Table of Contents
Virtually each printed account compresses twelve separate requests right into a single imagined demand for a file. Half One reconstructs all 5 requests at challenge by date, quantity, company, topic and textual content, separates the demand for a complete FBI file from the demand for named interview data, and data the filing-date discrepancy the courtroom itself notes.
Nothing on this case may be understood by means of the fiction that Aaron Greenspan submitted one request for Tinubu’s file. He submitted twelve requests to 6 businesses, and 5 materially completely different requests survived to abstract judgment. They named completely different custodians, topics, intervals, case data and doc varieties. Any account that collapses them into one demand destroys the precision required to evaluate what was requested, what was refused and what every company was legally required to look. Inference
Twelve requests went to 6 businesses and elements throughout 2022 and 2023. Every sought felony investigative data about 4 named people allegedly related to a Chicago heroin ring working within the early Nineteen Nineties, and the opinion names them as Bola Ahmed Tinubu, Lee Andrew Edwards, Mueez Adegboyega Akande and Abiodun Agbele. Documented
Subject material throughout all twelve was a single joint investigation. Decide Howell describes it as an inquiry carried out by the FBI, the IRS, the DEA and the USA Attorneys’ Workplaces for the Northern District of Indiana and the Northern District of Illinois into the actions of a Chicago heroin ring, together with cash laundering. Documented
Naming conventions within the file are inconsistent and the courtroom famous it. Akande seems along with his first and center names reversed in some paperwork, and the opinion follows the plaintiff in rendering him Mueez Adegboyega Akande. Quantity II adopts the identical conference and flags the variation as an alternative of silently selecting. Documented
5 of the twelve reached abstract judgment. Three of the eight requests the plaintiff outlined don’t contain Tinubu or Agbele and fell exterior the narrowed dispute, and the events agreed in August 2024 to restrict briefing to the refusals to verify as to Tinubu, the refusal as to Agbele, and redactions and withholdings regarding these two. Documented
Learn additionally: Tinubu At UN In New York: U.S. Drug File Calls for Motion — Quantity II, Overview
The First Request: DEA, July 2022
First of the 5 in time went to the DEA. Request No. 22-00892-F, filed July 21, 2022, sought any data from the DEA’s Hammond, Indiana or Washington workplaces regarding the Nigerian heroin distribution group energetic from roughly 1988 to 1994 or later, involving Tinubu and Edwards. Documented
Wording of that request issues greater than its date does. It defined that the group is described in a civil forfeiture criticism and an Inside Income Service felony investigation affidavit in ILND Case No. 1:93-cv-04483, which is the case Quantity I examined in full. Documented
Citing the 1993 papers contained in the request itself is what ultimately carried the argument. A requester who factors an company to a public courtroom submitting is just not speculating about what the federal government as soon as did, and the identical paperwork later provided the official acknowledgment on which the April 2025 ruling turned. Inference
Framing of that request additionally mounted its limits. It named two of the 4 males and requested two named workplaces for data about a company, which is a narrower factor than a requirement for a private file and simpler for an company to look. Inference
The Second Request: CIA, March 2023
Second got here the CIA. Request No. F-2023-01008, filed March 23, 2023, sought data regarding Bola Ahmed Tinubu and Mueez Adegboyega Akande, described as each Nigerian residents, for the interval January 1, 1985 to December 31, 2021. Documented
Scope of that interval is value noting as a result of it far exceeds the others. Thirty-seven years of data on two overseas nationals is a request of a unique character from one in search of an outlined case file, and the CIA’s reply was correspondingly completely different in form. Inference
The Third and Fourth Requests: Two Completely different FBI Calls for
Third and fourth went to the FBI inside eight weeks of one another, and they aren’t the identical request. Quantity II separates them as a result of printed accounts routinely merge them right into a single demand for a file, which misstates what was sought and what any reply may imply. Inference
Request No. 1588244-000, filed electronically on March 29, 2023, sought all the FBI file for Bola Ahmed Tinubu, giving a date of beginning of March 29, 1952 and describing him as President-Elect of Nigeria as of February 2023. Breadth defines it, because it asks for an entire file with out limiting by interval, subject material or file kind. Documented
Its companion is the other in form. Filed in Might 2023, it sought Kind 302 interview data with Bola Tinubu from FBI Case No. 245-IP-71386-UUUUUU throughout the timeframe 1992 to 1993, which specifies a file kind, a case quantity and a two-year window. Documented
Submitting date of that second FBI request is itself disputed on the face of the file. Plaintiff’s papers give Might 23, 2023, defendants give Might 25, and the FBI’s personal declarant notes a Might 25 timestamp. Nothing examined resolves the discrepancy, and Quantity II data it as an alternative of adopting both model. Documented
Two days matter lower than the behavior of recording them. A discrepancy of this dimension adjustments nothing within the litigation, and marking it prices a sentence whereas establishing that the register on this quantity experiences the file because it stands and never because it reads most easily. Inference
Precision in regards to the two FBI requests governs all the pieces that follows. An company answering a requirement for a complete file faces a unique search obligation from one answering a requirement for a named file kind inside an recognized case quantity, and conflating them makes any evaluation of search adequacy meaningless. Inference
Learn additionally: Tinubu At UN In New York: U.S. Drug File Calls for Motion — Half 4
The Fifth Request: DEA, December 2023
Fifth and final in time went again to the DEA. Request No. 24-00201-F, filed December 5, 2023, sought the DEA case file for Abiodun Agbele situated in both the Northern District of Indiana or the Northern District of Illinois, masking January 1, 1990 to December 31, 1995. Its exhibit on the docket is dated December 5 and the company letter answering it’s dated December 27, 2023. Documented
Agbele’s inclusion modified the form of the case. He’s not the president of something, the 1993 affidavit describes him as arrested and cooperating, and the request for a file on him ran on a separate monitor that produced a separate holding. Inference
Timing of that request can be distinct. Filed in December 2023, it arrived after the litigation had begun and after the intervention had been granted, which is why it entered the case by means of the second amended criticism and never the unique one. Documented
How the Requests Map to the Criticism
Counts within the second amended criticism map to the requests and the mapping is value recording. Depend 5 challenges the response to FBI Request No. 1588244-000, Depend 6 the response to 1593615-000, Depend 9 the response to DEA Request No. 22-00892-F, Depend 11 the response to 24-00201-F, and Depend 12 the response to CIA Request No. F-2023-01008. Documented
Depend 13 stood other than the remainder and sought declaratory judgment as an alternative of data. Its surviving allegations have been narrowed by the identical August 2024 settlement, and nothing examined data what stays of it right this moment. Documented
Narrowing in August 2024 additionally eliminated materials from the case, and Quantity II data what left in addition to what stayed. Plaintiff waived all challenges regarding Counts 2, 7 and 10, any data regarding Lee Andrew Edwards arising underneath Depend 9, and corresponding allegations in Depend 13, which sought declaratory judgment. Documented
Waiver of the Edwards materials deserves specific word. One of many 4 males named throughout the requests dropped out of the contested litigation totally by settlement, which implies nothing within the April 2025 ruling or something after it issues data about him. Inference
Quantity II subsequently issues two males and never 4. Tinubu and Agbele are the topics of each surviving request, and any account of this litigation describing it as an inquiry right into a four-man community misstates what stays earlier than the courtroom. Documented
Reconstructing the requests at this stage of element serves one goal. A reader who is aware of precisely what was requested can choose for himself whether or not any reply given was aware of it, and no such judgment is feasible from summaries describing the case as a requirement for a drug file. Inference
Recorded Gaps
Recorded Gaps for this half are three. Nothing examined establishes the textual content of the seven requests not at challenge within the cross-motions. Nothing examined resolves whether or not FBI Request No. 1593615-000 was filed on Might 23 or Might 25, 2023. Nothing examined establishes the entire quantity, contents or current withholding standing of the data responsive to every surviving request.
Information Not Retrieved
Information Not Retrieved for this half are the second amended criticism and its fifty-seven displays, the unique and first amended complaints, and the joint standing report recording the August 2024 narrowing. Every is a public submitting on the docket in No. 23-1816 and none has been obtained for this quantity.
Forensic Plate — Half 1, first exhibit. 5 rows giving every request by quantity, submitting date, topic and data sought, masking FBI requests 1588244-000 and 1593615-000, DEA requests 22-00892-F and 24-00201-F, and CIA request F-2023-01008, with the corresponding rely within the second amended criticism.
Forensic Plate — Half 1, second exhibit. Two columns itemizing what was retained for judgment and what was waived by settlement, together with Counts 2, 7 and 10 and all data regarding Lee Andrew Edwards.
EOUSA and the Division of State ought to every state publicly what response was given to the requests directed to them earlier than their dismissal, and whether or not any search was carried out. Neither stays a defendant, and neither has defined on any public file what it did with a request naming a sitting head of state. Inference
Observe: this quantity’s Proof Docket is consolidated throughout all elements and seems on the shut of the quantity somewhat than after every installment. It may be transformed to WordPress-ready HTML on request, in the identical method because the elements.
