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Respectfully submitted,
s/Brian W. Toth
Sanford L. Bohrer
Florida Bar No. 160643
sbohrer@hklaw.com
Brian W. Toth
Florida Bar No. 57708
brian.toth@hklaw.com
HOLLAND & KNIGHT LLP
701 Brickell Avenue, Suite 3300
Miami, Florida 33131
Telephone: (305) 374-8500
Fax: (305) 789-7799
and
EXHIBIT 1
From:
To:
Cc:
Subject:
Date:
Ms. Handman we are unable to provide the documents you request at this time, as requests to the
FBI for documents in connection with civil litigation must be made in accordance with DOJs Touhy
regulations, 28 CFR 16.21 et seq. Also, to the extent that any documents you request are covered
by the Privacy Act, 5 USC 552a, you would need to provide us with a waiver, court order, or other
basis for production consistent with the Privacy Act.
I can tell you that the FBI sent Mr. Klayman an email on October 1, 2015, asking for more
information and clarification in response to an email he sent on September 24, 2015. The FBI has no
objection to Mr. Klayman providing you a copy of that email exchange or the other documents that
you seek.
Ted Schwartz
Mr. Klayman attached please find a 9/8/15 letter to you from FBI General Counsel James Baker.
It would be most efficient if you would provide the information requested in the attached letter to
Associate Division Counsel Edward Williams via email at Edward.WilliamsWFO@ic.fbi.gov. The
facsimile number is 202-278-2658 and the mailing address is:
Thank you,
Ted Schwartz
Assistant General Counsel
Civil Litigation Unit I, OGC
FBI
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