About the December 14th 2012 Mass-Shooting at Sandy Hook Elementary School - #Michael Ayele (a.k.a) W - #NCD 01/14/2013

2. National Council on Disability An independent federal agency making recommendations to the President and Congress to enhance the quality of life for all Americans with disabilities and their families. February 15, 2022 W (AACL) Michael A. Ayele PO Box 20438 Addis Ababa, Ethiopia Re: FOIA Request NCD-2022-04 Dear W: This letter is in response to your Freedom of Information Act (FOIA) request, dated February 9, 2022, in which you requested: ”What I am requesting for prompt disclosure are all records within your possession detailing (1) the formal and informal ties that exist between your office, the Department of Commerce, the Department of Education (DoED), the Department of Homeland Security (DHS), the Department of Justice (DOJ), the Department of Labor (DOL), the Department of State (DoS), the Department of the Treasury, the Equal Employment Opportunity Commission (EEOC), the National Council on Disability (NCD), the Social Security Administration (SSA) and the White House; (2) your communications about Joe Biden being one of fifteen Vice Presidents who went on to become U.S President alongside John Adams, Thomas Jefferson, Martin Van Buren, John Tyler, Millard Fillmore, Andrew Johnson, Chester A. Arthur, Theodore Roosevelt, Calvin Coolidge, Harry S. Truman, Lyndon B. Johnson, Richard Nixon, Gerald R. Ford and George H. W. Bush; vi (3) your communications about the January 2013 NCD letter recommending for then Vice-President Joe Biden to “develop a framework to invest in community-based mental health support and programs;” (4) your communications about the January 2013 NCD letter recommending for then Vice-President Joe Biden to “avoid any proposal to link the Social Security Administration’s database of representatives payees with the FBI’s National Instant Criminal Background Check System (NICS);” (5) your communications about the January 2013 NCD letter recommending for then Vice-President Joe Biden to “avoid any proposal comparable to the provision of S. 436, the Fix Gun Checks Act; which amends the Higher Education Act to require colleges and universities to outline procedures for the involuntary referrals of students with perceived psychiatric disabilities for evaluation and institutionalization;” (6) your communications about the January 2013 NCD letter recommending for then Vice-President Joe Biden to “ensure that identification and isolation of individuals who have harmed others or are at risk of committing acts of violence does not lead to unnecessary expansion in institutionalization, involuntary commitment and forced treatment for individuals who may benefit from mental health services and supports but pose no risk of violence and have a basic human rights to make independent decisions;” (7) your communications about the Missouri Department of Mental Health (DMH) as a state agency, which refuses to confirm or deny to former employee Michael A. Ayele (a.k.a) W that many patients/prisoners of the Fulton State 1331 F Street, NW ■ Suite 850 ■ Washington, DC 20004 202-272-2004 Voice ■ 202-272-2022 Fax ■ www.ncd.gov

3. Hospital (FSH) Hearnes Forensic Center (HFC) have ceased to pose an imminent threat to themselves as well as others; (8) your communications about the Missouri DMH as a state agency, which refuses to confirm or deny to former employee Michael A. Ayele (a.k.a) W that many patients of the FSH (HFC) are being incarcerated for unduly long period of time instead of going to a less-restrictive environment; (9) your communications about the Missouri DMH as a state agency, which refuses to confirm or deny to former employee Michael A. Ayele (a.k.a) W that complaints had been filed by staff of the FSH (HFC) because patients/prisoners thereof had been incarcerated for unduly long period of time instead of going to a less-restrictive environment; (10) your communications about the Missouri DMH as a state agency, which refuses to confirm or deny to former employee Michael A. Ayele (a.k.a) W that complaints had been filed by patients/prisoners of the FSH (HFC) because they had been incarcerated for unduly long period of time instead of going to a less restrictive environment; vii (11) your communications about the decision of the NCD to inform then Vice-President Joe Biden that “there is no current system capable of reliably identifying persons who are likely to become dangerous;” (12) your communications about the decision of the NCD to inform then Vice- President Joe Biden that “there is no established correlation between psychiatric diagnosis and violent behavior;” (13) your communications about the decision of the NCD to inform then Vice-President Jose Biden that “federal legislation calling for forced medication or treatment would restrict the fundamental civil rights of people with psychiatric disabilities;” (14) your communications about the NCD as an independent non-partisan federal agency, which has “consistently expressed concern about the conflation of mental health disabilities with gun violence;” (15) your communications about the NCD as an independent non-partisan federal agency, which “takes no position with respect to many of the often debated issues around availability of guns” in American society; viii (16) your communications about the NCD as an independent non-partisan federal agency, which has applauded “the Senate’s approval of the bipartisan disapproval resolution to unlink the Social Security Administration’s database of representative payees with the Federal Bureau of Investigation’s National Instant criminal Background Check System;” ix (17) your communications about the COVID-19 pandemic having led to significant increases in gun sales throughout the United States of America (U.S.A); x (18) your communications about the Joe Biden – Kamala Harris White House administration “comprehensive strategy to prevent and respond to gun violence and ensure public safety;” (19) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “establish zero tolerance for rogue gun dealers that willfully violate the law;” xi (20) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “maximize the efficacy of ATF resources to crack down on rogue gun dealers violating” U.S laws; (21) your communications about the decision of the Bureau of Alcohol, Tobacco and Firearms (ATF) to designate a “specific point of contact in every field division for mayors, police chiefs, or other local leaders to report concerns about particular dealers’ compliance with the law;” (22) the name(s), the academic background(s), the professional responsibility(ies) and annual salary(ies) of the ATF point of contact serving in your City & County for the purpose of auditioning your concerns about gun violence as well as your conversations with them; (23) your communications about the actions taken by the Joe Biden – Kamala Harris administration to launch a multijurisdictional firearms trafficking strike force; (24) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “provide the public with additional data to promote transparency and accountability in enforcement of federally licensed firearms dealer policies;” (25) your communications about the actions taken by the Joe Biden – 2

4. Kamala Harris administration to “convene state legislators and Attorneys General regarding policy strategies to hold gun dealers and manufacturers accountable for their contribution to the flow of crime guns;”xii (26) your communications about the actions taken by the Joe Biden – Kamala Harris administration to expand “summer programming, employment opportunities, and other services and supports, especially for teenagers and young adults;”xiii (27) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “help formerly incarcerated individuals successfully reenter their communities;” xiv (28) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “expand federal hiring of formerly incarcerated persons;” xv (29) your communications about the DOJ’s Hiring Second Chance Act Fellow; xvi (30) your communications about the actions taken by the Joe Biden –Kamala Harris administration to “leverage tax credits to incentivize hiring of formerly incarcerated individuals;” xvii (31) your communications about the additional actions taken by the Joe Biden –Kamala Harris administration to “reduce gun crime;” xviii (32) your communications about the Freedom of Information Act (FOIA) appeal submitted by Michael A. Ayele (a.k.a) W citing several inconsistencies in the manner the Department of the Interior (DOI) had processed his records request dealing with the gun violence public health epidemic and the executive branch of government; xix (33) the communications between the Government of Mexico and the Department of State before the filing of their complaint, which was assigned in the United States District Court for the District of Massachusetts Case Number 1:21 – cv – 11269 – FDS; (34) your communications about the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the trafficking of their guns to drug cartels through straw purchasing,xx repeat sales, kitchen table sales, ‘missing’ guns and firearm shows;” (35) your communications about the decision of the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the trafficking of their guns to drug cartels” by “designing and marketing their rifles as military style assault weapons;” (36) your communications about the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the trafficking of their guns to drug cartels” by “designing their guns to allow use by unauthorized persons;” (37) your communications about the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the trafficking of their guns to drug cartels” by “designing their guns to enable defacement of serial numbers;” (38) your communications about the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the trafficking of their guns to drug cartels” by “refusing to implement the reforms they know are necessary;” (39) your communications about the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the unlawful trafficking of their guns because it maximized their sales and profits;” (40) your communications about the backing provided to the Mexican government’s federal lawsuit, which was assigned by the U.S District Court for the District of Massachusetts Case Number 1: 21 – cv – 11269 – FDS; xxi (41) your communications about the decision of the Government of Mexico to legalize marijuana/cannabis for recreational purposes; xxii (42) your communications about the memorandum of understanding (MOU)concluded between the EEOC and the Government of Mexico on September 02nd 2021; (43) the communications between the EEOC and the Government of Mexico before the conclusion of the MOU; (44) the MOU concluded between the EEOC and the Government of Mexico; xxiii (45) your communications about the response provided by the District of Columbia Government (DC.Gov) Office of Police Complaint (OPC) to the FOIA request submitted by Michael A. Ayele (a.k.a) W dealing with the March for Our 3

5. Lives Rally; xxiv (46) your communications about the letter written by D.C Mayor Muriel Bowser on December 10th 2021 dealing with gun violence in the capital of the U.S; xxv (47) your communications about Missouri’s Second Amendment Preservation Act; (48) your communications about Missouri’s Second Amendment Preservation Act declaring “that federal supremacy does not apply to federal laws that restrict or prohibit the manufacture, ownership, and use of firearms, firearm accessories, or ammunition within the state because such laws exceed the scope of the federal government’s authority;” (49) your communications about Missouri’s Second Amendment Preservation Act declaring as “invalid all federal laws that infringe on the right to bear arms under the Second Amendment to the U.S Constitution and Article I, Section 23 of the Missouri Constitution;” (50) your communications about Missouri’s Second Amendment Preservation Act holding the courts and law enforcement agencies responsible for protecting the “rights of law-abiding citizens to keep and bear arms;” (51) your communications Missouri’s Second Amendment Preservation Act subjecting a civil penalty of $50,000 upon any “public officer or state or local employee who tries to enforce the firearms law declared invalid by the act or any person who acts under the color of law to deprive a Missouri citizen of rights or privileges ensured by the federal and state constitution;” (52) your communications about Missouri’s Second Amendment Preservation Act providing people the opportunity to “pursue an action for injunctive relief in the circuit court of the county in which the action allegedly occurred or in the circuit court of Cole County;”xxvi (53) your communications about the complaint filed by the City & County of Saint Louis, Missouri in the Missouri Circuit Court for Cole County; (54) your communications about the decision of the City & County of Saint Louis to note in their complaint that “House Bill 85 is a radical, dangerous and obviously unconstitutional attempt to declare that Missouri will refuse to follow federal gun laws;” (55) your communications about the decision of the City & County of Saint Louis to note in their complaint that “Governor Parson and the Republican legislature have (…) chosen to preserve Missouri’s growing reputation for extremist and dangerous laws;” (56) your communications about the decision of the City & County of Saint Louis to note in their complaint that “HB 85 violates the United States Constitution’s Supremacy Clause, which provides that federal law preempts state law;” (57) your communications about the decision of the City & County of Saint Louis to note in their complaint that “in misguided zeal to prevent imaginary threats to the right to keep and bear arms, the political branches in our state government blatantly violated the federal and state constitutions by attempting to nullify federal gun laws;” (58) the communications between the City & County of Saint Louis before the filing of their complaint in the Missouri Circuit Court for Cole County; (59) the communications between Jackson County, the City & County of Saint Louis and the judge assigned to their complaint in the Missouri Circuit Court for Cole County (Daniel Green);xxvii (60) your communications about Cori Bush as Missouri’s first Black Congresswoman who previously worked as a registered nurse (R.N); (61) your communications about the car of Cori Bush having been struck by gunfire while it was parked in the St. Louis area on January 2022;xxviii (62) your communications about Amnesty International defining mass shootings as shootings where four or more victims are killed;xxix (63) your communications about the May 2021 murder-suicide mass shooting rampage at Santa Clara Valley Transportation Authority (VTA); (64) your communications about Samuel Cassidy as a Caucasian man who was employed for the VTA before he carried out the murder-suicide mass shooting rampage; (65) your communications about the reasons, which led Samuel Cassidy to carry out a murder-suicide mass shooting rampage at his previous place of employment; (66) your communications about Samuel Cassidy 4

6. as a Caucasian man, who according to his ex-girlfriend had been diagnosed with bipolar disorder; (67) your communications about Samuel Cassidy as a Caucasian man, who had previously been questioned by the Department of Homeland Security (DHS) Customs & Border Patrol (CPB) on the issue of his “hatred for the VTA;” xxx (68) the DHS (CBP) memo on Samuel Cassidy; xxxi (69) the complaints filed by Samuel Cassidy with the EEOC and/or the California Department of Fair Employment & Housing (DFEH) alleging discriminatory practices ongoing in the VTA; (70) your communications about the open-letter penned by San Jose Mayor Samuel Liccardo following the murder-suicide mass shooting rampage carried out by Samuel Cassidy; xxxii (71) your communications about San Jose becoming the first U.S city to mandate gun liability insurance;xxxiii (72) the possibility of your city/county following the lead of San Jose, California in requiring gun liability insurance; (73) your communications about the impact of gun violence on public health and the “right to education;” xxxiv (74) the academic backgrounds, the professional responsibilities and annual salaries of Jonathan M. Young, Phoebe Ball, Jeff Rosen, Tishaura Jones, Sam Page, Caleb Clifford, Frank White, Crystal Williams, Jalen Anderson, Kevin Merritt, Daniel Green, Frederic Winston, Chris Nuelle, Beth Orwick, Matt Moak, Heidi L. Leopold, Robert H. Dieker, Steve D. Shadowen, Jonathan E. Lowy, Richard M. Burnell, Craig Fair and Laurie Smith.” It appears that NCD is not the intended party for this FOIA request. Regardless, NCD does not have any records responsive to your request. For tracking purposes, your tracking number is NCD-2022-04. If you need further assistance, you may contact Amy Nicholas, NCD’s FOIA Public Liaison at 202-731-2313 or anicholas@ncd.gov. Please include your tracking number with any correspondence. If needed, it is your right to seek dispute resolution services from NCD’s Public Liaison or the Office of Government Information Services (OGIS). OGIS may be reached at: Office of Government Information Services (OGIS) National Archives and Records Administration 8601 Adelphi Road College Park, MD 20740-6001 OGIS@Nara.gov 202-741-5770 fax 202-741-5769 NCD’s appeal process allows you to appeal withheld information or the adequacy of NCD’s search by writing within 90 days of your receipt of this letter to: Anne Sommers McIntosh Executive Director National Council on Disability 1331 F St. NW. Suite 850 Washington DC 20004 5

7. Your appeal must be in writing and should contain a brief statement of the reasons why you believe the requested information should be released. Enclose a copy of your initial request, request number and a copy of this letter. Both the appeal letter and envelope should be prominently marked “Freedom of Information Act Appeal.” After processing, actual fees must be equal to or exceed $25 for the Council to require payment of fees. See 5 CFR §10,00010k. The fulfillment of your request did not exceed $25, therefore there is no billable fee for the processing of this request. Respectfully, Joan Durocher Chief FOIA Officer 6

8. National Council on Disability An independent federal agency making recommendations to the President and Congress to enhance the quality of life for all Americans with disabilities and their families. March 30, 2022 W (AACL) Michael A. Ayele PO Box 20438 Addis Ababa, Ethiopia Re: FOIA Request NCD-2022-04 Dear W: This letter is in response to your Freedom of Information Act (FOIA) labeled as an appeal, dated February 17, 2022: “Please be advised that I am contacting you for the purpose of filing an appeal to the FOIA request you had assigned Case No.: 2022 – 04. As a representative of the media and a member of the general public, I have concerns about your response to my FOIA request because of your failure to promptly disclose records within your possession detailing the internal communications employees and legal representatives of the National Council on Disability (NCD) have had amongst themselves before the publication of the January 2013 letter addressed to then Vice-President Biden (1) recommending for him to “develop a framework to invest in community based mental health and support programs;” (2) recommending for him to “avoid any proposal to link the Social Security Administration’s database of representatives payees with the FBI’s National Instant Criminal Background Check System (NICS);” (3) recommending for him to “avoid any proposal comparable to the provisions of S. 436, the Fix Gun Checks Act, which amends the Higher Education Act to require colleges and universities to outline procedures for the involuntary referrals of students with perceived psychiatric disabilities for evaluation and institutionalization.” [i] Additionally, I have concerns with your failure to disclose the academic backgrounds, the professional responsibilities and annual salaries of Jonathan M. Young, Phoebe Ball and Jeff Rosen at the time of their employment with the NCD. The core issues presented in my records request I would like for the NCD to address are the following. 1) Will you promptly disclose the notes that were taken during the January 14th 2013 meeting Jonathan M. Young referred to? 2) Were communications in the form of e-mails and postal correspondence had before January 14th 2013 between employees and legal representatives of the NCD on the issues of avoiding (i) proposals that link Social Security Administration’s database of representative payees with the FBI’s NICS, (ii) proposals comparable to the provisions of S. 436 and the Fix Gun Checks Act? If yes, will you promptly disclose those records? I would again like to reiterate that I am requesting for prompt disclosure records that exist within your 1331 F Street, NW ■ Suite 850 ■ Washington, DC 20004 202-272-2004 Voice ■ 202-272-2022 Fax ■ www.ncd.gov

9. possession detailing (1) the notes that were taken during the January 14th 2013 NCD meeting Jonathan M. Young referred to; (2) the communications between employees and legal representatives of the NCD before January 14th 2013 on the issue of avoiding (i) proposals that link Social Security Administration’s database of payees with the FBI’s NICS, (ii) proposals comparable to the provisions of S. 436 and the Fix Gun Checks Act; (3) the academic background, the professional responsibilities and annual salaries of Jonathan M. Young, Phoebe Ball and Jeff Rosen at the time of their employment with the NCD.” Thank you for clarifying your multi-tiered FOIA request. We are treating this correspondence as a clarification of prior requested records as it was not clear that you were requesting academic background, salaries and professional responsibilities of former NCD employees. NCD has attached the academic background and salaries of the former NCD employees you requested. The professional responsibilities for Ms. Ball’s position are attached. The professional responsibilities of NCD’s former Chairmen Young and Rosen are on our website in NCD’s bylaws. The communications you request between employees and legal representatives are legally privileged conversations and exempt from release under the Freedom of Information Act pursuant to 5 USC §552(5)(b). The notes taken by Jonathan Young during an NCD meeting are predecisional and also exempt from disclosure pursuant to 5 USC §552(5)(b). For tracking purposes, your tracking number is NCD-2022-04. If you need further assistance, you may contact Amy Nicholas, NCD’s FOIA Public Liaison at 202-731-2313 or anicholas@ncd.gov. Please include your tracking number with any correspondence. If needed, it is your right to seek dispute resolution services from NCD’s Public Liaison or the Office of Government Information Services (OGIS). OGIS may be reached at: Office of Government Information Services (OGIS) National Archives and Records Administration 8601 Adelphi Road College Park, MD 20740-6001 OGIS@Nara.gov 202-741-5770 fax 202-741-5769 NCD’s appeal process allows you to appeal withheld information or the adequacy of NCD’s search by writing within 90 days of your receipt of this letter to: Anne Sommers McIntosh Executive Director National Council on Disability 1331 F St. NW. Suite 850 Washington DC 20004 2

10. Your appeal must be in writing and should contain a brief statement of the reasons why you believe the requested information should be released. Enclose a copy of your initial request, request number and a copy of this letter. Both the appeal letter and envelope should be prominently marked “Freedom of Information Act Appeal.” After processing, actual fees must be equal to or exceed $25 for the Council to require payment of fees. See 5 CFR §10000.10k The fulfillment of your request did not exceed $25, therefore there is no billable fee for the processing of this request. Respectfully, Joan Durocher Chief FOIA Officer 3

11. National Council on Disability An independent federal agency making recommendations to the President and Congress to enhance the quality of life for all Americans with disabilities and their families. FOIA REQUESTED EDUCATION AND WAGES OF NCD STAFF AND COUNCIL MEMBERS Phoebe Ball, Legislative Affairs Specialist JurisDoctorate,NortheasternUniversitySchoolofLaw Bachelor of Arts, English, University of Iowa, Iowa City, IA Jonathan Young, former NCD Chairman Juris Doctorate, Yale Law School Ph.D., American History, University of North Carolina at Chapel Hill M.A., American History, University of North Carolina at Chapel Hill Jeff Rosen, former NCD Chairman Juris Doctorate, University of Washington B. A., Gallaudet University SALARY   Members, including the Chair is $74.51/hr. Phoebe Ball’s salary $114,590, including locality pay. (Base: $89,370 and Locality: $25,220) 1331 F Street, NW ■ Suite 850 ■ Washington, DC 20004 202-272-2004 Voice ■ 202-272-2074 TTY ■ 202-272-2022 Fax ■ www.ncd.gov

12. LEGISLATIVE AFFAIRS SPECIALIST GS-301-14 INTRODUCTION: Serves as a Legislative Affairs Specialist in the Directorate of Legislative Affairs and Outreach for the National Council on Disability (NCD), an independent federal agency, subject to the provisions of title 5 USC and established by the Vocational Rehabilitation Act, as amended in 1978, and the Rehabilitation Amendments of 1984 (PL 21), dated February 22, 1984. The NCD staff supports the Council which is comprised of Presidential and Congressional appointees. The Council’s principal purpose is to develop recommendations to use in advising the President, the Congress, Federal entities, the states, and occasionally international entities on policies and programs that promote full inclusion, independence and equal opportunity for people with disabilities. The Council sets its agenda using a strategic planning process and communicates its priorities via the issuance of a five-year Strategic Plan. The NCD, as a key contributor to the development and implementation of policies and practices affecting the disability community; maintains continuing liaison with Members of Congress and their staff, officials in federal, state and local governments and advocacy organizations in order to educate on issues and monitor the development of legislation and government regulations impacting the community. MAJOR DUTIES: Incumbent serves as a key NCD (National Council on Disability) liaison with Members of Congress and their staffs, providing or arranging for authoritative and informative testimony and responses to Congressional inquiries about NCD policy publications and position statements on issues surfacing within the disability community which have been raised to the Congressional level. Incumbent regularly conducts congressional policy briefings. Similarly, serves as liaison with federal, state, tribal, and local government organizations and other NCD stakeholders to provide briefings or to arrange for other contacts for the NCD staff and/or Council for purposes of promoting, evaluating, or developing feedback about federal policies affecting the disability community. Assists members of the Council and NCD staff by providing training and advice on best available techniques, protocols or methodologies for interacting and engaging Members of Congress (both in the House and the Senate), Committee Chairs and Committee members and their staff representatives; representatives of state and local governments; and, representatives of other federal agencies and stakeholders. Incumbent works with the NCD policy staff and/or Council members to prepare them to provide either written or oral testimony before Congress. Responds to information

13. requests from state and local governments and advocacy groups on NCD legislative and/or other related regulatory and program activities and accomplishments. Develops various legislative affairs materials, such as legislative analyses, leave-behind sheets, website report landing page text, speeches, moderation prompts for panel presentations, key talking points for reports and/or speeches, legislative and regulatory updates, budget analyses, original writing and academic research for agency policy publications, and other materials and products for use by Presidential and Congressional appointees and professional staff of NCD. Drafts NCD position letters on legislation, regulation, and other related activity based upon NCD’s lengthy history of policy research. Reviews, tracks and analyzes proposed and introduced legislation and regulatory or program implementation actions or issues of consequence to people with disabilities. Provide time sensitive reports and real-time notification to NCD staff and Council members as major initiatives/actions develop. Performs in-depth analyses of laws, programs, and policies relevant to the disability community and recommends areas in which NCD should consider legislative or regulatory positions or initiatives. Carefully reviews and provides written analyses and summaries of proposed budgets of the President and the U.S. Congress, regarding their effect on existing programs and agencies on which people with disabilities rely. Tracks and alerts Council and staff of Congressional hearings of importance to the disability community prior to their occurrence, and identifies strategic opportunities for NCD involvement, including submissions to the written record. Incumbent works with members of the policy staff to implement NCD proposals. Carefully source- and fact-checks material used in conjunction with NCD policy publications drafted by incumbent or by a contractor on behalf of the agency. Tracks legislative amendments to bills of interest to the agency and considers importance and implications of the changes, raising opportunities to weigh in to the attention of agency leadership for consideration." Respond to Congressional inquiries and constituent concerns. Incumbent collaborates with the NCD Public Affairs Specialist to provide regular updates on legislative and regulatory action to stakeholders. Knowledge Required by the Position Level 1-8 1550 points Expert knowledge of disability laws and regulations and NCD policy positions, functions, goals, priorities and commitments in order to analyze proposed legislation and regulations/programs, present briefings, or provide oral or written testimony on issues of

14. concern to the disability community to Members of Congress, their staffs and agency officials/staff members at the federal or state level. Knowledge of the operations and practices related to the Congressional hearing process, Congressional committee structure, staff, and the administrative offices of Congress, Congressional appropriations and budget cycle; and Presidential budget cycle. Extensive knowledge of the legislative process at the federal level; an understanding of the legislative process(es) at the state/tribal/local levels. Ability to communicate independently in order to represent NCD publications and policy position on issues relating to people with disabilities in a variety of forums, including with Members of Congress, congressional committees and staff members, and federal agency officials and staff who may have limited understanding of the issues or hold opinions that diverge from NCD positions. Expertise and skills required to establish and maintain positive interpersonal relationships. Expertise in utilizing a variety of tools and methodologies to interact effectively with Members of Congress and their staffs; including federal/state agency and tribal officials and their staff members. Knowledgeable of the organizations and programs at the federal, state and local levels responsible for serving people with all types of disabilities; Knowledgeable and proficient handling and working with disability and cultural competencies. Knowledge of disability etiquette when addressing disability community concerns with policy makers, their staff and other NCD stakeholders. Ability to analyze, interpret and communicate complex and politically sensitive issues relating to disability policy and programs and, using this information, assist in developing plans and recommend policies, methods and strategies to assist in their resolution. Supervisory Controls Level 2-4 450 points Incumbent works under the supervision of the Director of Legislative Affairs and Outreach who sets overall objectives. The incumbent and supervisor, in consultation, develop project/assignment goals and standards and deadlines. The employee is responsible, as a functional expert, for independently planning and carrying out assignments, resolving most of the conflicts that may arise and coordinating the work with others as necessary. The employee keeps the supervisor informed of progress

15. and potentially controversial matters or impediments. Completed work is reviewed in terms of meeting requirements or expected results and requires very little edits. Guidelines Level 3-5 650 points Guidelines consist of plans and priorities determined by the Council and Executive Director, general policy statements and statutory mandates, as well as the authorizing legislation for NCD, PL 98-221. While these guidelines establish a general direction or tone for dealing with the legislative process and Members of Congress and other agency officials and staff, there are no internal agency guidelines and few precedents applicable to unusual or sensitive Congressional or inter-agency (at the federal, state and local levels) relationships. Accordingly, incumbent must exercise independent judgment and creativity in determining actions and reactions to specific situations and is recognized as a technical authority regarding the development and interpretation of laws and regulations in the field of disability policy. Complexity Level 4-5 325 points Work assignments are related to the full spectrum of issues, policies and programs concerning people with disabilities at all levels—federal, state, local and private sector. Incumbent must identify and analyze a broad range of issues and make decisions on how to present the NCD position and policy options to a variety of audiences in order to most effectively meet Council goals and priorities and the needs of the disability community. Decisions regarding how to best meet the needs of the community are impacted by major areas of uncertainty in approach, methodology or interpretation and evaluation processes that result from such elements as continuing changes in the priorities of the Council, state and federal budgets, technological developments, breadth of scope, or conflicting requirements. Scope and Effect Level 5-5 325 points Incumbent is responsible for analyzing and interpreting disability policy, programs, laws and regulations and providing authoritative information and analyses to Presidentially and Congressionally appointed council members, Members and committees of Congress, their staff and federal/state/local agency officials about the interaction with and relationship to NCD policies, programs, proposals, activities and accomplishments and the potential effect on the disability community. Incumbent must be able to answer substantive questions, explain and describe alternatives to critical policy problems

16. associated with the disability community. Effective performance of work not only impacts the understanding and perception of NCD held by Members of Congress and other stakeholders at all levels of government (i.e., at the Federal, state and local levels), the public and members of private organizations and other advocacy groups, but also provides new approaches to understanding the identified problem and contributes to the planning of legislative solutions. Personal Contacts and Purpose of Contacts Levels 6-4 & 7-d 330 points The personal contacts are with Presidentially and Congressionally appointed Council Members, elected Members of Congress and their staff, top level management of other federal agencies, officials of disability community advocacy organizations, academic experts, and representatives of public and private interest groups. The nature of the contact varies depending on the context of and rationale for the contact. The purpose of contacts is to justify, defend, negotiate, educate, or settle matters that involve significant, complex, or controversial issues pertaining to the disability community. Incumbent is required to participate actively in Congressional briefings and hearings, conferences, meetings, presentations and other forums with stakeholders in order to achieve common understanding of issues and to achieve a satisfactory solution through compromise or the development of alternative solutions. Physical Demands Level 8-1 5 points Work is normally performed at the NCD office while sitting at a desk or in briefings or meetings at NCD or on Capitol Hill. Incumbent may be required to take public transportation (e.g., bus, metro, train or airplane) to attend meetings and make presentations in the local area or in other parts of the United States. Work Environment Level 9-1 5 points The environment involves everyday risks or discomforts that require normal safety precautions typical of such places as offices, meeting or training rooms. Work areas are adequately lighted, heated and ventilated. TOTAL POINTS: 3640 (Range 3605-4050) Grade Conversion = GS-14

17. FOIA APPEAL 02/17/2022 W (AACL) Michael A. Ayele P.O.Box 20438 Addis Ababa, Ethiopia E-mail : waacl13@gmail.com ; waacl1313@gmail.com ; waacl42913@gmail.com Freedom of Information Act (FOIA) Appeal Request Case No.: 2022 – 04 Hello, Thank you for your email. I am in receipt of it. I am writing this letter in response to your correspondence dated February 15th 2022, which I received on the following day. Please be advised that I am contacting you for the purpose of filing an appeal to the FOIA request you had assigned Case No.: 2022 – 04. As a representative of the media and a member of the general public, I have concerns about your response to my FOIA request because of your failure to promptly disclose records within your possession detailing the internal communications employees and legal representatives of the National Council on Disability (NCD) have had amongst themselves before the publication of the January 2013 letter addressed to then Vice- President Biden (1) recommending for him to “develop a framework to invest in community based mental health and support programs;” (2) recommending for him to “avoid any proposal to link the Social Security Administration’s database of representatives payees with the FBI’s National Instant Criminal Background Check System (NICS);” (3) recommending for him to “avoid any proposal comparable to the provisions of S. 436, the Fix Gun Checks Act, which amends the Higher Education Act to require colleges and universities to outline procedures for the involuntary referrals of students with perceived psychiatric disabilities for evaluation and institutionalization.”i Additionally, I have concerns with your failure to disclose the academic backgrounds, the professional responsibilities and annual salaries of Jonathan M. Young, Phoebe Ball and Jeff Rosen at the time of their employment with the NCD. The core issues presented in my records request I would like for the NCD to address are the following. 1) Will you promptly disclose the notes that were taken during the January 14th 2013 meeting Jonathan M. Young referred to? 2) Were communications in the form of e-mails and postal correspondence had before January 14th 2013 between employees and legal representatives of the NCD on the issues of avoiding (i) proposals that link Social Security Administration’s database of representative payees with the FBI’s NICS, (ii) proposals comparable to the provisions of S. 436 and the Fix Gun Checks Act? If yes, will you promptly disclose those records? I would again like to reiterate that I am requesting for prompt disclosure records that exist within your possession detailing (1) the notes that were taken during the January 14th 2013 NCD meeting Jonathan M. Young referred to; (2) the communications between employees and legal representatives of the NCD before January 14th 2013 on the issue of avoiding (i) proposals that link Social Security Administration’s database of representative payees with the FBI’s NICS, (ii) proposals comparable to the provisions of S. 436 and the Fix Date. : February 17th 2022 W (AACL) – MICHAEL A. AYELE 1

18. FOIA APPEAL 02/17/2022 Gun Checks Act; (3) the academic background, the professional responsibilities and annual salaries of Jonathan M. Young, Phoebe Ball and Jeff Rosen at the time of their employment with the NCD. I hope you reconsider your response. Have a good day. Take care. W (AACL) Michael A. Ayele Anti-Racist Human Rights Activist Audio-Visual Media Analyst Anti-Propaganda Journalist W (AACL) – MICHAEL A. AYELE 2

19. FOIA APPEAL 02/17/2022 Work Cited i Letter to Vice President Biden Regarding Anticipated Taskforce Recommendations Dear Mr. Vice President: I write to bring to your attention critical recommendations on behalf of the National Council on Disability (NCD), an independent federal agency comprised of 15 presidential appointees charged with providing advice to the President and Congress on disability policy. NCD applauds your leadership on the gun violence task force because the tragedy of Newtown has touched all of us in a deep and abiding way and decisive action is warranted. NCD affirms its support for efforts to improve the quality, availability, and affordability of mental health services and supports. NCD also remains concerned about the risk of taking reflexive actions that may appear to be designed to prevent future Newtown tragedies but have other unintended and undesirable consequences in worsening rather than improving access to mental health services and supports. The principal challenge is that access to mental health services is already compromised by deep and enduring stigma about seeking and receiving mental health treatment. We cannot afford to exacerbate harmful stereotypes about mental illness even as we must act to ensure that all individuals with mental health needs can get help when they need it and help ensure that people who pose significant risks of harming and killing others do not have the opportunity to do so. A basic fact endures: people with psychiatric disabilities are more often the victims of violence than they are the perpetrators of violence. We must recognize the risk of increasing one type of violence while we seek to reduce another type. Earlier today the Council adopted a series of recommendations during a Special Meeting called specifically to consider recommendations to your task force and review certain legislative and policy proposals that may prove more harmful than beneficial. We urge you to pay careful consideration to these recommendations as you finalize your own recommendations and begin to implement them. As we stated at the creation of your task force, NCD remains willing to work with you and your staff as the work of your task force unfolds. First, NCD recommends you develop a framework to invest in community-based mental health supports and programs. Existing federal research reveals a profound shortage of community- based services, including mobile crisis services and peer supports. Community mental health programs can offer excellent, comprehensive services when sufficiently funded and supported. Unfortunately, the severe deficiency in current resources means that these services are often available only to people who are in immediate crisis and who have already endured multiple hospitalizations. Recently, pilot programs have been developed across the country to better meet the needs of people when they have their first psychotic episode. These programs are community- based and help to address critical unmet needs. NCD encourages the Taskforce to advance policy recommendations in line with these models and the principles undergirding them. W (AACL) – MICHAEL A. AYELE 3

20. FOIA APPEAL 02/17/2022 Second, NCD urges you to avoid any proposal to link the Social Security Administration's database of representative payees with the FBI's National Instant Criminal Background Check System (NICS). Whatever merits such a proposal might seem to present, such benefits are outweighed by the inaccurate and discriminatory inference that would result: equating the need for assistance in managing one's finances with a presumption of incapacity in other areas of life. Maximizing self-direction is critical to enabling people with disabilities to meet the goals of the ADA: equality of opportunity, full participation, independent living, and economic self- sufficiency. Many people with disabilities and seniors rely on representative payees as a practical measure to facilitate income support. There should not be any permissible inference that use of a representative payee signals impairment of decision-making—whether it be in casting votes or choosing health care providers. Linking the representative payee system and the NICS would support just such an inference. NCD recommends you ensure that the selection of a representative payee continues to have no implication on other areas of rights beyond financial decision-making. Third, NCD urges you to avoid any proposal comparable to the provision of S. 436, the Fix Gun Checks Act, which amends the Higher Education Act to require colleges and universities to outline procedures for the involuntary referrals of students with perceived psychiatric disabilities for evaluation and institutionalization. As set forth in its first recommendation, NCD maintains that enhanced access to mental health services and supports is critical. We also understand that current law properly requires that knowledge of an immediate threat to safety is reported and addressed. However, a policy that broadly targets individuals who have not exhibited a threat of harm risks increasing discrimination and stigmatization for college students and could have the chilling effect of discouraging students from seeking the very mental health services they need in times of distress. Universities across the country are making progress with mental health programs on campus and are showing positive results. NCD supports increased opportunity for peer-to-peer support and campus-based counseling programs, and encourages campus policies that focus on making these resources more broadly available. Finally, NCD urges you to ensure that identification and isolation of individuals who have harmed others or are at risk of committing acts of violence does not lead to unnecessary expansion in institutionalization, involuntary commitment and forced treatment for individuals who may benefit from mental health services and supports but pose no risk of violence and have a basic human right to make independent decisions. There is no current system capable of reliably identifying persons who are likely to become dangerous, and there is not established correlation between psychiatric diagnosis and violent behavior. Federal legislation calling for forced medication or treatment would restrict the fundamental civil rights of people with psychiatric disabilities. Incarcerating individuals for punishment of crimes committed is central to our criminal justice system. But incarceration and forced treatment of stigmatized individuals based on misplaced fears and stereotypes has no place in our civil society. Institutional care has a long-standing history of poor outcomes and civil rights violation among persons with psychiatric disabilities. Thank you for your thoughtful consideration of NCD’s recommendations. We remain ready to assist and advise your task force, the Administration, and leaders of Congress to best meet the W (AACL) – MICHAEL A. AYELE 4

21. FOIA APPEAL 02/17/2022 health, safety and security needs of the American public, including Americans with psychiatric disabilities. Very Respectfully, Jonathan M. Young, PhD, JD Chairman, National Council on Disability. National Council on Disability (NCD), January 14th 2013.: https://ncd.gov/publications/2013/Jan142013 W (AACL) – MICHAEL A. AYELE 5

22. RECORDS REQUEST 04/03/2022 W (AACL) Michael A. Ayele P.O.Box 20438 Addis Ababa, Ethiopia E-mail : waacl13@gmail.com ; waacl1313@gmail.com ; waacl42913@gmail.com Request for Records Hello, This is Michael A. Ayele sending this message though I now go by W. You may call me W. I am writing this letter to file a request for records with your offices.i The bases for this records request are (1) the January 14th 2013 letter written by the National Council on Disability (NCD) to then Vice-President Joseph R. Biden (Joe Biden) on the 2nd Amendment of the U.S Constitution;ii (2) the complaint filed by the City & County of Saint Louis, Missouri for the purpose of blocking the recently publicized Missouri’s Second Amendment Preservation Act;iii (3) the complaint filed by the Government of Mexico in the United States District Court for the District of Massachusetts, which has been assigned Case Number 1:21 – cv – 11269 – FDS;iv (4) the decision of the City of San Jose to require gun owners to have liability insurance.v I) Requested Records What I am requesting for prompt disclosure are all records within your possession detailing (1) the formal and informal ties that exist between your office, the Department of Commerce, the Department of Education (DoED), the Department of Homeland Security (DHS), the Department of Justice (DOJ), the Department of Labor (DOL), the Department of State (DoS), the Department of the Treasury, the Equal Employment Opportunity Commission (EEOC), the National Council on Disability (NCD), the Social Security Administration (SSA) and the White House; (2) your communications about Joe Biden being one of fifteen Vice Presidents who went on to become U.S President alongside John Adams, Thomas Jefferson, Martin Van Buren, John Tyler, Millard Fillmore, Andrew Johnson, Chester A. Arthur, Theodore Roosevelt, Calvin Coolidge, Harry S. Truman, Lyndon B. Johnson, Richard Nixon, Gerald R. Ford and George H. W. Bush; vi (3) your communications about the January 2013 NCD letter recommending for then Vice-President Joe Biden to “develop a framework to invest in community-based mental health support and programs;” (4) your communications about the January 2013 NCD letter recommending for then Vice-President Joe Biden to “avoid any proposal to link the Social Security Administration’s database of representatives payees with the FBI’s National Instant Criminal Background Check System (NICS);” (5) your communications about the January 2013 NCD letter recommending for then Vice-President Joe Biden to “avoid any proposal comparable to the provision of S. 436, the Fix Gun Checks Act; which amends the Higher Education Act to require colleges and universities to outline procedures for the involuntary referrals of students with perceived psychiatric disabilities for evaluation and institutionalization;” (6) your communications about the January 2013 NCD letter recommending for then Vice-President Joe Biden to “ensure that identification and isolation of individuals who have harmed others or are Date.: April 03rd 2022 W (AACL) – MICHAEL A. AYELE 1

23. RECORDS REQUEST 04/03/2022 at risk of committing acts of violence does not lead to unnecessary expansion in institutionalization, involuntary commitment and forced treatment for individuals who may benefit from mental health services and supports but pose no risk of violence and have a basic human rights to make independent decisions;” (7) your communications about the Missouri Department of Mental Health (DMH) as a state agency, which refuses to confirm or deny to former employee Michael A. Ayele (a.k.a) W that many patients/prisoners of the Fulton State Hospital (FSH) Hearnes Forensic Center (HFC) have ceased to pose an imminent threat to themselves as well as others; (8) your communications about the Missouri DMH as a state agency, which refuses to confirm or deny to former employee Michael A. Ayele (a.k.a) W that many patients of the FSH (HFC) are being incarcerated for unduly long period of time instead of going to a less-restrictive environment; (9) your communications about the Missouri DMH as a state agency, which refuses to confirm or deny to former employee Michael A. Ayele (a.k.a) W that complaints had been filed by staff of the FSH (HFC) because patients/prisoners thereof had been incarcerated for unduly long period of time instead of going to a less-restrictive environment; (10) your communications about the Missouri DMH as a state agency, which refuses to confirm or deny to former employee Michael A. Ayele (a.k.a) W that complaints had been filed by patients/prisoners of the FSH (HFC) because they had been incarcerated for unduly long period of time instead of going to a less restrictive environment; vii (11) your communications about the decision of the NCD to inform then Vice-President Joe Biden that “there is no current system capable of reliably identifying persons who are likely to become dangerous;” (12) your communications about the decision of the NCD to inform then Vice- President Joe Biden that “there is no established correlation between psychiatric diagnosis and violent behavior;” (13) your communications about the decision of the NCD to inform then Vice-President Jose Biden that “federal legislation calling for forced medication or treatment would restrict the fundamental civil rights of people with psychiatric disabilities;” (14) your communications about the NCD as an independent non-partisan federal agency, which has “consistently expressed concern about the conflation of mental health disabilities with gun violence;” (15) your communications about the NCD as an independent non-partisan federal agency, which “takes no position with respect to many of the often debated issues around availability of guns” in American society; viii (16) your communications about the NCD as an independent non-partisan federal agency, which has applauded “the Senate’s approval of the bipartisan disapproval resolution to unlink the Social Security Administration’s database of representative payees with the Federal Bureau of Investigation’s National Instant criminal Background Check System;” ix(17) your communications about the COVID-19 pandemic having led to significant increases in gun sales throughout the United States of America (U.S.A); x (18) your communications about the Joe Biden – Kamala Harris White House administration “comprehensive strategy to prevent and respond to gun violence and ensure public safety;” (19) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “establish zero tolerance for rogue gun dealers that willfully violate the law;”xi (20) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “maximize the efficacy of ATF resources to crack down on rogue gun dealers violating” U.S laws; (21) your communications about the decision of the Bureau of Alcohol, Tobacco and W (AACL) – MICHAEL A. AYELE 2

24. RECORDS REQUEST 04/03/2022 Firearms (ATF) to designate a “specific point of contact in every field division for mayors, police chiefs, or other local leaders to report concerns about particular dealers’ compliance with the law;” (22) the name(s), the academic background(s), the professional responsibility(ies) and annual salary(ies) of the ATF point of contact serving in your City & County for the purpose of auditioning your concerns about gun violence as well as your conversations with them; (23) your communications about the actions taken by the Joe Biden – Kamala Harris administration to launch a multijurisdictional firearms trafficking strike force; (24) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “provide the public with additional data to promote transparency and accountability in enforcement of federally licensed firearms dealer policies;” (25) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “convene state legislators and Attorneys General regarding policy strategies to hold gun dealers and manufacturers accountable for their contribution to the flow of crime guns;”xii (26) your communications about the actions taken by the Joe Biden – Kamala Harris administration to expand “summer programming, employment opportunities, and other services and supports, especially for teenagers and young adults;”xiii (27) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “help formerly incarcerated individuals successfully reenter their communities;” xiv (28) your communications about the actions taken by the Joe Biden – Kamala Harris administration to “expand federal hiring of formerly incarcerated persons;”xv (29) your communications about the DOJ’s Hiring Second Chance Act Fellow; xvi(30) your communications about the actions taken by the Joe Biden –Kamala Harris administration to “leverage tax credits to incentivize hiring of formerly incarcerated individuals;” xvii (31) your communications about the additional actions taken by the Joe Biden –Kamala Harris administration to “reduce gun crime;”xviii (32) your communications about the Freedom of Information Act (FOIA) appeal submitted by Michael A. Ayele (a.k.a) W citing several inconsistencies in the manner the Department of the Interior (DOI) had processed his records request dealing with the gun violence public health epidemic and the executive branch of government; xix (33) the communications between the Government of Mexico and the Department of State before the filing of their complaint, which was assigned in the United States District Court for the District of Massachusetts Case Number 1:21 – cv – 11269 – FDS; (34) your communications about the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the trafficking of their guns to drug cartels through straw purchasing,xx repeat sales, kitchen table sales, ‘missing’ guns and firearm shows;” (35) your communications about the decision of the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the trafficking of their guns to drug cartels” by “designing and marketing their rifles as military style assault weapons;” (36) your communications about the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the trafficking of their guns to drug cartels” by “designing their guns to allow use by unauthorized persons;” (37) your communications about the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the trafficking of their guns to drug cartels” by “designing their guns to enable defacement of serial numbers;” (38) your communications about the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and W (AACL) – MICHAEL A. AYELE 3

25. RECORDS REQUEST 04/03/2022 facilitating the trafficking of their guns to drug cartels” by “refusing to implement the reforms they know are necessary;” (39) your communications about the decision of the Government of Mexico to accuse U.S gun manufacturers of “assisting and facilitating the unlawful trafficking of their guns because it maximized their sales and profits;” (40) your communications about the backing provided to the Mexican government’s federal lawsuit, which was assigned by the U.S District Court for the District of Massachusetts Case Number 1: 21 – cv – 11269 – FDS; xxi (41) your communications about the decision of the Government of Mexico to legalize marijuana/cannabis for recreational purposes; xxii (42) your communications about the memorandum of understanding (MOU)concluded between the EEOC and the Government of Mexico on September 02nd 2021; (43) the communications between the EEOC and the Government of Mexico before the conclusion of the MOU; (44) the MOU concluded between the EEOC and the Government of Mexico; xxiii (45) the documents outlining the impact of the December 2012 mass shooting at Sandy Hook Elementary School on the City of Escondido, California; (46) your communications about the settlement agreement concluded between the families of the Sandy Hook Elementary School and the gun manufacturer, Remington;xxiv (47) your communications about the response provided by the District of Columbia Government (DC.Gov) Office of Police Complaint (OPC) to the FOIA request submitted by Michael A. Ayele (a.k.a) W dealing with the March for Our Lives Rally; xxv (48) your communications about the letter written by D.C Mayor Muriel Bowser on December 10th 2021 dealing with gun violence in the capital of the U.S; xxvi (49) your communications about Missouri’s Second Amendment Preservation Act; (50) your communications about Missouri’s Second Amendment Preservation Act declaring “that federal supremacy does not apply to federal laws that restrict or prohibit the manufacture, ownership, and use of firearms, firearm accessories, or ammunition within the state because such laws exceed the scope of the federal government’s authority;” (51) your communications about Missouri’s Second Amendment Preservation Act declaring as “invalid all federal laws that infringe on the right to bear arms under the Second Amendment to the U.S Constitution and Article I, Section 23 of the Missouri Constitution;” (52) your communications about Missouri’s Second Amendment Preservation Act holding the courts and law enforcement agencies responsible for protecting the “rights of law-abiding citizens to keep and bear arms;” (53) your communications Missouri’s Second Amendment Preservation Act subjecting a civil penalty of $50,000 upon any “public officer or state or local employee who tries to enforce the firearms law declared invalid by the act or any person who acts under the color of law to deprive a Missouri citizen of rights or privileges ensured by the federal and state constitution;” (54) your communications about Missouri’s Second Amendment Preservation Act providing people the opportunity to “pursue an action for injunctive relief in the circuit court of the county in which the action allegedly occurred or in the circuit court of Cole County;”xxvii (55) your communications about the complaint filed by the City & County of Saint Louis, Missouri in the Missouri Circuit Court for Cole County; (56) your communications about the decision of the City & County of Saint Louis to note in their complaint that “House Bill 85 is a radical, dangerous and obviously unconstitutional attempt to declare that Missouri will refuse to follow federal gun laws;” (57) your communications about the decision of the City & County of Saint Louis to note in their complaint that “Governor Parson and the Republican legislature W (AACL) – MICHAEL A. AYELE 4

26. RECORDS REQUEST 04/03/2022 have (…) chosen to preserve Missouri’s growing reputation for extremist and dangerous laws;” (58) your communications about the decision of the City & County of Saint Louis to note in their complaint that “HB 85 violates the United States Constitution’s Supremacy Clause, which provides that federal law preempts state law;” (59) your communications about the decision of the City & County of Saint Louis to note in their complaint that “in misguided zeal to prevent imaginary threats to the right to keep and bear arms, the political branches in our state government blatantly violated the federal and state constitutions by attempting to nullify federal gun laws;” (60) the communications between the City & County of Saint Louis before the filing of their complaint in the Missouri Circuit Court for Cole County; (61) the communications between Jackson County, the City & County of Saint Louis and the judge assigned to their complaint in the Missouri Circuit Court for Cole County (Daniel Green);xxviii (62) your communications about Cori Bush as Missouri’s first Black Congresswoman who previously worked as a registered nurse (R.N); (63) your communications about the car of Cori Bush having been struck by gunfire while it was parked in the St. Louis area on January 2022;xxix (64) your communications about Amnesty International defining mass shootings as shootings where four or more victims are killed;xxx (65) your communications about the May 2021 murder-suicide mass shooting rampage at Santa Clara Valley Transportation Authority (VTA); (66) your communications about Samuel Cassidy as a Caucasian man who was employed for the VTA before he carried out the murder-suicide mass shooting rampage; (67) your communications about the reasons, which led Samuel Cassidy to carry out a murder-suicide mass shooting rampage at his previous place of employment; (68) your communications about Samuel Cassidy as a Caucasian man, who according to his ex-girlfriend had been diagnosed with bipolar disorder; (69) your communications about Samuel Cassidy as a Caucasian man, who had previously been questioned by the Department of Homeland Security (DHS) Customs & Border Patrol (CPB) on the issue of his “hatred for the VTA;” xxxi (70) the DHS (CBP) memo on Samuel Cassidy; xxxii (71) the complaints filed by Samuel Cassidy with the EEOC and/or the California Department of Fair Employment & Housing (DFEH) alleging discriminatory practices ongoing in the VTA; (72) your communications about the open-letter penned by San Jose Mayor Samuel Liccardo following the murder-suicide mass shooting rampage carried out by Samuel Cassidy; xxxiii (73) your communications about San Jose becoming the first U.S city to mandate gun liability insurance;xxxiv (74) the possibility of your city/county following the lead of San Jose, California in requiring gun liability insurance; (75) your communications about the impact of gun violence on public health and the “right to education;” xxxv (76) the academic backgrounds, the professional responsibilities and annual salaries of Jonathan M. Young, Phoebe Ball, Jeff Rosen, Tishaura Jones, Sam Page, Caleb Clifford, Frank White, Crystal Williams, Jalen Anderson, Kevin Merritt, Daniel Green, Frederic Winston, Chris Nuelle, Beth Orwick, Matt Moak, Heidi L. Leopold, Robert H. Dieker, Steve D. Shadowen, Jonathan E. Lowy, Richard M. Burnell, Craig Fair and Laurie Smith. II) Request for a Fee Waiver and Expedited Processing W (AACL) – MICHAEL A. AYELE 5

27. RECORDS REQUEST 04/03/2022 According to Amnesty International, “among wealthier, developed countries, the USA is an outlier when it comes to firearm violence. US governments have allowed gun violence to become a human rights crisis. Wide access to firearms and loose regulations lead to more than 39,000 men, women and children being killed with guns each year in the USA. On average, more than 360 people in the USA are shot every day and survive – at least long enough to get to a hospital. In 2017, some 39,773 died from gunshot injuries, an average of nearly 109 people each day. Per capita, this is significantly higher than in other industrialized countries. Firearm homicides in the USA disproportionately impact communities of color and particularly young black men. (…) 14,542 people in the USA lost their lives in gun homicides in 2017. African Americans accounted for 58.5% of these nationwide, despite making up just 13% of the U.S population. Firearm homicide was the leading cause of death for black men and boys aged 15-34 in 2017, and they were more than 10 times more likely to die from firearm homicide than white men and boys of the same age group. Failure to address systemic discrimination; failure to keep firearms out of the hands of those most likely to misuse them; and a failure to invest in gun violence prevention programs all contribute to this crisis. Women facing domestic violence and children are also disproportionately affected. (…) Most children who are victims of firearm killings in the USA are from minority communities. Homicide is the second leading cause of death among black children and 65% of those killings are committed with guns.”xxxvi In my opinion, the facts presented by Amnesty International about gun violence in the U.S.A are not elements, which tend to bolster public confidence in the activities of the government or their efforts to reduce and eradicate gun related crimes. The core issues presented in my records request are the following. 1) Have you had any conversations among yourselves about the December 14th 2012 mass-shooting at Sandy Hook Elementary School? xxxvii Have you had any conversations about the settlement agreement concluded between the families of victims in the Sandy Hook Elementary School shooting and the gun manufacturer, Remington? 2) Have you had any conversations about the January 2013 letter of the NCD addressed to then Vice- President Joe Biden advising him to “ensure that identification and isolation of individuals who have harmed others or are at risk of committing acts of violence does not lead to unnecessary expansion in institutionalization, involuntary commitment and forced treatment for individuals who may benefit from mental health services and supports but pose no risk of violence and have a basic human rights to make independent decisions?” Have you had any conversations about the January 2013 letter of the NCD addressed to then Vice-President Joe Biden informing him that “federal legislation calling for forced medication or treatment would restrict the fundamental civil rights of people with psychiatric disabilities?” Have you had any conversations about the risk of conflating mental health disabilities with gun violence? Have you previously reached out to the point of contact representing the ATF for the purpose of expressing specific concerns you have about gun violence in your City & County? If yes, will you promptly disclose those conversations that you have had amongst yourselves, other government officials not listed on this records request, the DOJ and/or the NCD? 3) Have you previously had conversations about the significant damages caused by U.S gun manufacturers (such as Smith & Wesson, Beretta, Century Arms, Colt, Glock, and Ruger) on the population in Mexico? To the extent of your knowledge, has the Government of Mexico contacted the U.S Department of State before filing their complaint with the U.S District Court for the District of Massachusetts? Has your City & County government previously considered filing an Amicus Curiae brief in support of the Government of Mexico? If yes, will you promptly disclose the pertinent records that are within W (AACL) – MICHAEL A. AYELE 6

28. RECORDS REQUEST 04/03/2022 your possession? 4) Have you had any conversations amongst yourselves about the mass- shooting at Santa Clara’s VTA? Have your offices formed an opinion about the responsibility that should be taken by the DHS (CBP) for the mass shooting rampage of May 2021 at Santa Clara’s VTA? Has your City & County government made any plans for the future to follow the lead of San Jose, California by requiring gun owners to have liability insurance? Have you had any conversations about the salary of Samuel Cassidy at the Santa Clara’s VTA? xxxviii Taking into consideration that Samuel Cassidy earned over $160,000 working for the Santa Clara’s VTA in 2019, do working conditions there sound like a coal mine to you? Has your City & County government concluded any formal and/or informal opinions about white privilege and entitlement? Who’s the ATF point of contact serving your city/county government since the Joe Biden –Kamala Harris White House administration announced their “comprehensive strategy to prevent and respond to gun violence and ensure public safety?” Have members of your police/sheriff departments begun coordinating with the ATF for the purpose of addressing your specific concerns about gun violence? If yes, will you promptly disclose your communications with the ATF point of contact serving in your jurisdiction? On the bases of the issues that have been raised, I believe this records request should be expedited and all fees waived. In my judgment, the records I have requested to be promptly disclosed (1) puts into question the government’s integrity because of decisions that have adversely impacted public confidence about the manner in which women and racial minorities are treated in the United States of America (U.S.A); (2) identifies operations and activities of the federal government in concert with U.S local and state government; (3) are meaningfully informative about government operations or activities in order to be ‘likely to contribute’ to and increase public understanding of those operations or activities. I hereby declare under penalty of perjury that all the statements I have made are to the best of my knowledge true and accurate. Have a good day. Take care. Keep yourselves at arms distance. Respectfully submitted: W (AACL) Michael A. Ayele Anti-Racist Human Rights Activist Audio-Visual Media Analyst Anti-Propaganda Journalist W (AACL) – MICHAEL A. AYELE 7

29. RECORDS REQUEST 04/03/2022 Work Cited iPlease be advised that I have previously disseminated a vast number of documents obtained through records request via Archive.org, Scribd.com, Medium.com and YouTube.com. These documents have been made available to the public at no financial expense to them. As a member of the media, I would like to take this opportunity to inform you that the records you disclose to me could be made available to the general public through the means I have mentioned above or other ones. On December 10th 2021, I have launched a website on Wordpress.com for the purpose of making the records previously disclosed to me by the U.S government further accessible to members of the general public interested in the activities of their elected and non- elected representatives. You can find out more about the recent publications of the Association for the Advancement of Civil Liberties (AACL) here.: https://michaelayeleaacl.wordpress.com/ ii Letter to Vice President Biden Regarding Anticipated Taskforce Recommendations Dear Mr. Vice President: I write to bring to your attention critical recommendations on behalf of the National Council on Disability (NCD), an independent federal agency comprised of 15 presidential appointees charged with providing advice to the President and Congress on disability policy. NCD applauds your leadership on the gun violence task force because the tragedy of Newtown has touched all of us in a deep and abiding way and decisive action is warranted. NCD affirms its support for efforts to improve the quality, availability, and affordability of mental health services and supports. NCD also remains concerned about the risk of taking reflexive actions that may appear to be designed to prevent future Newtown tragedies but have other unintended and undesirable consequences in worsening rather than improving access to mental health services and supports. The principal challenge is that access to mental health services is already compromised by deep and enduring stigma about seeking and receiving mental health treatment. We cannot afford to exacerbate harmful stereotypes about mental illness even as we must act to ensure that all individuals with mental health needs can get help when they need it and help ensure that people who pose significant risks of harming and killing others do not have the opportunity to do so. A basic fact endures: people with psychiatric disabilities are more often the victims of violence than they are the perpetrators of violence. We must recognize the risk of increasing one type of violence while we seek to reduce another type. Earlier today the Council adopted a series of recommendations during a Special Meeting called specifically to consider recommendations to your task force and review certain legislative and policy proposals that may prove more harmful than beneficial. We urge you to pay careful consideration to these recommendations as you finalize your own recommendations and begin to implement them. As we stated at the creation of your task force, NCD remains willing to work with you and your staff as the work of your task force unfolds. W (AACL) – MICHAEL A. AYELE 8

30. RECORDS REQUEST 04/03/2022 First, NCD recommends you develop a framework to invest in community-based mental health supports and programs. Existing federal research reveals a profound shortage of community- based services, including mobile crisis services and peer supports. Community mental health programs can offer excellent, comprehensive services when sufficiently funded and supported. Unfortunately, the severe deficiency in current resources means that these services are often available only to people who are in immediate crisis and who have already endured multiple hospitalizations. Recently, pilot programs have been developed across the country to better meet the needs of people when they have their first psychotic episode. These programs are community- based and help to address critical unmet needs. NCD encourages the Taskforce to advance policy recommendations in line with these models and the principles undergirding them. Second, NCD urges you to avoid any proposal to link the Social Security Administration's database of representative payees with the FBI's National Instant Criminal Background Check System (NICS). Whatever merits such a proposal might seem to present, such benefits are outweighed by the inaccurate and discriminatory inference that would result: equating the need for assistance in managing one's finances with a presumption of incapacity in other areas of life. Maximizing self-direction is critical to enabling people with disabilities to meet the goals of the ADA: equality of opportunity, full participation, independent living, and economic self- sufficiency. Many people with disabilities and seniors rely on representative payees as a practical measure to facilitate income support. There should not be any permissible inference that use of a representative payee signals impairment of decision-making—whether it be in casting votes or choosing health care providers. Linking the representative payee system and the NICS would support just such an inference. NCD recommends you ensure that the selection of a representative payee continues to have no implication on other areas of rights beyond financial decision-making. Third, NCD urges you to avoid any proposal comparable to the provision of S. 436, the Fix Gun Checks Act, which amends the Higher Education Act to require colleges and universities to outline procedures for the involuntary referrals of students with perceived psychiatric disabilities for evaluation and institutionalization. As set forth in its first recommendation, NCD maintains that enhanced access to mental health services and supports is critical. We also understand that current law properly requires that knowledge of an immediate threat to safety is reported and addressed. However, a policy that broadly targets individuals who have not exhibited a threat of harm risks increasing discrimination and stigmatization for college students and could have the chilling effect of discouraging students from seeking the very mental health services they need in times of distress. Universities across the country are making progress with mental health programs on campus and are showing positive results. NCD supports increased opportunity for peer-to-peer support and campus-based counseling programs, and encourages campus policies that focus on making these resources more broadly available. Finally, NCD urges you to ensure that identification and isolation of individuals who have harmed others or are at risk of committing acts of violence does not lead to unnecessary expansion in institutionalization, involuntary commitment and forced treatment for individuals who may benefit from mental health services and supports but pose no risk of violence and have a basic human right to make independent decisions. There is no current system capable of W (AACL) – MICHAEL A. AYELE 9

31. RECORDS REQUEST 04/03/2022 reliably identifying persons who are likely to become dangerous, and there is not established correlation between psychiatric diagnosis and violent behavior. Federal legislation calling for forced medication or treatment would restrict the fundamental civil rights of people with psychiatric disabilities. Incarcerating individuals for punishment of crimes committed is central to our criminal justice system. But incarceration and forced treatment of stigmatized individuals based on misplaced fears and stereotypes has no place in our civil society. Institutional care has a long-standing history of poor outcomes and civil rights violation among persons with psychiatric disabilities. Thank you for your thoughtful consideration of NCD’s recommendations. We remain ready to assist and advise your task force, the Administration, and leaders of Congress to best meet the health, safety and security needs of the American public, including Americans with psychiatric disabilities. Very Respectfully, Jonathan M. Young, PhD, JD Chairman, National Council on Disability. National Council on Disability (NCD), January 14th 2013.: https://ncd.gov/publications/2013/Jan142013 iiiSt. Louis and adjoining St. Louis County filed a lawsuit Monday seeking to block Missouri's new law barring state and local authorities from enforcing federal gun laws, saying the law would increase the risk of gun violence in a state already drowning in it. The suit filed in Cole County Circuit Court seeks an injunction to halt enforcement of the law and to overturn it on the grounds that it violates the Constitution's Supremacy Clause, which established that federal law trumps state law. The law, which Republican Gov. Mike Parson signed this month, would subject law enforcement agencies with officers who knowingly enforce any federal gun laws to a fine of about $50,000 per violating officer. Republican lawmakers who championed the legislation said they were motivated by the possibility that gun restrictions could be tightened by President Joe Biden's administration. Democrats said the law is unconstitutional and predicted it wouldn't survive a court challenge. Democratic St. Louis Mayor Tishaura Jones said the law is not only unconstitutional, but dangerous. She noted that 2020 was among the deadliest years ever for gun violence in Missouri. St. Louis had its deadliest year in a half-century. Kansas City, meanwhile, saw a record number of killings last year. St. Louis County Executive Sam Page, also a Democrat, said the region can't prosper if people don't feel safe. “This new law is like the state holding out a sign that says ‘Come Commit Gun Violence Here,’” Page said in a statement. Jackson County Executive Frank White says he W (AACL) – MICHAEL A. AYELE 10

32. RECORDS REQUEST 04/03/2022 supports the lawsuit filed by the city and county of St. Louis. "Given the unconstitutionality, but more importantly, the public safety risks this law presents, I believe our community and state would best be served by Jackson County joining this action and for HB 85 to ultimately be deemed unenforceable by the court,” White said in a letter to Jackson County legislators. White said he will be asking the county legislature to pass a resolution at its next meeting for the county to join the litigation. The U.S. Department of Justice, in a letter last week, warned Missouri officials that the state can’t ignore federal law. Parson and Attorney General Eric Schmitt responded that they still plan to enforce the new law. Schmitt’s spokesman, Chris Nuelle, called the lawsuit a “partisan” maneuver by “progressive politicians.” “We will continue our efforts to prosecute violent crime, and we will not shy away from defending the Second Amendment rights of law abiding citizens,” Nuelle said. The state law also prompted the resignation of the police chief of O’Fallon, a St. Louis suburb that is home to about 89,000 people and is the state's seventh-largest city. The outgoing chief, Philip Dupuis, said in a statement this month that the law would “decrease public safety and increase frivolous lawsuits designed to harass and penalize good, hard- working law enforcement agencies.” Several states passed similar laws this year, including Arizona, Arkansas, Idaho, Montana, Oklahoma, Tennessee, Texas and West Virginia. Missouri’s law went further than most in its possible punishments for officers who do enforce federal gun laws. Several states also passed similar laws during Barack Obama's time in the White House, but judges ruled against them. Saint Louis city and county sue to block new Missouri gun law, ABC News.: https://abcnews.go.com/Politics/wireStory/st-louis-city-county-sue-block-missouri-gun- 78408265 ivPlaintiff Estados Unidos Mexicanos (the “Government”), a sovereign nation, brings this action to put an end to the massive damage that the Defendants cause by actively facilitating the unlawful trafficking of their guns to drug cartels and other criminals in Mexico. Almost all guns recovered at crime scenes in Mexico—70% to 90% of them—were trafficked from the U.S. The Defendants include the six U.S.-based manufacturers whose guns are most often recovered in Mexico—Smith & Wesson, Beretta, Century Arms, Colt, Glock, and Ruger. Another manufacturer defendant is Barrett, whose .50 caliber sniper rifle is a weapon of war prized by the drug cartels. The remaining defendant— Interstate Arms—is a Boston-area wholesaler through which all but one of the defendant manufacturers sell their guns for re-sale to gun dealers throughout the U.S. (…) For decades the Government and its citizens have been victimized by a deadly flood of military-style and other particularly lethal guns that flows from the U.S. across the border, into criminal hands in Mexico. This flood is not a natural phenomenon or an inevitable consequence of the gun business or of U.S. gun laws. It is the foreseeable result of the Defendants’ deliberate actions and business practices. (…) Defendants design, market, distribute, and sell guns in ways they know routinely arm the drug cartels in Mexico. Defendants use reckless and corrupt gun dealers and dangerous and illegal sales practices that the cartels rely on to get their guns. Defendants design these guns to be easily modified to fire automatically and to be readily transferable on the criminal market in Mexico. Defendants W (AACL) – MICHAEL A. AYELE 11

33. RECORDS REQUEST 04/03/2022 know how to make and sell their guns to prevent this illegal trade; the U.S. government and a U.S. court told them how. Defendants defy those recommendations, and many others, and instead choose to continue supplying the criminal gun market in Mexico—because they profit from it. (…) The Government has strong domestic laws that make it virtually impossible for criminals to lawfully obtain guns in Mexico. Mexico has one gun store in the entire nation and issues fewer than 50 gun permits per year. (…) Defendants undermine these stringent laws, and wreak havoc in Mexican society, by persistently supplying a torrent of guns to the drug cartels. It is estimated that more than a half million guns annually are trafficked from the U.S. into Mexico. Defendants produce more than 68% of those U.S.-origin trafficked guns, which means that they annually sell more than 340,000 guns that flow from their plants in Massachusetts and other U.S. states to criminals south of the border. (…) Defendants are fully on notice of the massive trafficking of their guns into Mexico. It has been extensively documented in news accounts, academic studies, government reports, United Nations inquiries and reviews, and law enforcement “traces” of guns from crime scenes in Mexico to the Defendants’ factories in the U.S. (…) Despite this abundant notice, Defendants have not implemented any public-safety-related monitoring or disciplining controls on their distribution systems—none at all. Their policy is to sell to any distributor or dealer that has a U.S. license to buy and sell the product, regardless of the buyer’s record of flouting the law and despite blazing red flags indicating that a gun dealer is conspiring with straw purchasers or others to traffic Defendants’ guns into Mexico. Defendants use this head-in-the-sand approach to deny responsibility while knowingly profiting from the criminal trade. (…) Defendants exacerbate their refusal to monitor and discipline their distribution systems by designing military-style assault weapons and marketing them in ways that attract and arm ruthless transnational criminal organizations like the drug cartels.(…) The consequences in Mexico have been dire. In addition to causing the exponential growth in the homicide rate, Defendants’ conduct has had an overall destabilizing effect on Mexican society. Late 2004 saw the drug cartels’ first assassination of a Mexican Mayor, followed in later years by their use of Defendants’ military-style weapons to attack the Mexican military and police, and by rampant increases in other gun-related crimes such as extortion and kidnapping (…) Defendants’ willfully blind, standardless distribution practices aid and abet the killing and maiming of children, judges, journalists, police, and ordinary citizens throughout Mexico. Defendants’ unlawful conduct has substantially reduced the life expectancy of Mexican citizens and cost the Government billions of dollars a year. And armed with Defendants’ guns, the cartels have aggressively marketed drugs such as fentanyl, destroying and ending lives in and outside of Mexico, including in the U.S. Defendants’ guns are the venom in the snakes that are the drug cartels; without those guns, they could be controlled and stopped. (…) Defendants are not accidental or unintentional players in this tragedy; they are deliberate and willing participants, reaping profits from the criminal market they knowingly supply—heedless of the shattering consequences to the Government and its citizens. (…) This need not happen. In a 2003 domestic public nuisance case against U.S. gun manufacturers and distributors—including Defendants Beretta, Century Arms, Colt, Glock, Smith & Wesson, Ruger, and Interstate—the late United States District Court Judge Jack B. Weinstein found as a fact after a trial that “each manufacturer should implement readily available reforms,” including “imposing liability insurance standards; limiting sales at gun shows; limiting multiple sales; limiting how the consumer gun transaction can be conducted to insure security; education and training of dealers; and monitoring dealers through visitation and other regular interaction.” NAACP v. AcuSport, Inc., 271 F. Supp. 2d 435, 523 (E.D.N.Y. 2003). Gun industry insiders have urged Defendants to make similar reforms. (…) In 2001, the U.S. federal government similarly called on Defendants to monitor, supervise, and set reasonable conditions for their distribution systems to prevent supplying criminals. Defendants refused. Defendant Smith & Wesson entered into a settlement agreement with the United States and several U.S. cities, committing to specific distribution-system reforms designed W (AACL) – MICHAEL A. AYELE 12

34. RECORDS REQUEST 04/03/2022 to prevent supplying guns to the criminal market. Under pressure from others in the industry, Smith & Wesson reneged on the agreement. (…) Defendants instead closed ranks with other industry participants to lobby the U.S. Congress for legislation to protect them in certain instances from liability for domestic injuries resulting from their conduct. Congress responded by enacting the Protection of Lawful Commerce in Arms Act (“PLCAA”) in 2005, which protects gun companies from some liability for harm solely caused by the unlawful misuse of guns in the U.S. resulting in injury in the U.S. (…) Defendants know that their porous distribution systems cause guns to be routinely trafficked over the border into Mexico, resulting in vast and continual harm to the Government and its people. They therefore must monitor and discipline those distribution systems to comply with not only U.S. law, but also the substantive law of Mexico, including its tort law. (…) The Supreme Court of the United States has repeatedly held that, where conduct in one nation causes injury in another the “default rule for tort cases” is that “the local law of the state where the injury occurred determines the rights and liabilities of the parties,” Sosa v. Alvarez-Machain, 542 U.S. 692 (2004), and that “a court will ordinarily apply foreign law to determine the tortfeasor’s liability to a plaintiff injured in a foreign country,” RJR Nabisco, Inc. v. European Community, 136 S. Ct. 2090, 2109 (2016). And RJR Nabisco emphasized that where U.S.-based corporations cause injury abroad to foreign sovereigns, the U.S. Constitution and statutes allow those sovereigns to sue for “violations of their own laws and to invoke federal diversity jurisdiction as a basis for proceeding in U.S. courts.” Id. (…) The U.S. Congress honored this principle of trans-national torts when it enacted PLCAA. Even if applied, PLCAA would not bar the Government’s case. But it does not apply because it bars certain claims against gun manufacturers and distributors only when the injury occurred in the U.S. and the criminal’s misuse of the gun was unlawful under U.S. domestic law. The Government’s injuries here occur in Mexico, and its claims result from unlawful misuse of guns in Mexico, not in the U.S. Every aspect of PLCAA confirms that the U.S. Congress enacted that statute with only U.S. domestic concerns in mind. (…) Just as Defendants may not dump toxic waste or other pollutants to poison Mexicans across the border, they may not send their weapons of war into the hands of the cartels, causing repeated and grievous harm, and then claim immunity from accountability. (…) To be clear, this lawsuit does not challenge or question the law, policy, or actions of the United States; the Government seeks to hold accountable and stop the reckless actions of private companies that foreseeably send their guns into Mexico. (…) Likewise, this case has nothing to do with the Second Amendment right of law-abiding, responsible U.S. citizens to keep and bear arms within the U.S. This case involves Defendants’ supplying their guns to law-breaking Mexican nationals and others in Mexico. The cartels have no Second Amendment rights, and the Defendants have no right to supply them. (…) The flow of guns from Defendants’ U.S. manufacturing plants and stores to the streets of Mexico is not an inevitable, natural phenomenon like the migration of monarch butterflies. Nor is it a necessary consequence of selling a lethal product or of U.S. gun laws. (…) The flow of guns into Mexico is a foreseeable result of Defendants’ deliberate and knowing decisions to design, market, distribute, and sell guns in ways they know with virtual certainty will supply criminals in Mexico. (…) Defendants know they have an obligation to help enforce the gun laws, and not to circumvent them. But Defendants continually violate and actively undermine these laws in order to profit from the criminal market in Mexico. (…) The cartels that cause such bloodshed and terror may fire Defendants’ guns in Mexico, but they are able to do so only because of deliberate decisions made in Massachusetts and in the other Defendants’ domestic corporate offices. (…) For years Defendants have been confronted with a mountain of facts that make clear that their chosen business practices routinely arm the cartels in Mexico with massive and lethal arsenals. (…) The U.S. federal government has determined that Defendants’ guns are the overwhelming source of the cartels’ arsenals, and that the trafficking of Defendants’ guns across the W (AACL) – MICHAEL A. AYELE 13

35. RECORDS REQUEST 04/03/2022 border into Mexico is a crisis of extraordinary proportions. Media reports, trafficking prosecutions, reported cases, articles, trace data, and other information confirm the same facts. (…) Defendants’ response to this mountain of information has been to double down on their unlawful practices and fight law enforcement efforts to stop the trafficking. (…) Defendants have undermined the social policy, in addition to the aspirations, of the Government of Mexico and its people. The Government bears many direct and indirect costs from these harms, including those identified above. Given their share of guns trafficked into Mexico, the Defendants are responsible for close to half of these losses. (…) Defendants’ deliberate conduct that floods Mexico with their guns causes untold harm to the Government. Some of those damages are outlined above. Were it not for Defendants’ wrongful conduct, there would be far fewer guns in Mexico, and far fewer guns in the hands of the cartels. There might still be snakes—in the form of criminal organizations—but they would have far less venom to inflict harm. (…) Life in Mexico would be a far different place if that were so—a safer place, a place in which fewer tax dollars would be spent on preventing and responding to violence and drug trafficking, and more could be spent on education, social services, and other efforts to positively improve lives. (…) Everyday existence for the Mexican people would be far different if life could be led without dangers and threats from the armed cartels—less fear, more freedom to gather together and enjoy life. (…) And without the Defendants’ supply of crime guns, the less-armed cartels could be controlled and stopped far more easily and effectively. That would help stem the drug trade that kills not only Mexicans but people in other nations, including the United States. And it would reduce the violence that the cartels spread north of the border. (…) Defendants’ wrongful conduct also ends lives, extraordinary and wonderful lives of Mexicans from every walk of life, as illustrated by a small sampling of the tens of thousands of lives lost as a result of Defendants’ deliberate conduct. Estados Unidos Mexicanos v Smith & Wesson Brands, Inc et al; Courthouse News.: https://www.courthousenews.com/wp-content/uploads/2021/08/mexico-smith-wesson- complaint.pdf vSan Jose approved a novel ordinance Tuesday that will require gun owners to purchase liability insurance and pay an annual fee for their firearms. The ordinance is the first of its kind to be enacted by a major U.S. city. (…) The insurance must cover losses or damages from accidental or negligent use of a firearm, including death, injury or property damage. An owner would be considered liable for a lost gun until reporting the loss to police, according to the ordinance. The ordinance also requires gun owners to invest in safes, trigger locks and safety classes. The City Council will hold a second vote on Feb. 8 to ratify the ordinance. It would then go into effect in August. California law bans the sale and possession of magazines that hold more than 10 rounds. The state also has a red flag law that allows police to seize a person's guns based on a restraining order.(…) The annual fee will amount to roughly $25 and affect around 50,000 households, according to city data. The money will help fund city programs, including mental health, suicide prevention, domestic violence prevention and gun safety. The city estimates it spends $39 million each year to respond to gun violence, including emergency services, victim assistance and criminal investigations. In San Jose, an average of 206 people were killed or seriously injured in shootings each year from 2012 to 2018. The ordinance contains some exceptions for active or retired police officers and concealed weapon permit holders. San Jose will require gun owners to have liability insurance. Los Angeles Times on Yahoo!.: https://news.yahoo.com/san-jose-requires-gun-owners- 205023762.html?fr=sycsrp_catchall W (AACL) – MICHAEL A. AYELE 14

36. RECORDS REQUEST 04/03/2022 vi15 vice presidents who became president themselves, Business Insider.: https://www.insider.com/vice-presidents-who-became-president-2020-12 viiExcerpt of E-mail Sent by Michael A. Ayele (a.k.a) W to the Missouri Department of Mental Health (DMH) on September 01st 2021 Hello, Thank you for your email. I am in receipt of it. I've been thinking about your correspondence and the six-weeks training I had passed in Fiscal Year (F.Y) 2013 at the Fulton State Hospital (FSH). During the later stages of the 6 weeks training, I (alongside others) had the opportunity to visit in person the Biggs Forensic Center (BFC), the Guhleman Forensic Center (GFC) and Hearnes Forensic Center (HFC). During those visits to these facilities, I remember meeting for the 1st time certain patients/prisoners of the Department of Mental Health (DMH) who had a(n) intellectual/developmental disabilities (IDD). Though I am not 100% certain, I believe patients/prisoners with an IDD were housed in the Social Learning Program (SLP) and the New Outlook Program (NOP) of the BFC. Additionally, I remember being informed that certain patients/prisoners with an IDD had been in HFC for several years even though they had ceased to be an imminent threat to their lives as well as others. In fact, certain staff of the DMH had expressed concerns and worries about HFC for this specific reason. (…) What I am requesting for prompt disclosure are all records within your possession detailing (1) the training material provided to psychologists, psychiatrists and medical doctors regularly assigned to the SLP, the NOP and the minimum security facility (aka) HFC dealing with how to administer I.Q tests for the purpose of determining an IDD status; (2) all concerns and complaints filed by staff of the HFC about patients/prisoners who have ceased to pose an imminent threat to themselves as well as others being incarcerated for unduly long period of time instead of going to a less-restrictive environment; (3) all concerns and complaints filed by patients/prisoners of the HFC about being incarcerated for longer period of times than necessary; (4) documents of legal education provided to patients/prisoners of the FSH about their rights to file in the judicial branch of the Missouri government Habeas Corpus and/or Civil complaints; (5) the DMH policy about patients/prisoners of the FSH right to use the public library, computers and/or the internet. Have a good day. W (AACL) Michael A. Ayele Anti-Racist Human Rights Activist Audio-Visual Media Analyst Anti-Propaganda Journalist W (AACL) – MICHAEL A. AYELE 15

37. RECORDS REQUEST 04/03/2022 Response of the Missouri Department of Mental to Michael A. Ayele (a.k.a) W Sunshine Request of September 01st 2021 W, There are no records responsive for item 1). For items 2), 3), and 4) any records that might exist for individual patients and residents are closed in accordance with Section 630.140, RSMo. For item 5), see attached Fulton State Hospital policies. Sincerely, Janet Gordon Records Custodian Department of Mental Health Resources: Stressed by COVID-19? Access these resources for your emotional health: https://dmh.mo.gov/disaster-services/covid-19-information DHSS COVID-19 24 hour hotline: 877-435-8411 Disaster Distress Helpline: Phone 800/985-5990. Text “TalkWithUs” to 66746 Social Justice: https://dmh.mo.gov/disaster-services/coping-with-community-unrest MO Show Me Hope Crisis Counseling Program: https://www.moshowmehope.org/ CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may contain confidential and privileged information for the use of the designated recipients named above. The designated recipients are prohibited from redisclosing this information to any other party without authorization and are required to destroy the information after its stated need has been fulfilled. If you are not the intended recipient, you are hereby notified that you have received this communication in error and that any review, disclosure, dissemination, distribution or copying of it or its contents is prohibited by federal or state law. If you have received this communication in error, please notify me immediately by telephone at 573.751.8067, and destroy all copies of this communication and any attachments. viiiNCD has consistently expressed concern about the conflation of mental health disabilities with gun violence as a myth, which, in each instance of its use, exacerbates harmful stereotypes about psychiatric disability and increases the level of stigma associated with seeking and W (AACL) – MICHAEL A. AYELE 16

38. RECORDS REQUEST 04/03/2022 receiving mental health treatment. As an agency whose mission is focused on enhancing the quality of life for individuals with disabilities and their families, it is important to note that NCD takes no position with respect to many of the often debated issues around the availability of guns in our society. However, linking the need for a representative payee with a presumption of incapacity to exercise any right sets a dangerous precedent that undermines the goals of the ADA: equality of opportunity, full participation, independent living, and economic self- sufficiency.NCD Letter to Rep. Johnson about “Social Security Beneficiary 2nd Amendment Rights Protection Act.” https://ncd.gov/publications/2015/ncd-letter-rep-johnson-about-social- security-beneficiary-2nd-amendment-rights ix NCD has consistently taken the position that equating the need for assistance in managing one's finances with a false presumption of incapacity in other areas of life, including possession of a firearm, unnecessarily and unreasonably deprives individuals with disabilities of a constitutional right and increases the stigma that those who may need a representative payee. The overly broad classification of “mental disorder,” includes a wide range of limitations and a shifting set of criteria relevant to whether or not one can engage in substantial gainful activity. NCD remains steadfast in our position that this classification remains irrelevant to the question of whether one can be a responsible gun owner. NCD Applauds Senate Action on SSA NICS Rule.: https://ncd.gov/newsroom/2017/ncd-applauds-senate-action-ssa-nics-rule x Gun sales, which spiked sharply during the early months of the coronavirus pandemic, have continued to increase in the United States, with first-time buyers making up more than one-fifth of Americans who purchased guns. The development will frustrate and disappoint gun control advocates who point out the huge number of firearms already circulating in American society as well as a seemingly never-ending cycle of mass shootings. A study by the General Social Survey, a public opinion poll conducted by a research center at the University of Chicago, 39% of American households own guns, up from 32% in 2016. Separately, research data compiled by the FBI’s National Instant Criminal Background Check System (NICS), background checks that topped 1m a week in March 2020 – the highest since the government began tracking them in 1998 – and continued, with one week in April this year recording a record 1.2m checks. Background checks are seen as a reliable metric to track gun sales. A third data study, compiled by Northeastern University and the Harvard Injury Control Research Center and seen by the New York Times shows that 6.5% of US adults, or 17 million people, have purchased guns in the past year, up from 5.3% in 2019. Of those, almost one-fifth who bought guns last year were first- time gun owners of whom half were women, a fifth were Black and a fifth were Hispanic, challenging the stereotype of white male gun owners building personal arsenals. In 2021, gun owners overall were 63% male, 73% were white, 10% were Black and 12% Hispanic. Separately, The Trace, a non-partisan group that tracks gun sales, estimates 2.3m guns were purchased in January alone. Sales, which had remained largely flat for the duration of the Trump presidency, jumped 64% in 2020, the group said. Still, the increases are relatively small compared to the 400m guns estimated to already be in circulation, including at least 4m AR-15s, W (AACL) – MICHAEL A. AYELE 17

39. RECORDS REQUEST 04/03/2022 commonly described as assault rifles. “Americans are in an arms race with themselves,” South Los Angeles city council representative Marqueece Harris-Dawson told the New York Times. “There was just as much a run on guns as on toilet paper in the beginning of the pandemic.” Increased gun sales come as Texas this month became the 20th state to pass legislation that no longer requires a permit to carry a concealed handgun. At the same time, a rash of mass shootings, often involving AR-15 weapons have dominated headlines. According to the Gun Violence Archive, 67 mass shootings have taken place in May this year. The most recent occurred on Sunday when a gunman opened fire in Miami, killing two people and injuring 20 others. Authorities in Texas said on Monday they had arrested a man accused of plotting to carry out a mass shooting at a Walmart, and a search of the suspect’s home turned up firearms, ammunition and materials officials described as “radical ideology paraphernalia”. US gun sales spiked during pandemic and continue to rise, The Guardian.: https://www.theguardian.com/us- news/2021/may/31/us-gun-sales-rise-pandemic xiGun dealers across the country are regulated by federal law that is enforced by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). Dealers that fail to comply with their obligations under the law create risks for all of us. Today, the Justice Department is announcing a new policy to underscore zero tolerance for willful violations of the law by federally licensed firearms dealers that put public safety at risk. Absent extraordinary circumstances that would need to be justified to the Director, ATF will seek to revoke the licenses of dealers the first time that they violate federal law by willfully 1) transferring a firearm to a prohibited person, 2) failing to run a required background check, 3) falsifying records, such as a firearms transaction form, 4) failing to respond to an ATF tracing request, or 5) refusing to permit ATF to conduct an inspection in violation of the law. In addition, ATF will notify every firearms dealer whose license is revoked about how to lawfully transfer any remaining inventory, as well as the potential criminal consequences of continuing to engage in the business of buying and selling guns without a license. The prior Administration stopped this important notification practice that helps deter future unlawful activity. Fact Sheet: Biden – Harris Administration Announces Comprehensive Strategy to Prevent and Respond to Gun Crime and Ensure Public Safety, White House.: https://www.whitehouse.gov/briefing-room/statements-releases/2021/06/23/fact-sheet- biden-harris-administration-announces-comprehensive-strategy-to-prevent-and-respond-to-gun- crime-and-ensure-public-safety/ xiiThe President continues to call on Congress to repeal the Protection of Lawful Commerce in Arms Act (PLCAA), which gives gun dealers and manufacturers special immunity from certain liability for their products. In the meantime, the White House will convene state legislators and Attorneys General to discuss strategies for enacting and employing state liability laws that can be used to hold dealers and manufacturers accountable for improper conduct not covered by PLCAA. Fact Sheet: Biden – Harris Administration Announces Comprehensive Strategy to Prevent and Respond to Gun Crime and Ensure Public Safety, White House.: https://www.whitehouse.gov/briefing-room/statements-releases/2021/06/23/fact-sheet-biden- W (AACL) – MICHAEL A. AYELE 18

40. RECORDS REQUEST 04/03/2022 harris-administration-announces-comprehensive-strategy-to-prevent-and-respond-to-gun-crime- and-ensure-public-safety/ xiiiYoung people are disproportionately likely to be involved in gun violence, either as perpetrators or victims. We also know that youth employment programs, including summer jobs programs, can reduce their involvement in violence by as much as 35% or 45%. The Biden Administration is committed to funding workforce development programs to keep young people safe and give them a path to success. Fact Sheet: Biden – Harris Administration Announces Comprehensive Strategy to Prevent and Respond to Gun Crime and Ensure Public Safety, White House.: https://www.whitehouse.gov/briefing-room/statements-releases/2021/06/23/fact-sheet- biden-harris-administration-announces-comprehensive-strategy-to-prevent-and-respond-to-gun- crime-and-ensure-public-safety/ xivFormerly incarcerated individuals face an uphill climb in landing a job. Many employers are reluctant to hire them out of stigma, fear, or concern that they lack the skills needed for the job. But employment is a key to formerly incarcerated individuals’ successful reentry into their communities. Individuals who secure employment after release have much lower recidivism rates than those who do not. Good, stable jobs promote public safety. That is why the Administration is taking concrete steps to facilitate employment and associated services, such as housing assistance, for people who are formerly incarcerated. Fact Sheet: Biden – Harris Administration Announces Comprehensive Strategy to Prevent and Respond to Gun Crime and Ensure Public Safety, White House.: https://www.whitehouse.gov/briefing-room/statements- releases/2021/06/23/fact-sheet-biden-harris-administration-announces-comprehensive-strategy- to-prevent-and-respond-to-gun-crime-and-ensure-public-safety/ xv The Office of Personnel Management (OPM) will evaluate the existence of any barriers faced by formerly incarcerated persons in accessing federal employment and consider whether the federal government should take further action as appropriate, including creating a new “Schedule A” excepted service hiring authority for formerly incarcerated persons. This Schedule A hiring authority would allow federal agencies to hire qualified individuals for any job opening through the non-competitive, excepted service hiring process. Schedule A appointments are one- year temporary appointments with good benefits that can be extended for an additional year. Schedule A positions equip people with the skills and experience to become more competitive in the job market. Schedule A hiring authority has previously been created for veterans, people with disabilities, individuals on work release from incarceration, and people hired in direct response to the effects of the COVID-19 pandemic. Fact Sheet: Biden – Harris Administration Announces Comprehensive Strategy to Prevent and Respond to Gun Crime and Ensure Public Safety, White House.: https://www.whitehouse.gov/briefing-room/statements-releases/2021/06/23/fact-sheet- biden-harris-administration-announces-comprehensive-strategy-to-prevent-and-respond-to-gun- crime-and-ensure-public-safety/ W (AACL) – MICHAEL A. AYELE 19

41. RECORDS REQUEST 04/03/2022 xviThe Department of Justice plans to post an application next month for a formerly incarcerated individual to work at DOJ as a Second Chance Act visiting fellow. This is a unique opportunity to draw on the expertise of a formerly incarcerated person as a policy advocate, legal or social services provider, or academic focusing on the successful reintegration of people returning home to their communities after incarceration. The fellow will develop innovative strategies that build upon and improve DOJ’s investments in reentry and reintegration.Fact Sheet: Biden – Harris Administration Announces Comprehensive Strategy to Prevent and Respond to Gun Crime and Ensure Public Safety, White House.: https://www.whitehouse.gov/briefing-room/statements- releases/2021/06/23/fact-sheet-biden-harris-administration-announces-comprehensive-strategy- to-prevent-and-respond-to-gun-crime-and-ensure-public-safety/ xviiThe Department of Labor and Department of the Treasury will help employers leverage the Work Opportunity Tax Credit (WOTC), which includes incentivizes to hire formerly incarcerated individuals. Under WOTC, employers can receive up to a $2,400 credit against federal income taxes for hiring a person within one year of their conviction or release from prison for a felony offense. The Departments of Labor and Treasury will encourage employers to take up this opportunity to hire formerly incarcerated individuals. Specifically, within 90 days, the Departments will issue guidance, provide technical assistance to state workforce agencies, and release materials on ways employers can leverage this tax credit and other resources, such as the Federal Bonding Program and the American Rescue Plan’s Employee Retention Credit (ERC). For example, a small business that hires someone who was released in the last twelve months and employs them through the second half of the year could qualify for a credit of up to $16,400 per worker by claiming both the WOTC and the ERC. The Department of the Treasury will also revise online materials to make it easier to claim the tax credit. Fact Sheet: Biden – Harris Administration Announces Comprehensive Strategy to Prevent and Respond to Gun Crime and Ensure Public Safety, White House.: https://www.whitehouse.gov/briefing- room/statements-releases/2021/06/23/fact-sheet-biden-harris-administration-announces- comprehensive-strategy-to-prevent-and-respond-to-gun-crime-and-ensure-public-safety/ xviiiPresident Biden Announces More Actions to Reduce Gun Crime and Calls on Congress to Fund Community Policing and Community Violence Intervention, White House.: https://www.whitehouse.gov/briefing-room/speeches-remarks/2022/02/03/president-biden- announces-more-actions-to-reduce-gun-crime-and-calls-on-congress-to-fund-community- policing-and-community-violence-intervention/ xix W (AACL) – Michael A. Ayele Statement in Response to Inconsistencies Within the Department of the Interior (DOI) The Association for the Advancement of Civil Liberties (AACL) acknowledges the existence of a gun-violence public health epidemic in the United States of America (USA). The AACL has found several actions taken by the DOI National Park Services (NPS) to be regrettable because they were not the sort to foster good ties and relationships between the government, the media W (AACL) – MICHAEL A. AYELE 20

42. RECORDS REQUEST 04/03/2022 and the general public. The AACL is specifically worried about the DOI (NPS) failure to grant the AACL the opportunity to submit new requests in connection with the executive branch of the U.S government to avoid paying fees in circumstances where the time to conduct a search at no cost (to the representative of the media and/or the member of the general public) has elapsed. The decision of the DOI (NPS) to charge (a financially restricted NGO) fees in connection to a records request, where a fee waiver was requested, is in the opinion of the AACL negative one. Furthermore, the actions taken by the DOI (NPS) are not consistent with several previous decisions made by the DOI to consider the AACL as a representative of the news media for the purpose of the Freedom of Information Act (FOIA). By letter dated March 26th 2021, the DOI Geological Survey had granted the AACL request for a fee waiver. Additionally, several offices associated with the Bureau of Land Management (BLM) have granted the AACL request for expedited processing for the case numbers they had assigned: DOI BLM 2021003200; DOI BLM 2021003202; DOI BLM 2021003207; DOI BLM 2021003208; and DOI BLM 2021003213. The AACL encourages members of the general public to call their representatives and ask them to refuse taking the National Rifle Association (NRA) political donations and contributions. W (AACL) Michael A. Ayele Anti-Racist Human Rights Activist Audio-Visual Media Analyst Anti-Propaganda Journalist The Association for the Advancement of Civil Liberties (AACL) Files An Appeal With the Department of the Interior (DOI) Citing Several Inconsistencies In the Manner They Have Processed a FOIA Request Dealing With the U.S Government, W (AACL), Michael A. Ayele, Archive.org.: https://archive.org/details/w-aacl-foia-appeal-in-connection-with-the-executive- branch-of-the-u.-s-gvt xxA “straw purchaser” is a person who buys a gun on someone else’s behalf. Straw purchases violate a number of federal and, in some cases, state gun laws including, but not limited to, provisions of the GCA. Gun sellers who knowingly supply straw purchasers also violate those laws. Estados Unidos Mexicanos v Smith & Wesson Brands, Inc et al; Courthouse News.: https://www.courthousenews.com/wp-content/uploads/2021/08/mexico-smith-wesson- complaint.pdf xxiThe attorneys general of 13 states and Washington DC this week expressed support for a federal lawsuit by the Mexican government that accuses a group of American gun manufacturers of facilitating the trafficking of weapons to criminals in Mexico, fueling gun violence. (…) The defendants -- among them brands like Smith & Wesson, Colt and Glock -- pointed to the law as one argument in an effort to have the case dismissed. But the attorneys general argue the PLCAA would not, in the words of Bonta's office, "shield the companies from accountability." Massachusetts Attorney General Maura Healey, in a news release issued Tuesday, asked the court to acknowledge gun manufacturers, dealers and distributors can be held accountable for W (AACL) – MICHAEL A. AYELE 21

43. RECORDS REQUEST 04/03/2022 how their products are marketed or sold. "It is unacceptable," Healey said, "for gun manufacturers and distributors to knowingly market their products in a way that facilitates the illegal trafficking of weapons into the hands of dangerous individuals." 13 states have backed the Mexican government’s lawsuit against a group of US gun manufacturers, CNN.: https://edition.cnn.com/2022/02/06/us/mexico-lawsuit-us-gun-manufacturers/index.html Thirteen states, several dozen cities, and a host of academics and gun violence prevention groups are throwing their support behind a lawsuit the Mexican government filed in U.S. federal court accusing major gunmakers of fueling cartel violence through negligent business practices. In a flurry of amicus briefs filed on January 31, the parties emphasized the deadly reverberations of Mexican cartel violence in the United States and abroad and urged the court to ignore pleas from gunmakers to dismiss the case on the grounds that it’s barred by the gun industry’s special legal immunity. Attorneys general from California, New York, Massachusetts, and 10 other states filed briefs, as did district attorneys from more than 20 American municipalities, including Chicago, Philadelphia, and San Antonio. The countries of Antigua and Barbuda and Belize wrote in support as well. (…) The amicus briefs focus primarily on the question of whether the gun industry’s special legal immunity should apply to the Mexican government’s lawsuit. Since 2005, the Protection of Lawful Commerce in Arms Act, or PLCAA, has protected the gun industry from most litigation, prohibiting suits brought because of the “criminal or unlawful misuse” of a firearm. In November, the defendant gun manufacturers filed several motions to dismiss the case on these grounds.The Mexican government argues that PLCAA shouldn’t shield gun companies from suits stemming from violations of foreign law. William Dodge, a law professor at the University of California, Davis, who authored a brief filed by a group of 16 experts in international litigation, said that the Mexican government is unambiguously correct.“It seems quite clear that Congress never thought about claims under foreign law when drafting PLCAA,” Dodge told The Trace. “If Congress didn’t address such claims, then they’re not barred by the act.” Mexico’s lawsuit signals a change in the country’s approach to combating organized crime. Since taking office in 2018, President Andres Manuel Lopez Obrador championed a “Mexico first” policy, rolling out a non-confrontational strategy to fight cartel violence labeled “hugs not bullets.” Mexican officials have attempted to address the root causes of organized criminal violence, focusing on social and economic policies. Part of that game plan includes making it harder for cartels to arm themselves by targeting the companies who manufacture their favored weapons. (…) Several of the amicus briefs argue that the gun companies’ alleged negligence extends beyond Mexico’s borders. U.S States, Cities, and Experts Back Mexico’s Lawsuit Against Gunmakers, The Trace.: https://www.thetrace.org/2022/02/mexico-lawsuit-colt-smith- and-wesson-glock-gun-companies/ xxiiMexico's Supreme Court has decriminalized the private recreational use of cannabis by adults, calling the current prohibition unconstitutional. In an 8-3 decision, the court ruled that adults would be able to apply for permits to cultivate and consume their own cannabis. Smoking in public and in front of children is banned. The ruling does not mention the commercialization of cannabis. The decision came after a legalization bill stalled in Congress. "Today is a historic day for liberties," Supreme Court president Arturo Zaldívar said.But some groups said the W (AACL) – MICHAEL A. AYELE 22

44. RECORDS REQUEST 04/03/2022 ruling was unlikely to result in major immediate changes. Mexico United Against Crime, a non- governmental organization, said the decision "does not decriminalize the activities necessary to carry out consumption" such as possession and transportation. Mexico's lower house approved a bill legalizing the recreational use of cannabis in March, but it still needs final approval by the Senate.The legislation would let users with a permit carry up to 28g and grow as many as eight plants at home for personal use. At present, it is illegal to carry more than five grams. Supporters of legalisation hope it could reduce some of the violence related to illegal drugs trade, which claims the lives of thousands of people in the country every year. Mexico marijuana: Top court decriminalizes recreational use of cannabis, BBC.: https://www.bbc.com/news/world-latin-america- 57645016#:~:text=Mexico's%20lower%20house%20approved%20a,carry%20more%20than%20 five%20grams. xxiiiOn Thursday, Sept. 2 at 10 a.m., the U.S. Equal Employment Opportunity Commission (EEOC) and the Government of Mexico, through its embassy in the United States, will sign a renewal of the memorandum of understanding (MOU) which calls for ongoing cooperation between the EEOC and the Mexican government to combat employment discrimination against Mexican Americans and Mexican nationals residing in the United States. The participants will include EEOC Chair Charlotte A. Burrows; Esteban Moctezuma Barragan, Ambassador of Mexico to the United States; and U.S. Secretary of Labor Martin Walsh. EEOC Chair Burrows, Ambassador Moctezuma, Labor Secretary Walsh and other officials will speak at the event. Other participating government agencies include the DOL’s Wage and Hour Division, the Occupational Safety and Health Administration (OSHA), and the Office of the General Counsel of the National Labor Relations Board (NLRB). This signing will occur during the 13th Annual Labor Rights Week (LRW). LRW is an initiative of the Government of Mexico that occurs around Labor Day in the United States. The objective of the LRW is to increase awareness and inform the Mexican and Latino communities about their fundamental labor rights. LRW encourages all to honor the contributions of all workers, regardless of language barriers or immigration status. EEOC To Sign New Memorandum of Understanding With Mexico on Workers’ Rights on Sept. 02, EEOC.: https://www.eeoc.gov/newsroom/eeoc-sign-new-memorandum-understanding- mexico-workers-rights-sept-2 xxivSandy Hook families settle for $73 M with gun maker Remington, Associated Press.: https://apnews.com/article/sandy-hook-school-shooting-remington-settlement- e53b95d398ee9b838afc06275a4df403 xxvThe District of Columbia Government (DC.Gov) Office of Police Complaint (OPC) Disclose Limited Records About the March for Our Lives Rally Dated March 24th 2018, W (AACL), Michael A. Ayele, Archive.: https://archive.org/details/dc.-gov-opc-disclose-limited-records- about-the-march-for-our-lives-rally-dated-m/page/n7/mode/2up W (AACL) – MICHAEL A. AYELE 23

45. RECORDS REQUEST 04/03/2022 xxviI’ve been told on too many occasions that guns aren’t the problem, that it’s the people who use them. But don’t tell me guns don’t kill people. Just two weeks ago, a baby was killed by a gun in his home. And while the investigation into what happened is still ongoing, one thing is true: that precious baby boy would be alive today if that gun wasn’t in his home. We don’t have to wait for the next senseless act of gun violence. I am imploring every person in our city who knows about an illegal gun to help us get it out of the community. Do it because you don’t want to stand by and see another child killed. Do it because you don’t want to see the person who owns it ruin their life or their family’s life. If for no other reason, do it because you could get up to $7,500 in reward money. We need the community to step up so that you can keep your home, your children and grandchildren, and our city safe. December 10th 2021 Letter from the Mayor.: https://content.govdelivery.com/accounts/DCWASH/bulletins/2ffe71b xxviiMissouri Second Amendment Preservation Act, Missouri Senate. : https://www.senate.mo.gov/21info/bts_web/bill.aspx?SessionType=R&BillID=57629955 xxviiiJackson County wants to sign onto the joint lawsuit filed by St. Louis City and County that challenges a new Missouri rule restricting how local and state police can enforce federal gun laws. The law, called the Second Amendment Preservation Act, imposes a $50,000 fine on any state or local official who enforces a federal gun law that’s not already a law in the Show-Me State. The rule also says federal laws infringing the Second Amendment are invalid in Missouri. “As we speak, there are attorneys in our County Counselor's Office who are finalizing motions to request to be able to enter that lawsuit,” said Caleb Clifford, chief of staff for County Executive Frank White Jr. This comes the same day the County Legislature approved a resolution supporting the plan to join the lawsuit. That resolution was approved by a vote of 5-3, with one legislator not present. “The county executive thought that it was important for us to show that this was supported not just by the executive himself, but it was also supported by the legislature, who was also voted in by the community,” Clifford said. Parson signed the law in question on June 12, at the Frontier Justice gun shop in Lee’s Summit. At the ceremony, the Republican echoed a dubious claim that has made the rounds on conservative social media. “You've had the vice president of the United States get up in an open forum — when she was running for president, if you remember this — and any particular weapon she decided she didn't like, she was going to come to your house, onto your front door, and take it away,” he said. “Well not in Missouri, she's not.” (…) “The law that the Missouri Legislature passed and the governor signed is blatantly unconstitutional,” said Jackson County Legislator Crystal Williams, who sponsored the county’s non-binding resolution. “It defies the Supremacy Clause of the United States Constitution — it's really as simple as that.” The Supremacy Clause, first applied in court in 1796, is the part of the W (AACL) – MICHAEL A. AYELE 24

46. RECORDS REQUEST 04/03/2022 Constitution specifying that federal laws overrule conflicting state laws. By passing the new measure, Missouri became one of at least 10 states this year to have enacted what some call Second Amendment sanctuary laws. They vary state-by-state, but most are meant to limit when state and local authorities can enforce federal gun restrictions. States in every region but the Northeast have passed laws aimed at either nullifying certain federal gun laws or preventing state and local police from enforcing them. Meanwhile, in 2020 Missouri experienced the third highest gun-death rate in the country, with 689 people shot and killed — more than in any previous year. “Kansas City and St. Louis are in the top, or near the top, in the nation for violence —especially gun violence,” said Jackson County Legislator Jalen Anderson. “Stripping away the powers of police or prosecutors when (they’re) trying to go after … the individuals who cause violence, I think, is very dangerous and wrong.”Missouri’s law enforcement community is split on the matter. (…) A spokesman for the Kansas City Police Department has said the new rule wouldn’t affect their officers’ daily jobs much, because the department has a team of detectives who advise and handle gun cases specifically. Most local departments in Missouri, though, don’t have those kinds of resources. Kevin Merritt, president of the Missouri Sheriff's Association, said many of his members aren't thrilled with the new law, but they aren’t against it either. That’s because the rule’s language could lead to more litigation against local authorities, he said, which could result in less cooperation with federal agencies. Whether or not Jackson County can join the lawsuit from St. Louis is ultimately up to the judge overseeing the case. A timetable for the lawsuit has not been set. Jackson County Looks to Join Lawsuit Challenging Missouri’s New 2nd Amendment Law, KCUR.: https://www.kcur.org/news/2021-07-06/jackson-county-looks-to- join-lawsuit-challenging-missouris-new-2nd-amendment-law In a separate case, St. Louis and Jackson counties filed suit against the state in hopes of blocking the law. Cole County Circuit Judge Daniel Green denied the request, a decision Missouri Attorney General Eric Schmitt hailed as an “important victory” over the Department of Justice under the Biden administration. The Missouri Supreme Court will hear an appeal of the lawsuit against the law on Monday. In an affidavit submitted in support of that lawsuit, Frederic Winston, head of the ATF’s Kansas City Field Division, wrote that the law hinders collaborative partnerships in a state where “violent crime is a significant problem.” He said a dozen officers in the state withdrew from working with ATF task forces because of the law, making crimes more difficult to solve through collaborations with local law enforcement. “ATF has seen impacts that I believe hinder the collaborative partnerships and investigative information sharing that protect the people of Missouri,” Winston’s affidavit says. “SAPA has also impacted ATF’s ability to rely on state and local partners for information unrelated to ATF’s own investigations, including those related to the criminal use, possession, and trafficking of firearms.” According to court filings, the Missouri State Highway Patrol cut ties with the ATF due to SAPA, suspending participation in all joint state-federal task forces and halting the sharing of certain W (AACL) – MICHAEL A. AYELE 25

47. RECORDS REQUEST 04/03/2022 data the federal government uses to solve crimes. In August, Poplar Bluff Police Chief Danny Whitely told "CBS 60 Minutes" he no longer works with federal prosecutors on gun cases due to SAPA. He said last year he didn’t seek federal charges against a man who shot at his ex- girlfriend because of the possibility of legal recourse. Anti-domestic violence groups have their own concerns about SAPA’s language. In a brief filed by the Missouri Coalition Against Domestic and Sexual Violence, the organization criticized a portion of SAPA the group said hinders law enforcement’s protection of domestic violence survivors. Before SAPA, federal law barred domestic abusers from owning guns. But Muenz said Missouri’s law doesn’t allow police to use the federal laws that allowed police to disarm domestic abusers in the past. Muenz said departments have stopped confiscating weapons in domestic violence situations due to SAPA. He said it's another example where law enforcements’ fears of lawsuits from SAPA are preventing police from doing their work. “I don’t want criminals to go free because we’re having to reduce what we do or maybe we’re not doing what we do for fear of being sued for violating this statute,” Muenz said. Police say Missouri’s gun law made it harder to stop crime. Now Iowa will consider a similar bill. Saint Louis Public Radio, NPR.: https://news.stlpublicradio.org/law-order/2022-02-05/police-say-missouris-gun- law-made-it-harder-to-stop-crime-now-iowa-will-consider-a-similar-bill xxixCori Bush lay claim to more than one professional title. She is Pastor Cori Bush, having founded a church in her native St. Louis, about a decade ago. She is also Cori Bush, registered nurse. And now she is Congresswoman-elect Cori Bush. Her victory, a romp in Missouri’s First Congressional District that saw her win by sixty percentage points, was foretold by the August Democratic primary, when Bush, running as a progressive in the anti-sclerotic mode of Alexandria Ocasio-Cortez and Ayanna Pressley, defeated Lacy Clay, the incumbent. A member of a local African-American political dynasty, Clay has represented the district since 2001, having succeeded his father, Bill, who was first elected in 1968. Bush, forty-four, isn’t just new blood. She will be both the first Black woman and likely the first nurse to represent Missouri in Congress. Cori Bush, A Nurse and Activist, Becomes The First Black Woman to Represent Missouri in Congress, The Saint Louis Post Dispatch, The New Yorker.: https://www.newyorker.com/magazine/2020/11/16/cori-bush-becomes-first-black-woman-and- first-nurse-to-represent-missouri-in-congress Missouri’s first Black congresswoman’s car was littered with bullets last weekend while it was parked in St. Louis. Despite sources believing she was not the intended target of the gunplay, the politician continues to receive a great outpouring of support from the community. NBC News states while U.S. House Rep. Cori Bush was not in the car when it was shot up, nor was she injured, but she is still shaken. (…) “Like far too many of us in St. Louis, experiencing gun violence is all too familiar,” Bush said in a statementreleased on Twitter. “Thankfully no one was harmed. But any act of gun violence shakes your soul.” The progressive steered the conversation from herself and drew attention to a much larger issue. “No one should have to fear for their safety here in St. Louis, and that is exactly why our movement is working every day to invest in our communities, eradicate the root causes of gun violence, and keep every neighborhood safe,” she continued. A source close to her says that it is believed the shooting, W (AACL) – MICHAEL A. AYELE 26

48. RECORDS REQUEST 04/03/2022 allegedly on the morning of Jan. 22, was not intended for the congresswoman but the incident is disturbing. The representative also says that there was evidence that other vehicles were tampered with over the weekend in the same area of the shooting. Congresswoman Cori Bush’s Car Shot Up In St. Louis, Blue Lives Matter Spokesman Has ‘Vile’ Response: ‘We Need the Lawmakers to be Victims.’ Atlanta Black Star, Yahoo.: https://www.yahoo.com/news/congresswoman-cori-bush-car-shot-030600425.html xxxMass shootings are typically defined as shootings where four or more victims are killed. In the USA, between 2009 and 2016, there were: 156 mass shootings with a total of 848 people killed and 339 injured Public mass shootings account for less than 1% of gun deaths in the USA. However, public mass shootings have a profound emotional and psychological effect on survivors, families and communities. They have created an environment in which people feel unsafe in public places, such as churches, schools, concert venues and cinemas which impacts their human rights to religion, education and leisure. Gun Violence – Key Facts, Amnesty International.: https://www.amnesty.org/en/what-we-do/arms-control/gun-violence/ xxxiCassidy had worked at the VTA since January 2001. His most recent job was a substation maintainer, which the VTA said is someone who works on the equipment that converts the power to run light rail trains. The shooting took place at about 6:30 a.m. PT at a light rail yard in San Jose as employees were starting trains up for the day, authorities said. Video shows that the gunman arrived about 5:30 a.m., FBI Special Agent in Charge Craig Fair said. Law enforcement officers quickly arrived at the scene but did not exchange gunfire with Cassidy. "I know for sure that when the suspect knew the law enforcement was there, he took his own life. Our deputies were right there at that time," said Santa Clara County Sheriff Laurie Smith. The sheriff's office said in a news release Thursday that recently discovered evidence pointed to Cassidy as being angry about work. "We can say that the suspect has been a highly disgruntled VTA employee for many years, which may have contributed to why he targeted VTA employees," the statement says. The gunman fired 39 bullets and investigators think he targeted his victims, the sheriff told CNN. During his rampage, the shooter told a local union official who was present but did not work for the VTA, "I'm not going to shoot you," according to Smith. (…) Cassidy had a hatred for his workplace that he expressed in notes discovered when his bags were searched almost five years ago, a Department of Homeland Security official told CNN on Thursday. Cassidy was taken into secondary inspection after returning from a trip to the Philippines on August 8, 2016, and US Customs and Border Protection officers searched his belongings, the W (AACL) – MICHAEL A. AYELE 27

49. RECORDS REQUEST 04/03/2022 official said. In addition to a black memo book filled with notes about hatred towards the transit agency, officers also found books about terrorism and fear and manifestos, the official said. (…) Cassidy was detained by CBP officials, at least in part because of red flags regarding sex tourism in that part of the world, the DHS official said. There is no indication that anything related to sex tourism was found. It doesn't appear that follow-up action was taken after the 2016 search, the official said. Cassidy traveled at least one more time to the Philippines after the 2016 inspection, the official said, but it's unclear if he was extensively searched after that subsequent trip. San Jose officials said police were never informed of the stop or the writings. (…) Cassidy had a strained relationship with an ex-girlfriend, court documents show, which revealed troubling allegations she made in a filing in 2009 as she responded to a restraining order he filed against her. The woman says she dated Cassidy for approximately one year in what she said became an off-and-on-again relationship after about six months. She described Cassidy as having mood swings that were "exacerbated when (Cassidy) consumed large quantities of alcohol," she said in the court document, and she alleged he had bipolar disorder. She said he enjoyed playing mind games with her, according to the court document. "Several times during the relationship he became intoxicated, enraged and forced himself on me sexually," said the former girlfriend, who CNN is not naming and is reaching out to for comment. Cassidy's ex-wife, Cecilia Nelms, told CNN affiliate the Bay Area News Group he resented his work. Nelms was married to Cassidy for about 10 years until the couple filed for divorce in 2005. She has not been in touch with her ex-husband for about 13 years, according to the outlet. "He had two sides," Nelms said. "When he was in a good mood he was a great guy. When he was mad, he was mad." He often spoke angrily about his coworkers and bosses, and at times directed his anger at her, Nelms told the outlet. When the two were married, he "resented what he saw as unfair work assignments" and "would rant about his job when he got home," she said. "He just thought that some people got more easy-going things at work, and he'd get the harder jobs," she said. San Jose gunman had three weapons on him and a dozen more at home, sheriff’s office says, CNN.: https://edition.cnn.com/2021/05/27/us/san-jose-shooting-suspect/index.html xxxiiU.S. Customs officers had previously detained the man who killed nine people in San Jose, Calif., on Wednesday and found that he professed a hatred of his workplace where the shooting occurred, according to a Department of Homeland Security memo. San Jose Shooter Was Previously Questioned by Law Enforcement Over Hatred of Workplace, The Wall Street Journal.: https://www.wsj.com/articles/san-jose-shooter-was-previously-questioned-by-law- enforcement-over-hatred-of-workplace-11622142384?mod=hp_lead_pos3 xxxiiiIn my city, a mass shooting took the lives of nine people at a transit rail yard in May. In the three weeks since, while friends and family have grieved over their devastating loss, San Jose suffered about 15 more episodes of gun violence, according to San Jose Police Department W (AACL) – MICHAEL A. AYELE 28

50. RECORDS REQUEST 04/03/2022 records received by my office. No longer do these facts startle; our nation has become desensitized to the ubiquity of gun violence. After each horror, prayers and platitudes precede what can only be described as a quiet conspiracy of congressional inaction and a distracting news cycle that anesthetizes our collective outrage. We move on. Grieving communities don't have the luxury of forgetting. We live among devastated family members, we hear the echoes of painful eulogies, and we work with traumatized friends. I joined several colleagues to propose a comprehensive set of initiatives to reduce gun related harm in San Jose. These proposals include two measures that no other city nor state in the United States has ever tried: mandatory gun insurance to support victims, and mandatory gun fees to compensate taxpayers. As with many other Silicon Valley innovations, we intend to implement and test these ideas, learn from our mistakes, improve, iterate and provide a platform for others to scale them to benefit their own communities. First, we will require every gun owner in my city to have liability insurance, regardless of where they purchased their gun. Insurance compensates the victims of unintentional gun harm -- which annually injures 27,000 Americans and claims the lives of 500 more -- paying medical bills, rehabilitative needs, and tragically, funeral expenses. Insurance also incentivizes safe gun ownership, where risk-adjusted premiums might encourage owners to take gun-safety courses, use gun safes or install child-safety locks. In the context of auto safety, insurers rewarding good driving or the use of airbags have reduced per-mile auto fatalities by 80% in five decades, saving 3.5 million lives. We need a similar approach to address unintentional firearm risk, because 4.6 million children live in a household where a gun is kept unlocked and loaded, and three-quarters of gun injuries occur at home. Second, we will require gun owners to pay a modest annual fee to compensate taxpayers for the cost of gun-related violence. Every day, our residents bear the financial burden for police officers who bravely respond to shootings, for ambulances that transport the wounded, and for trauma surgeons to save them. These direct costs of gun violence to California taxpayers -- to say nothing of the costs to victims or their families -- exceeded $1.4 billion in 2018, a sum equivalent to the entire General Fund budget of my city, America's 10th largest. Many like to point to the Second Amendment to skew the discussion on much needed gun reform. And while it protects the rights of citizens to own guns, it doesn't require the public to subsidize gun ownership. Skeptics will say that criminals won't comply. They're right; yet that's an important feature of these proposals, not a defect. These ordinances create a legal mandate that provides police with a lawful means for seizing guns from non-law-abiding, dangerous people. The response to every officer's call for domestic violence in my city, for example, includes the question, "do you have any guns in the home?" If that gun owner lacks proof of payment or insurance, the police can seize the gun -- and dramatically reduce the lethality of the risk to the victim. Of course, the benefits can be more widespread: the majority of mass shootings in the US victimize intimate partners or otherwise involve domestic violence. These proposals won't W (AACL) – MICHAEL A. AYELE 29