Negley vs FBI

Civil Action No. SA-12-CV-362 (OG)

Court Records

Plaintiff's Complaint for Relief (filed April 18, 2012) PDF

Defendant’s Answer (filed May 23, 2012) PDF

Plaintiff’s First Requests for Admissions and Requests for Production to Defendant Federal Bureau of Investigation (filed August 10, 2012) PDF

FBI Motion for Protective Order (filed September 12, 2012) PDF
FBI Motion for Protective Order, Exhibit 1 PDF
FBI Motion for Protective Order, Exhibit 2 PDF
FBI Motion for Protective Order, Exhibit 3 PDF
FBI Motion for Protective Order, Exhibit 4 PDF
FBI Motion for Protective Order, Exhibit 5 PDF
FBI Motion for Protective Order, Exhibit 6 PDF

Plaintiff’s Response to Defendant’s Motion for Protective Order (filed October 5, 2012) PDF
Exhibit A PDF

Order on Motion for Protective Order PDF

Plaintiff’s Motion for Leave to File Sur-Reply to Defendant’s Reply to Response to Motion for Protective Order (filed October 17, 2012) PDF

Defendant’s Response in Opposition to Plaintiff’s Motion for Leave to File Sur-Reply (filed October 17, 2012) PDF

Court Order Granting Protective Order (filed February 14, 2013) PDF

Plaintiff’s Motion for Reconsideration of Order Granting Defendant’s Motion for Protective Order (filed April 4, 2013) PDF

Defendant’s Unopposed Motion for 14-Day Extension of Time to Respond to Plaintiff’s Motion for Reconsideration and to File Defendant’s Motion for Summary Judgment (filed April 22, 2013) PDF

Defendant's Response to Plaintiff's Motion for Reconsideration (filed May 6, 2013) PDF
Defendant's Response to Plaintiff's Motion for Reconsideration, Exhibit 1
Defendant's Response to Plaintiff's Motion for Reconsideration, Exhibit 2
Defendant's Response to Plaintiff's Motion for Reconsideration, Exhibit 3

Defendant's Motion for Leave to Submit Sur-Response Regarding Plaintiff's Motion for Reconsideration (filed May 21, 2013) PDF

Defendant's Sur-Reponse to Plaintiff's Motion for Reconsideration (filed May 21, 2013) PDF

Plaintiff's Response to Motion for Summary Judgement (filed June 5, 2013) PDF
Plaintiff's Response to Motion for Summary Judgement, Exhibit A
Plaintiff's Response to Motion for Summary Judgement, Exhibit B
Plaintiff's Response to Motion for Summary Judgement, Exhibit C
Plaintiff's Response to Motion for Summary Judgement, Exhibit D
Plaintiff's Response to Motion for Summary Judgement, Exhibit E

Reply in Support of Defendant's Motion for Summary Judgment (filed June 17, 2013) PDF
Reply in Support of Defendant's Motion for Summary Judgment - Exhibit PDF

Plaintiff's Motion for Leave to File Sur-Reply to Defendant's Reply to Response to Motion for Summary Judgment (filed July 23, 2013) PDF

Plaintiff's Sur-Reply to Defendant's Reply to Response to Motion for Protective Order (filed July 23, 2013) PDF
Sur-Reply Exhibit A
Sur-Reply Exhibit B
Sur-Reply Exhibit C

Order Granting Summary Judgment (filed July 31, 2013) (PDF)

Order on Motion for Attorney Fees (filed August 21, 2013) (PDF)

Notice of Appeal (filed September 27, 2013) (PDF)

Brief for Appellant in the United States Court of Appeals for the Fifth Circuit (filed December 16, 2013) (PDF)

Brief for Appellee in the United States Court of Appeals for the Fifth Circuit (filed February 20, 2014) (PDF)

Brief in Reply to the Response of the Federal Bureau of Investigation (filed March 20, 2014) (PDF)

Petition for Writ of Certiorari to the United States Court of Appeals for the Fifth Circuit (filed January 30, 2015) (PDF)

Letter to John F. Carroll from the Supreme Court of the United States Denying the Petition for a Writ of Certiorari (dated March 30, 2015) (PDF)



Declarations of David M. Hardy

Declaration of David M. Hardy (dated May 6, 2013) PDF

Declarations of John F. Boseker

Declaration of John F. Boseker (dated May 3, 2013) PDF

Deposition of Agent Clifford C. Holly

Deposition of Agent Clifford C. Holly, Exhibit C of Plaintiff's Sur-Reply to Defendant's Reply to Response to Motion for Protective Order (filed July 23, 2013) PDF

Correspondence

Letter to John F. Carroll from Robert Shaw-Meadow (dated June 13, 2012) PDF

Letter to John F. Carroll from Robert Shaw-Meadow (dated June 19, 2012) PDF

Letter to John F. Carroll from Robert Shaw-Meadow (dated September 4, 2012) PDF

Letter to Robert Shaw-Meadow from John F. Carroll (dated September 10, 2012) PDF

Letter to Susan B. Gerson from John F. Carroll (dated March 22, 2013) PDF

Letter to John F. Carroll from David M. Hardy, (dated August 12, 2014) PDF

Letter to David M. Hardy from John F. Carroll, (dated August 22, 2014) PDF

Letter to Susan B. Gerson from John F. Carroll (dated August 22, 2014) PDF

Letter to the Director of the Office of Information Policy, U.S. Department of Justice from John F. Carroll (dated October 28, 2014) PDF

Urgent Fax Memorandum from James L. Negley to United States Senators (sent December 15, 2014) PDF

Letter to John F. Carroll from Priscilla Jones of the United States Department of Justice (dated January 23, 2015) PDF

Letter from Thomas S. Hay and Clarence Y. Lee to the Department of Justice (dated May 17, 2015) PDF

Letter from Thomas S. Hay and Clarence Y. Lee to the Department of Justice (dated November 13, 2015) PDF

Letter from Thomas S. Hay and Clarence Y. Lee to the April D. Seabrook (dated December 1, 2015) PDF


Document Production

FOIA Document Production by DOJ (dated March 18, 2013) including Facsimile Transmission from David M. Castillo to Chief Division Counsel, Sacramento Division, FBI (dated January 22, 2002) PDF