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RE: FOIA Request #CFPB-2012-129-F October 4, 2012 Ms.

Lisette Garcia Judicial Watch 425 Third Street SW, Suite 800 Washington, DC 20024 Dear Ms. Garcia: This letter is in final response to your Freedom of Information Act (FOIA) request dated April 4, 2012. Your request sought 1) All communications with or about St. Paul, Minnesota, its residents, landlords, low-income properties or employees, specifically those exchanges; a.) relating to the city's recent petition for certiorari to the U.S. Supreme Court, including the petition's withdrawal in February 2012; b.) regarding "disparate impact" theory or analysis in the housing, landlord-tenant, or mortgage arena; c.) involving any member of the U.S. Senate's Democratic Policy & Communications Committee, the House Democratic Caucus, or the White House, and their respective staffs; and, d.) involving third parties such as the National Low Income Housing Coalition, Thomas Goldstein, or Walter Mondale and their respective staffs; 2. All invoices for travel, food, lodging, communications, or entertainment expenses incurred in connection with any "disparate impact" lawsuit brought against St Paul, Minnesota. The timeframe for this request is February 11, 2010, through the present. A search of the Legal and Supervision, Enforcement, and Fair Lending Divisions for documents responsive to your request produced a total of 1,342 pages. Of those pages, I have determined that 473 pages of the records are granted in full, 2 pages are granted in part, and 867 pages are withheld in full pursuant to Title 5 U.S.C. 552 (b)(5) and (b)(6). A search of the Office of the Chief Financial Officer for documents responsive to your request for invoices for travel, food, lodging, communications, or entertainment expenses incurred in connection with any "disparate impact" lawsuit brought against St Paul, Minnesota produced no records. FOIA Exemption 5 protects from disclosure those inter- or intra-agency documents that are normally privileged in the civil discovery context. After carefully reviewing the responsive documents, I determined that [portions of] the responsive documents qualify for protection under the deliberative process, attorney work-product, and attorney-client privileges. Most of these materials included draft legal briefs. FOIA Exemption 6 exempts from disclosure personnel or medical files and similar files the release of which would cause a clearly unwarranted invasion of personal privacy. This requires a

balancing of the publics right to disclosure against the individuals right to privacy. The types of documents and/or information that we have withheld may consist of home addresses, personal or mobile phone numbers, or other information belonging to a third party that are considered personal. The privacy interests of the individuals in the records you have requested outweigh any minimal public interest in disclosure of the information. Any private interest you may have in that information does not factor into the aforementioned balancing test. You may appeal any of the responses or decisions set forth above. If you choose to file an appeal, you must do so within 45 calendar days from the date of this letter. Your appeal must be in writing, signed by you or your representative, and should contain the rationale for the appeal. You may send your appeal via the mail (address below), email (CFPB_FOIA@cfpb.gov) or fax (1-855-FAX-FOIA (329-3642)). Your appeal should be addressed to: Consumer Financial Protection Bureau Attention: Chief FOIA Officer Freedom of Information Appeal 1700 G Street, NW Washington, D.C. 20552 An additional 349 pages have been referred to the below agency for processing and direct response to you. Their contact information is listed below: U.S. Department of Justice Civil Rights Division BICN Bldg., Room 3219B 950 Pennsylvania Avenue, NW Washington, DC 20530 Telephone: (202) 414-4209 Email: CRT.FOIArequests@usdoj.gov For inquiries concerning your request, please contact Laura Magere, by phone at 202-435-7907 and reference the FOIA request number above. If you are unable to reach Ms. Magere, please feel free to contact CFPBs FOIA Service Center by email at CFPB_FOIA@cfpb.gov or by telephone at 1-855-444-FOIA (3642). Sincerely,

Martin Michalosky FOIA Manager Operations Division