations of law.  The court rejected the agency’s argument that disclosure was proper because each questionnaire was disclosed as part of a prosecutive report that (when viewed as a whole) did reveal a potential violation of law.  Id. at 736-37.  Further, the court found that the Inspector General’s disclosure of the questionnaires to the DOJ (for a criminal fraud prosecution) was not compatible with the purpose for which they originally were collected by the Department of Energy (for a security-clearance eligibility determination), notwithstanding the fact that the Inspector General subsequently acquired the questionnaires – on an intra-agency “need to know” basis pursuant to 5 U.S.C. § 552a(b)(1) – for the purpose of a fraud investigation.  Id. at 737-39. On cross-appeals, a divided panel of the Court of Appeals for the Ninth Circuit affirmed the district court’s judgment on other grounds.  Covert, 876 F.2d at 754-56.  The panel majority held that the Department of Energy’s failure to provide actual notice of the routine use on the questionnaires at the time of original collection, under subsection (e)(3)(C), precluded the Department of Energy from later invoking that routine use under subsection (b)(3).  Id. at 755-56; see also Puerta v. HHS, No. 99-55497, 2000 WL 863974, at *1-2 (9th Cir. June 28, 2000) (following Covert but finding that agency had provided notice of routine use on form used to collect information), aff’g No. EDCV 94-0148, slip op. at 7 (C.D. Cal. Jan. 5, 1999); USPS, 9 F.3d at 146 (citing Covert with approval and remanding case for factual determination as to whether subsection (e)(3)(C) notice was given); Stafford, 437 F. Supp. 2d at 1119-20 (adhering to Covert and finding that SSA notified plaintiff of potential uses “on three occasions when collecting her information,” even though these notifications were non-specific references to the Federal Register); Pontecorvo, No. 00-1511, slip op. at 12 (D.D.C. Sept. 30, 2001) (stating that agency must comply with subsection (e)(3)(C) “in order to substantiate an exception for ‘routine use’”).  Prior to Covert, no other court had required actual notice.  See the additional discussion under “5 U.S.C. § 552a(e)(3) - Notice Requirements,” below. Since Krohn v. DOJ, agencies have narrowed the scope of their routine use disclosures during legal proceedings, disclosing only records “arguably relevant to the litigation.” Although initially agencies published broad routine uses, they have been narrowed since the District Court for the District of Columbia issued its decision in Krohn v. DOJ, No. 78-1536, slip op. at 4-7 (D.D.C. Mar. 19, 1984).  In Krohn, the court invalidated an FBI routine use allowing for “dissemination [of records] during appropriate legal proceedings,” finding that such a routine use was impermissibly “vague” and was “capable of being construed so broadly as to encompass all legal proceedings.”  In response to Krohn, OMB issued guidance to agencies in which it suggested a model routine use – employing a “relevant and necessary to the litigation” standard – to permit the public filing of protected records with a court.  OMB Bedell Memo, https://www.justice​.gov/paoverview_omb-85.  Many agencies, including the DOJ, have adopted “post-Krohn” routine uses designed to authorize the public filing of relevant records in court.  See, e.g., 66 Fed. Reg. 36,593, 36,594 (July 12, 2001) (routine use [number 7] applicable to records in DOJ’s “Civil Division Case File System”); 63 Fed. Reg. 8,666, 8,667-68 (Feb. 20, 1998) (routine uses [letters “o” and “p”] applicable to records in U.S. Attorney’s Office’s “Civil Case Files”). The “post-Krohn” routine uses, such as the ones cited above that employ an “arguably relevant to the litigation” standard, have withstood challenges in the courts.  See, e.g., Jackson v. FBI, No. 02-C-3957, 2007 WL 2492069, at *8 (N.D. Ill. Aug. 28, 2007) (allowing U.S. Attorney’s filing in court of plaintiff’s unsuccessful application for FBI employment during pendency of plaintiff’s Title VII suit because application was “at the very heart of his civil suit”); Russell v. GSA, 935 F. Supp. 1142, 1145-46 (D. Colo. 1996) (finding disclosure in public pleadings of information regarding investigation of plaintiff was permissible under routine use providing for disclosure in proceeding before court where agency is party and records are determined “to be arguably relevant to the litigation”); Osborne v. USPS, No. 94-30353, slip op. at 6-9 (N.D. Fla. May 18, 1995) (holding on alternative ground that disclosure of plaintiff’s injury-compensation file to retired employee who had prepared file and who had been subpoenaed by plaintiff and was expecting to be deposed on matters documented in file was proper pursuant to routine use providing for disclosures “incident to litigation” and “in a proceeding before a court” because “deposition was a proceeding before [the] Court”); Sheptin v. DOJ, No. 91-2806, 1992 U.S. Dist. LEXIS 6221, at *6-7 (D.D.C. Apr. 30, 1992) (finding no wrongful disclosure where agency routine uses permit use of presentence report during course of habeas proceeding).  Such challenges could arise from an argument that the routine use does not satisfy the “compatibility” requirement of subsection (a)(7) of the Act, cf. Britt, 886 F.2d at 547-50 (holding mere “relevance” to recipient entity is improper standard for “compatible” routine use disclosure). Courts generally have held that routine use disclosures to further an investigation or enabled the receiving or disclosing agency to fulfill its mission are “compatible” disclosures under the routine use disclosure exception. The courts generally have found that disclosing information is pursuant to a compatible routine use when the information furthered an investigation or enabled either agency to fulfill its mission.  See, e.g., Taylor v. United States, 106 F.3d 833, 836-37 (8th Cir. 1997) (finding routine use exception applied to disclosure of federal taxpayer information collected for purpose of federal tax administration to state tax officials for purpose of state tax administration), aff’g Taylor v. IRS, 186 B.R. 441, 446-47, 453-54 (N.D. Iowa 1995); Alphin v. FAA, No. 89-2405, 1990 WL 52830, at *1 (4th Cir. Apr. 13, 1990) (finding routine use exception applied to disclosure of enforcement investigation final report to subject’s customers); Hastings v. Judicial Conference of the United States, 770 F.2d 1093, 1104 (D.C. Cir. 1985) (finding routine use exception applied to disclosure of criminal investigative records to judicial committee investigating judge); United States v. Miller, 643 F.2d 713, 715 (10th Cir. 1981) (determining that

Continued... .... 4. 5 U.S.C. § 552a(b)(4) - Bureau of the Census “No agency shall disclose any record which is contained in a system of records by any means of communication to any person, or to another agency, except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains unless the disclosure would be – . . . (4) to the Bureau of the Census for purposes of planning or carrying out a census or survey or related activity pursuant to the provisions of Title 13.”  5 U.S.C. § 552a(b)(4). Comment: For a discussion of this provision, see OMB 1975 Guidelines, 40 Fed. Reg. at 28,954, https://www.justice.gov/paoverview_omb-75.   5. 5 U.S.C. § 552a(b)(5) - Statistical Research “No agency shall disclose any record which is contained in a system of records by any means of communication to any person, or to another agency, except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains unless the disclosure would be – . . . (5) to a recipient who has provided the agency with advance adequate written assurance that the record will be used solely as a statistical research or reporting record, and the record is to be transferred in a form that is not individually identifiable.”  5 U.S.C. § 552a(b)(5). Comment: OMB guidelines suggest that the statistical research disclosure exception is intended to reduce the likelihood that agencies utilize statistical records to “reconstruct” individually identifiable records. The term “statistical record” is defined in the Act as a record that is not used in making individual determinations.  5 U.S.C. § 552a(a)(6).  One might question whether this exception to subsection (b) is anomalous, because the information to be released is arguably not a “record,” see 5 U.S.C. § 552a(a)(4), or a “disclosure,” see 5 U.S.C. § 552a(b), as it is not identifiable to any individual.  The OMB 1975 Guidelines, however, provide a plausible explanation, stating, “ne may infer from the legislative history and other portions of the Act that an objective of this provision is to reduce the possibility of matching and analysis of statistical records with other records to reconstruct individually identifiable records.” 40 Fed. Reg. at 28,954, https://www.justice.gov/paoverview_omb-75.   6. 5 U.S.C. § 552a(b)(6) - National Archives “No agency shall disclose any record which is contained in a system of records by any means of communication to any person, or to another agency, except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains unless the disclosure would be – . . . (6) to the National Archives and Records Administration as a record which has sufficient historical or other value to warrant its continued preservation by the United States Government, or for evaluation by the Archivist of the United States or the designee of the Archivist to determine whether the record has such value.”  5 U.S.C. § 552a(b)(6). Comment: For a discussion of this provision, see OMB 1975 Guidelines, 40 Fed. Reg. at 28,955, https://www.justice.gov/paoverview_omb-75.   7. 5 U.S.C. § 552a(b)(7) - Law Enforcement Request         “No agency shall disclose any record which is contained in a system of records …except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains, unless the disclosure would be— … (7) to another agency or to an instrumentality of any governmental jurisdiction within or under the control of the United States for a civil or criminal law enforcement activity if the activity is authorized by law, and if the head of the agency or instrumentality has made a written request to the agency which maintains the record specifying the particular portion desired and the law enforcement activity for which the record is sought.”  5 U.S.C. § 552a(b)(7). Comment: The law enforcement request disclosure exception allows certain disclosures, upon written request, to another agency or instrumentality for civil or criminal law enforcement purposes. This provision allows agencies to disclose records to federal law enforcement agencies and, “upon receipt of a written request, [to] disclose a record to another agency or unit of State or local government for a civil or criminal law enforcement activity.”  OMB 1975 Guidelines, 40 Fed. Reg. at 28,955, https://www.justice.gov/paoverview_omb-75. A request for records under the subsection (b)(7) exception must be for civil or criminal law enforcement purposes.  See United States v. Collins, 596 F.2d 166, 169 (6th Cir. 1979) (holding, among other reasons, disclosure of reports authored by someone suspected of fraud satisfied criminal law enforcement activity disclosure condition); SEC v. Dimensional Entm’t Corp., 518 F. Supp. 773, 774-75, 777 (S.D.N.Y. 1981) (finding disclosure was proper because SEC asked Parole Commission to release transcript in question for purpose of assisting SEC with its attempt to secure injunctive relief against defendant after SEC presented evidence that defendant will likely continue his unlawful activity). While the head of the agency or instrumentality must generally make the written request for the law enforcement request disclosure exception, agencies may, when necessary, delegate this responsibility to officials no lower than the “section chief” level. The request must be submitted in writing and generally must be from the head of the agency or instrumentality.  See Doe v. DiGenova, 779 F.2d 74, 85 (D.C. Cir. 1985) (concluding that VA’s disclosure of veteran’s medical records in response to federal grand jury subpoena was not authorized because federal grand jury subpoena is issued by federal prosecutors, not head of an agency); Doe v. Naval Air Station, 768 F.2d 1229, 1233 (11th Cir. 1985) (“[E]xemption (b)(7) requires a written request for disclosure by the head of the agency making such request to the agency which maintains the record.”); see also Reyes v. Supervisor of DEA, 834 F.2d 1093, 1095 (1st Cir. 1987) (noting the record lacked an indication that FBI, United States Probation Office, AUSA, and BOP made a written request for records); Stafford v. SSA, 437 F. Supp. 2d 1113, 1121 (N.D. Cal. 2006) (finding improper disclosure because head of local agency did not request disclosed information from SSA in writing). Record-requesting authority may be delegated to lower-level agency officials when necessary, but not below the “section chief” level.  The Department of Justice has delegated record-requesting authority to the “head of a component or a United States Attorney, or either’s designee.”  28 C.F.R. § 6.40(c) (2014); cf. Lora v. INS, No. 2:02cv756, 2002 WL 32488472, at *2 (E.D. Va. Oct. 8, 2002) (applying subsection (b)(7) to disclosure of information from INS file upon request from Assistant United States Attorney), aff’d per curiam, 61 F. App’x 80 (4th Cir. 2003).   8. 5 U.S.C. § 552a(b)( - Health or Safety of an Individual “No agency shall disclose any record which is contained in a system of records…except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains, unless the disclosure would be— … ( to a person pursuant to a showing of compelling circumstances affecting the health or safety of an individual if upon such disclosure notification is transmitted to the last known address of such individual.”  5 U.S.C. § 552a(b)(. Comment: Under this exception, agencies may disclose records under emergency conditions that affect an individual’s health or safety.  See Schwarz v. INTERPOL, No. 94-4111, 1995 WL 94664, at *1 n.3 (10th Cir. Feb. 28, 1995) (finding unsubstantiated allegations alone do not constitute “showing of compelling circumstances”); Stafford v. SSA, 437 F. Supp. 2d 1113, 1121 (N.D. Cal. 2006) (holding that SSA did not satisfy health and safety exception b

Quo Warranto, This means "By What Authority", the best way to understand this is when you look at an everyday Warrant Situation. The 4th Amendment says no Unreasonable Search and Seizure, this has been interpreted to mean that when there is an investigation and enough information has been gathered from Public Sources to go to a Judge abd say "We think there may be a [Specific Thing], in a [Specific Location], based on this Evidence", and the Judge can then sign a Warrant for that thing to be Observed or Taken, this includes the Seizure of Persons. Tennessee v. Garner is the case Police Cite to Justify Murder, it actually says that because the Officer in Tennessee Blew a Hole in a Young Black Man's head for stealing a purse from a House and Running away, that now the Courts will adopt a stance that was already happening in Federal Agencies, which was to no longer follow the practice that Felonies constitute in any way whatsoever a "Dead or Alive" Warrant on the action of the Felony, and because Midemeanors and Felonies are now so similar and Arbitrarily made, that it is now much different than it was in the days of Gunslinging and Saloon Gunfights (apart from like the occasional Biker shootout instigated by the FBI nowadays), so committing a Felony doesn't Warrant Death, but instead being a threat. So Tennessee v. Garner said that if a Violent Criminal is fleeing after an attack, there is a threat of bodily injury to others. So there is a question if force to be used now, and escalation, which at it's highest would be in response to someone running away with a gun in their hand. But that is why now we hear Police discussing Fear in Court, and being afraid that they would die, so they had to use force. Because that is the Standard. So if we look at the Day to Day Warrant Situation, we are seeing a Judge Approving a Specific thing in a Specific Place to be Legally Seized or Observed, and Seizure includes any action by the Government to restrain your ability to move, as in arrest or detainment or Death. When the Cop comes to your door, you say "Do you have Warrant", and they show a Warrant. That is a Quo Warranto situation. This is a Case where a Judicial Warrant was overturned for Broadness, it also can be illegal if it is a Malicious Warrant https://www.law.cornell.edu/supremecourt/text/10-704 MESSERSCHMIDT v. MILLENDER Shelly Kelly was afraid that she would be attacked by her boyfriend, Jerry Ray Bowen, while she moved out of her apartment. She therefore requested police protection. Two officers arrived, but they were called away to an emergency. As soon as the officers left, Bowen showed up at the apartment, yelled “I told you never to call the cops on me bitch!” and attacked Kelly, attempting to throw her over a second-story landing. After Kelly escaped to her car, Bowen pointed a sawed-off shotgun at her and threatened to kill her if she tried to leave. Kelly nonetheless sped away as Bowen fired five shots at the car, blowing out one of its tires... Messerschmidt included two affidavits in the warrant application. The first detailed his extensive law enforcement experience and his specialized training in gang-related crimes. The second, expressly incorporated into the search warrant, described the incident and ex plained why Messerschmidt believed there was probable cause for the search. It also requested that the warrant be endorsed for night service because of Bowen’s gang ties. Before submitting the application to a magistrate for approval, Messerschmidt had it reviewed by his supervisor, Sergeant Robert Lawrence, as well as a police lieutenant and a deputy district attorney. Messerschmidt then submitted the application to a magistrate, who issued the warrant. The ensuing search uncovered only Millender’s shotgun, a California Social Services letter addressed to Bowen, and a box of .45-caliber ammunition. When you file "Quo Warranto", you are just saying "Where is your Warrant", but not just in 4th Amendment situations. It means "By What Authority", and it can be filed against Companies, Agencies, etc, for them to prove by what legal Authority they are operating. This is also then used to Challenge Election Results, that is where you see it most now but it is not just for Elections. If we look at the FISA Court we can see a Good Example, I will text everyone how to file against FISA later in this thread. But the Rules are basically that the Warrants have to be renewed with new Info every 6 months, and only allows for Surveillance. It was made to watch Foreign Terrorist operations in America. We can best actually see the purpose of the Court in its History. First it was Established in the 70s because the FBI was doing way to much, what Tupac called "Beyond the call of duty" when the Police Officer beat him in the Street for J-Walking. The FBI was just doing too much, and was trying to get Black Panthers to argue and were generally stopping what was being called a Revolution. We can actually see this mindset of the FBI and how it is wrong if we first look at what was happening and what it meant. In the 60s there was the Black Panther Party for Self Defense, a Political Party. There was the Youth International Party, a Political Party associated with the "Up Against the Wall Motherfuckers", etc. The FBI was fighting the Formation of Political Parties, mainly in a McCarthyistic fight against Communist and Socialist Parties from forming.  This is what the FBI was doing, and then they also threw in the KKK for good measure so it wasn't Racist completely even though it was all Racial, even back to the Mobs and earlier. This was called COINTELPRO and they said they stopped doing it after that, and then said the hadn't been doing it long. But if you look at the Marcus Garvey FBI Vault, this is just what they do. The first Black FBI Agents became captain of, and crashed, the first Black Cruise Ship. But this thing they were fighting is called a "New Party System", which means New Political Parties entering the System. We can see this in the Prohibitionist Party, the early Federalists, and Whigs (who became the Republicans under Lincoln). So that's what was happening in the 60s, And the FBI stopped it, So the FISA Court was created to stop them from doing things like that in America ever again. But then came 9/11 and the Patriot Act, and the Freedom Act, all bolstered by Bill Clinton's CALEA, which made it a Law for Cell Phone companies to make Bugging a Phone and listening in, etc, as easy as flipping a switch. The Patriot Act was used: "To Protect us from Terror"... "But also Drug Cartels are kinda epic, so we need the Army and Navy and National Guard in the Drug War"... "And also we are investigating Trump"... "And don't you remember we beat Edward Snowden and everyone enjoys us watching them now" An SF-95, is how you declare the Government has Damaged you and prepare to sue under Federal Tort Law.

We will also be getting in to Texas Labor Laws and the CARES Act in this thread also. I did not enter my hearing for my 04-15-21 Ruling wondering "Oh dear, I really hope I am owed money, I really wish to get something", I called in after waiting almost half a year for a hearing, and PROVED to the Judge I was owed money. And he agreed that I should have been paid, and I have not yet been paid. I am not asking what can be gotten, I am telling everyone how Distribution of COVID Relief money was completely messed up.

According to news articles from credible sources published in 2021. Billions in COVID relief was lost to fraud. .... Its impossible to address this. Most don't follow current events closely enough to be aware things like this happen. Once the funds have been misallocated, there usually isn't a method to retrieve them or have them returned. Fraudsters typically reside in countries which do not extradite criminals to the USA to be prosecuted. Long story short, it is very hard to address this.

Texas did it more the opposite, They saw that happening and instead of taking your attitude that it was swindled, they decided that's what everyone was joining for. They blocked anyone not in a Payroll system, and then worked to put the Money in the Rainy Day Fund. It is very hard, but not impossible, luckily I have been at this since March 2020 and have detailed records if everything, and alerted Investigators all along. The Texas State Auditor has been Investigating for months. And so has the Federal GAO, and even the FBI. This is part of the January 6th Insurrection, Texas Government was actually busy trying to kill Mike Pence while I was creating Records. I was even already Investigating Ken Paxton and my Home Town before all of this

yah..  i call bs here.  when i see this amount of material combined with statments like "the government is forcing black females in to sex work"  what you have is conspiracy thinking at work.  and i might be wrong.   but im probably not.

If they continue not to pay everyone there will be Federal hearings. I will add Evidence now. Lots of links on the way. We have records of Everything. ---------- Forwarded message ---------- From: El Sasha <mahatmajapa@gmail.com> Date: Monday, June 7, 2021 Subject: Fwd: Texas is no Longer a Functioning State Re: TWC is Playing Games RE: LSC and LANWT have referred me to you To: "pbarkhurst@bhlawpc.com" <pbarkhurst@bhlawpc.com>, "will.bardwell@splcenter.org" <will.bardwell@splcenter.org>, "mjbarkermeyer@gmail.com" <mjbarkermeyer@gmail.com>, "mlb@longlaw.com" <mlb@longlaw.com>, "cbarbour@blswlaw.com" <cbarbour@blswlaw.com>, "dale@baringerlawfirm.com" <dale@baringerlawfirm.com>, "danahbarbos@gmail.com" <danahbarbos@gmail.com>, "smbarber@mc.edu" <smbarber@mc.edu>, "Brennan@ou.edu" <Brennan@ou.edu>, "barbier@laed.uscourts.gov" <barbier@laed.uscourts.gov>, "michellebarfieldlaw@yahoo.com" <michellebarfieldlaw@yahoo.com>, "brett.barfield@hklaw.com" <brett.barfield@hklaw.com>, "mfd@tcm.law" <mfd@tcm.law>, "denise.barnett@usdoj.gov" <denise.barnett@usdoj.gov>, "cbarnes@malsi.org" <cbarnes@malsi.org>, "jwbarnet@yahoo.com" <jwbarnet@yahoo.com>, "bbarnes@rctlegal.com" <bbarnes@rctlegal.com>, "abarnes@wileyrein.com" <abarnes@wileyrein.com>, "bbarnett@susmangodfrey.com" <bbarnett@susmangodfrey.com>, "tijuana.barnes@udc.edu" <tijuana.barnes@udc.edu>, "marialyn.barnard@gmail.com" <marialyn.barnard@gmail.com>, "sajbarnes@comcast.net" <sajbarnes@comcast.net>, "sbarnes@fdh.com" <sbarnes@fdh.com>, "david.barlow@davidwbarlow.com" <david.barlow@davidwbarlow.com>, "roy@barneslawgroup.com" <roy@barneslawgroup.com>, "abarlow@kuchlerpolk.com" <abarlow@kuchlerpolk.com>, "jmbarne1@go.olemiss.edu" <jmbarne1@go.olemiss.edu>, "ronald.barliant@goldbergkohn.com" <ronald.barliant@goldbergkohn.com>, "hbarnes@allenbarneslaw.com" <hbarnes@allenbarneslaw.com>, "patrick@barkmanlawyer.com" <patrick@barkmanlawyer.com>, "crystal.barnes16@stjohns.edu" <crystal.barnes16@stjohns.edu>, "lbarkley@jeffersoncano.com" <lbarkley@jeffersoncano.com>, "barousse@bornewilkes.com" <barousse@bornewilkes.com>, "bobbybarrealaw@gmail.com" <bobbybarrealaw@gmail.com>, "EBARRERA@mmlk.com" <EBARRERA@mmlk.com>, "mtrowbridge@phjlaw.com" <mtrowbridge@phjlaw.com>, "neil@ngbaronlaw.com" <neil@ngbaronlaw.com>, "ibarras@iplawconsulting.com" <ibarras@iplawconsulting.com>, "pbb@pbarnettlaw.com" <pbb@pbarnettlaw.com>, "brooke@longlaw.com" <brooke@longlaw.com>, "lbarquist@boginmunns.com" <lbarquist@boginmunns.com>, "jeb61fulton@aol.com" <jeb61fulton@aol.com>, "jbartholomew@barneslawgroup.com" <jbartholomew@barneslawgroup.com>, "bbartholomew@sessions.legal" <bbartholomew@sessions.legal>, "dbarrios@bkc-law.com" <dbarrios@bkc-law.com>, "pcb@decof.com" <pcb@decof.com>, "bbarriere@fishmanhaygood.com" <bbarriere@fishmanhaygood.com>, "abarriere@huberslack.com" <abarriere@huberslack.com>, "fbarry@dkslaw.com" <fbarry@dkslaw.com>, "kbarrettwiik@bestlaw.com" <kbarrettwiik@bestlaw.com>, "lee@bcrlaw.net" <lee@bcrlaw.net>, "hbarrow@andrewsmyers.com" <hbarrow@andrewsmyers.com>, "barrett_chambers@ohsd.uscourts.gov" <barrett_chambers@ohsd.uscourts.gov>, "abarrett@haganbarrett.com" <abarrett@haganbarrett.com>, "ebarron@wtplaw.com" <ebarron@wtplaw.com>, "attorneys@thebartonlawfirm.com" <attorneys@thebartonlawfirm.com>, "rbarton@hfblaw.com" <rbarton@hfblaw.com>, "aeb@ccbattorneys.com" <aeb@ccbattorneys.com>, "bob.barton@taylorporter.com" <bob.barton@taylorporter.com>, "jtbarton@mix.wvu.edu" <jtbarton@mix.wvu.edu>, "emadisonwalker@gmail.com" <emadisonwalker@gmail.com>, "mbartley@uscourts.cavc.gov" <mbartley@uscourts.cavc.gov>, "kbartsch@ahn-law.com" <kbartsch@ahn-law.com>, "dbartlett@erisgrp.com" <dbartlett@erisgrp.com>, "eric.bartsch@stoel.com" <eric.bartsch@stoel.com>, "brad@mcallistergarfield.com" <brad@mcallistergarfield.com>, "wbauer@mail.stmarytx.edu" <wbauer@mail.stmarytx.edu>, "william.bates@farrar-bates.com" <william.bates@farrar-bates.com>, "ernie@ernestbauerlaw.com" <ernie@ernestbauerlaw.com>, "jgbates@phillipsmurrah.com" <jgbates@phillipsmurrah.com>, "rbaudouin@krebsfarley.com" <rbaudouin@krebsfarley.com>, "jbates@bakerlaw.com" <jbates@bakerlaw.com>, "wbaudoin@dartt.biz" <wbaudoin@dartt.biz>, "attorneybaten@gmail.com" <attorneybaten@gmail.com>, "kbattle@mokblaw.com" <kbattle@mokblaw.com>, "meredith.bateman@klgates.com" <meredith.bateman@klgates.com>, "mbateman@schiffhardin.com" <mbateman@schiffhardin.com>, "taylorb@mmrblaw.com" <taylorb@mmrblaw.com>, "sbassett@mbfc.com" <sbassett@mbfc.com>, "ana.batista@upr.edu" <ana.batista@upr.edu>, "fbassett@ndnlaw.com" <fbassett@ndnlaw.com>, "simeonhb@disputeresolve.com" <simeonhb@disputeresolve.com>, "sbaxter@mckoolsmith.com" <sbaxter@mckoolsmith.com>, "jebaxley@deloitte.com" <jebaxley@deloitte.com>, "rudy@boslaw.com" <rudy@boslaw.com>, "david.baum@alston.com" <david.baum@alston.com>, "ambautis@my.loyno.edu" <ambautis@my.loyno.edu>, "Suzanne_Bauknight@tneb.uscourts.gov" <Suzanne_Bauknight@tneb.uscourts.gov>, "bbauges@cu-portland.edu" <bbauges@cu-portland.edu>, "abauermeister@sbgblaw.com" <abauermeister@sbgblaw.com>, "william_bauer@ca7.uscourts.gov" <william_bauer@ca7.uscourts.gov>, "tbeach@wtplaw.com" <tbeach@wtplaw.com>, "beattycn@mail.uc.edu" <beattycn@mail.uc.edu>, "pinksalmon007@gmail.com" <pinksalmon007@gmail.com>, "Dbeach@beach-oswald.com" <Dbeach@beach-oswald.com>, "beasley@beasleylaw.net" <beasley@beasleylaw.net>, "lisa_bertinobeaser@nywb.uscourts.gov" <lisa_bertinobeaser@nywb.uscourts.gov>, "jbazile@glennarmentor.com" <jbazile@glennarmentor.com>, "barbara.bearnson@usdoj.gov" <barbara.bearnson@usdoj.gov>, "damonb@townsleylawfirm.com" <damonb@townsleylawfirm.com>, "abb@legalhawaii.com" <abb@legalhawaii.com>, "tjb@federmanlaw.com" <tjb@federmanlaw.com>, "ajbaynham@liskow.com" <ajbaynham@liskow.com>, "tbfg33@gmail.com" <tbfg33@gmail.com>, "kbbecker@liskow.com" <kbbecker@liskow.com>, "jackie.bechara@gmail.com" <jackie.bechara@gmail.com>, "bryon.becker@bakerbotts.com" <bryon.becker@bakerbotts.com>, "npbebov2002@yahoo.co.uk" <npbebov2002@yahoo.co.uk>, "bbecker938@aol.com" <bbecker938@aol.com>, "jamie@freetothrive.org" <jamie@freetothrive.org>, "abeaumont@perkinscoie.com" <abeaumont@perkinscoie.com>, "bbeauman@sturgillturner.com" <bbeauman@sturgillturner.com>, "rbeaulieu@mcguirewoods.com" <rbeaulieu@mcguirewoods.com>, "dbeck@beckredden.com" <dbeck@beckredden.com>, "pbeauchamp.law@gmail.com" <pbeauchamp.law@gmail.com>, "tim@bechtoldlaw.net" <tim@bechtoldlaw.net>, "judge_beaty@ncmd.uscourts.gov" <judge_beaty@ncmd.uscourts.gov>, "zachschanaron@gmail.com" <zachschanaron@gmail.com>, "lelandbegay@utemountain.org" <lelandbegay@utemountain.org>, "jeremyrbedford@gmail.com" <jeremyrbedford@gmail.com>, "bjb184@law.miami.edu" <bjb184@law.miami.edu>, "sandra_beckwith@ohsd.uscourts.gov" <sandra_beckwith@ohsd.uscourts.gov>, "pbeers@glennfeldmann.com" <pbeers@glennfeldmann.com>, "mike.beers@bultersnow.com" <mike.beers@bultersnow.com>, "michele.beckwith@usdoj.gov" <michele.beckwith@usdoj.gov>, "BBeers@beerslaw.net" <BBeers@beerslaw.net>, "beckwithj1989@gmail.com" <beckwithj1989@gmail.com>, "kbeckman@pipesmiles.com" <kbeckman@pipesmiles.com>, "Laurel_beeler@cand.uscourts.gov" <Laurel_beeler@cand.uscourts.gov>, "ab3448@mynsu.nova.edu" <ab3448@mynsu.nova.edu>, "ryan.beckett@butlersnow.com" <ryan.beckett@butlersnow.com>, "tjb3@beedemlaw.com" <tjb3@beedemlaw.com>, "stacie.beckerman@ord.uscourts.gov" <stacie.beckerman@ord.uscourts.gov>, "becker@chaffe.com" <becker@chaffe.com>, "mark.beebe@arlaw.com" <mark.beebe@arlaw.com>, "rbecker7@mail.stmarytx.edu" <rbecker7@mail.stmarytx.edu>, "acaciabellamy@gmail.com" <acaciabellamy@gmail.com>, "jbelkarce@yahoo.com" <jbelkarce@yahoo.com>, "ebelin@provostylaw.com" <ebelin@provostylaw.com>, "cbell@carltonfields.com" <cbell@carltonfields.com>, "tbell@irwinllc.com" <tbell@irwinllc.com>, "alfred.belcuore@belcuorelaw.com" <alfred.belcuore@belcuorelaw.com>, "rbell@mhba.com" <rbell@mhba.com>, "andre@manassehandgill.com" <andre@manassehandgill.com>, "nbell@my.loyno.edu" <nbell@my.loyn

I think this is not just in Texas but all around the world. Many people in any government, monarch, or any type of government are using the supposed funds for certain types of events, like the pandemic, to their pockets. Indeed, many people have died to prevent the stopping of that kind of operation. Is there even a way to stop all of this corruption?

I will continue to post Evidence and everything about the Labor Law, and Evidence that Money is being Withheld, and we can get into Ken Paxton and Collin County, And we will be getting deep into Law in this thread, But I want to point out here that thid skepticism express ed that I "might be wrong", and it "seems like conspiracy talk", that is very tame for the internet. So I just want to say for the benefit of the reader now, so it does not become derailed, this is not a crazy challenge to me compared to most of the internet to everything else on the internet. There is probably a lot going on everywhere. We have the IACHR, check for your counterpart and start getting on record. There are hearings also so you can find the date by looking for the meeting dates and signing up. So we can start to get ths discussed, I'll get a video now. https://www.corteidh.or.cr/como_acceder_al_sistema.cfm?lang=en I can help people file cases and Writs in their Country. I want everyone to start cases about things who need to. I am filing Ethics stuff and everything. I have financial records on Judges, and I have records of the DEA watching me instead of Granting Exemption, the being part of the Colombia part of this. The NSA and FBI have records of me, there are places called like NSA CCS, or CSS centers. And I wrote a Protest guide like 6 years ago before Ferguson, maybe more than 6. I left Texas to go to Colorado on a FAFSA for a Semester in 2017, I was my Mom's house for a week, and FBI agents came to ask if I wanted to start a Revolution.

This case shows how Attainder works, Board of Medical Examiners v. Nzedu, 228 S.W.3d 264 (Tex. App. 2007) https://www.courtlistener.com/opinion/2357115/board-of-medical-examiners-v-nzedu/ Scientology in Court United States v. ARTICLE OR DEVICE, ETC., 333 F. Supp. 357 (D.D.C. 1971) The Drug Enforcement Agency has confirmed it is investigating a wild night in Rotterdam, in which sources say an agent drank too much, stripped naked, pooped on the door of another agent’s hotel room — yet avoided arrest. https://www.washingtonexaminer.com/opinion/dea-agent-strips-naked-defecates-in-front-of-another-agents-hotel-room-sources-say https://thehill.com/homenews/news/541551-dea-suspends-agent-seen-outside-capitol-during-riot https://buffalonews.com/news/local/crime-and-courts/pharoahs-owner-charged-with-bribing-dea-agent-as-feds-investigate-buffalo-mafia/article_6d9d428e-7abc-11eb-b85d-fbc423a29063.html https://abcnews.go.com/Politics/wireStory/standout-dea-agent-conspired-drug-cartel-73010095 https://abcnews.go.com/US/wireStory/retired-dea-agents-agency-legacy-discrimination-71326557 https://www.nola.com/news/courts/article_0fc2a2a2-13de-11eb-8aed-b30e74bdb80f.amp.html https://sanangelolive.com/news/crime/2020-09-11/former-dea-agent-arrested-attempting-sell-massive-amount-cocaine https://www.theguardian.com/world/2020/dec/15/mexico-security-law-dea-agents-us https://www.live5news.com/2020/05/01/ap-dea-agent-accused-stealing-ppe-agency-warehouse/ Cooper v. Pate, 378 US 545 (1964); Mustafaa v. Dutton, 958 F 2d 372 (6th Cir 1992); Africa v. Commonwealth, 662 F2d 1025 (3rd Cir 1981); Utah v. Mooney, 20010787 (2004 UT 49); Olsen V DEA 878 F.2d 1458 (1989); Washington v. Sessions, et al 1:17-cv-05625; MARK PERKEL v. US DOJ, DEA 08-74457 (2009) We are suing Texas for Slander, Cruel and Unusual Homeless Punishment, and a Class Action for IDme issues, and Facebook's behavior together with the Texas Tea Party QAnon-ers Gang Injunctions needed, Particularly in Texas https://m.facebook.com/123488374379680/posts/3698658190195996/ Pastor Jeffers is basically the Original QAnonShaman, and Ken Paxton along with Sydney Powell made Trump think the other States and SCOTUS were stealing from him. The article in the link is from the below lawyer's friend, and it is about how much poor people love going to court with no lawyers. I had the LSC and DOJ look at this and the FBI is investigating. 1 Attorney: https://www.cowlesthompson.com/index.php?section=news-and-events&prrid=214&catid=2 His partner in Law: 2010-06-07 slc - Kirsten Clanton IMG_0884_175x150.pngKirsten Anderson -  Litigation Director       Pronouns: She, her, hers   Ms. Anderson joined Southern Legal Counsel in 2007 as a staff attorney and became the organization's Litigation Director in 2016.  She litigates complex civil rights cases in state and federal trial and appellate courts and in administrative forums.  Since 2007, she has directed SLC's Ending Homelessness Project which utilizes litigation, policy advocacy, community education and outreach to remove legal barriers to ending homelessness.  She is a frequently invited speaker on social justice issues, particularly on the civil and human rights of homeless individuals. Ms. Anderson is a member of The Florida Bar, and the bars of the U.S. Middle, Southern and Northern District Courts of Florida and the Eleventh Circuit Court of Appeals. She is a Past Chair of the Public Interest Law Section (PILS) of The Florida Bar and is a past chair of the PILS Committee on Homelessness.  Prior to joining SLC, she worked as an associate at a private law firm specializing in immigration and nationality law. Ms. Anderson received her J.D. with honors (2005); M.A. in Latin American Studies (2005); and B.A. in Spanish with honors (2001), all from the University of Florida. In 2009, she received the Outstanding Young Alumnus Award from the University of Florida Alumni Association. On Sunday, May 9, 2021, Sasha Gallagher <wearemckinneytexas@gmail.com> wrote: And I work for a Tyler Technologies competitor btw. Part of this is Ken Paxton and others stealing Trade Secrets. I'm not some bum off the street. On Thursday, May 6, 2021, Sasha Gallagher <wearemckinneytexas@gmail.com> wrote: This is the Criminal Investigation into Bob Davis, but his office is not in McKinney, it is in Richardson/Dallas. ---------- Forwarded message ---------- From: Sasha Gallagher <wearemckinneytexas@gmail.com> Date: Monday, April 12, 2021 Subject: Re: Collin County Police Report #20023116 To: "ragan@mckinneytexas.org" <ragan@mckinneytexas.org>, "jbrownrigg@co.collin.tx.us" <jbrownrigg@co.collin.tx.us>, "sasher@collincountytx.gov" <sasher@collincountytx.gov>, "ahatch@co.collin.tx.us" <ahatch@co.collin.tx.us>, "mselman@collincountytx.gov" <mselman@collincountytx.gov>, "pcundiff@collincountytx.gov" <pcundiff@collincountytx.gov>, "mlangan@collincountytx.gov" <mlangan@collincountytx.gov> Greg Abbott lied to the FBI 11 years ago to put her in Jail https://mobile.twitter.com/taygoldenstein/status/1375077428557664258 On Monday, April 6, 2020, Sasha Gallagher <wearemckinneytexas@gmail.com> wrote: The Transcript from Jan 23rd is now being demanded by a 5th COA Judge in the Dallas appeals court. Please review Andrew Hatch's error, because it will be laid plain in Court soon and I would like the Police to be accurate. On Tuesday, April 27, 2021, Sasha Gallagher <wearemckinneytexas@gmail.com> wrote: ---------- Forwarded message ---------- From: Sasha Gallagher <wearemckinneytexas@gmail.com> Date: Thursday, May 28, 2020 Subject: Collin County To: "const4@collincountytx.gov" <const4@collincountytx.gov>, "const3@collincountytx.gov" <const3@collincountytx.gov>, "const2@collincountytx.gov" <const2@collincountytx.gov>, "const1@collincountytx.gov" <const1@collincountytx.gov> I personally had never thought of Collin County as a particularly corrupt place, until my experience with Kerrie Walker. In 2010 I wanted to explain my Religion in Court, to explain how the Collin County Police and Narcotics Sergeant came to my house with no warrant, broke in after looking through the front door window and seeing me walk upstairs, then arresting me for having Religious Materials. My first attorney wouldn't let me use a Religious Defense and I still didn't assume it was corrupt, so I asked him to remove himself from my case and he wrote a nasty letter to the Judge. Then, Kerrie Walker was my Public Defender, and because of her actions on my case I fled the state to go learn about my Rights. I still didn't necessarily assume corruption. After I left, there was a Scandal with a City Manager firing the Police Cheif on YouTube and inventing high paying jobs for his friends Jason Gray http://www.dallasnews.com/news/community-news/mckinney/headlines/20140225-embattled-mckinney-city-manager-jason-gray-resigns1.ece Jason Cooley Ty Lake Joe Williams Todd Philips Cheree Bontrager Geralyn Kever Then, upon my return in 2015 and reading my 2010 Court documents, I started Googling Kerrie Walker and learned about her Resignation from the CCDAO, and then by that time she had also let her Bar License expire, meaning she was no longer an Attorney. This was a very small instance of Corruption involving 2 people. You could even say in a sense that Kerrie is herself a Victim of the Corruption of Collin County and she was just "doing what everyone was doing". Kerrie Walker Curtis Howard (former FBI Agent) https://www.dallasnews.com/news/watchdog/2009/11/02/hot-links-why-was-collin-dwi-case-aborted/ I then began to look a little deeper, it was 2015/16. So I starting Googling and found that Rick Perry was under pressure for abuse of office. And he may not have explicitly abused his office there, but the instance shows the attitude of Texas Politicians. http://www.statutes.legis.state.tx.us/docs/PE/htm/PE.39.htm https://en.m.wikipedia.org/wiki/Rick_Perry_veto_controversy Rick Perry Kirk Watson Mary Ann Wiley David L Botsford

If you were a Wheless, you could use your PFS in Federal Court to File IFP. Meaning they claim to have no assets or income. They could get a Free court case, no filing fee https://www.scribd.com/document/465247305/Wheless-Personal-Financial-Statement https://www.scribd.com/document/445086192/Judge-Cynthia-Wheless-Recusal-Petition-to-Human-Rights-IACHR-OAS-Rev-Ryan-Sasha-Shai-van-Kush https://www.scribd.com/document/465247986/Cynthia-Cindy-Wheless-Personal-Financial-Statement Thomas Jefferson Notes on Virginia http://docsouth.unc.edu/southlit/jefferson/jefferson.html "Great numbers of French, of English, and of Americans, are perfectly acquainted with these people. Had he had an opportunity of enquiring of any of these, they would have told him, that there never was an instance known of an Indian begging his life when in the power of his enemies: on the contrary, that he courts death by every possible insult and provocation. His reasoning then would have been reversed thus. 'Since the present Indian of North America is brave, and authors tell us, that the ancestors of those of South America were brave also; it must follow, that the cowardice of their descendants is the effect of subjugation and ill treatment.' For he observes, ib. §. 27. that 'los obrages los aniquilan por la inhumanidad con que se les trata.' that in other situations also he meets death with more deliberation, and endures tortures with a firmness unknown almost to religious enthusiasm with us: that he is affectionate to his children, careful of them, and indulgent in the extreme: that his affections comprehend his other connections, weakening, as with us, from circle to circle, as they recede from the center: that his friendships are strong and faithful to the uttermost† extremity: A remarkable instance of this appeared in the case of the late Col. Byrd, who was sent to the Cherokee nation to transact some business with them. It happened that some of our disorderly people had just killed one or two of that nation. It was therefore proposed in the council of the Cherokees that Col. Byrd should be put to death, in revenge for the loss of their countrymen. Among them was a chief called Silòuee, who, on some former occasion, had contracted an acquaintance and friendship with Col. Byrd. He came to him every night in his tent, and told him not to be afraid, they should not kill him. After many days deliberation, however, the determination was, contrary to Silòuee's expectation, that Byrd should be put to death, and some warriors were dispatched as executioners. Silòuee attended them, and when they entered the tent, he threw himself between them and Byrd, and said to the warriors, 'this man is my friend: before you get at him, you must kill me.' On which they returned, and the council respected the principle so much as to recede from their determination.

And btw, Part of this is literally Polish Judges who are using Polish and Eastern European Hackers to say that is like us, because we are teaching people to use Bitcoin and asking for our money. Actively and Effectively stopping us from Feeding various Economies. This is not just a Byproduct of their actions, but a very central part of it. Against me in particular. I'm building a Blockchain Beauty Economy with my Wife. The FBI started this against me because I wrote Protest Guides, made Crowd unControl tutorials, while talking to the New Black Panthers, the Moors, the Nation of Islam, etc, and then Ferguson happened. A lot of people at this event were there because of me, and I still have a lot of people waiting for me to Organize them https://www.denverpost.com/2013/04/22/denver-police-420-shooting-followed-argument-between-gang-rivals/ http://www.famous-trials.com/chicago8/1326-hoffman New Black Panthers https://en.wikipedia.org/wiki/New_Black_Panther_Party_voter_intimidation_case BIEs https://www.nytimes.com/2017/11/15/opinion/black-identity-extremism-fbi-trump.html And this thread is going to get into some of the stuff we are talking about as far as Slavery Human Trafficking, I will get into that next. Because Game is not harmless in all situations, We are talking about Pimps and Women in Slavery. There are Escorts, Strippers, CamGirls, Call Girls, Back Page type Prostitutes, then there are like Groupies, etc, etc. And there is a system of Slavery involved in what is going on with Pimping, not all of it is Slavery, but it's there. The show "For my Man" is kind of a good start. And it feeds itself, like there are intentions of just like Freedom when people write songs about Gang stuff and everything, but there are people who are hardly involved in anything and even who are, doing stupid things because they started doing a few things, got caught up with someone else's Wife or Man, and now feel like the person being cheated on isn't even Human, like a Rodent or Roach, and same with the Cheater, like "I'll take that Blowjob, Skank; and when I take some shit you can't tell your husband where it went". Understanding all this can put a whole new perspective in Forensic Files, etc.