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# Defendant's Motion to Dismiss (ECF 14)
- URL: https://gijustice.com/20261009-doj-ecf14/
- Published: 2026-10-09T17:04:00.000Z
- Updated: 2026-10-26T17:19:00.000Z
- Author: Logan M Isaac
- Tags: 6:26-cv-00832-MTK, Chelsea Wein, USDOJ

**DEFENDANT'S MOTION TO DISMISS FOR LACK OF SUBJECT-MATTER JURISDICTION AND FAILURE TO STATE A CLAIM AND MOTION FOR SUMMARY JUDGMENT**

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## CERTIFICATE OF COMPLIANCE WITH LR 7-1

Pursuant to Local Rule 7-1(a)(1)(A), undersigned counsel for Defendant has conferred with Pro Se Plaintiff, and Plaintiff opposes the relief sought in this motion.

## MOTION

Defendant moves under Rule 12(b)(1) of the Federal Rules of Civil Procedure to dismiss all of Plaintiff's claims against Defendant for a lack of subject matter jurisdiction because Plaintiff lacks standing to bring this suit and because Plaintiff's claims challenging the United States Department of Justice National Security Division's lack of timely response under the Freedom of Information Act are moot.

With respect to Plaintiff's claims against the United States Department of Justice Civil Rights Division, Defendant moves to dismiss under Rule 12(b)(6) of the Federal Rules of Civil Procedure for failure to state a claim upon which relief can be granted. Defendant also moves for summary judgment under Federal Rule of Civil Procedure 56 because Plaintiff failed to exhaust administrative remedies before bringing this lawsuit.

## INTRODUCTION

Pro se plaintiff Logan Martin Isaac brings this Freedom of Information Act ("FOIA") action against the U.S. Department of Justice's National Security Division ("NSD") and Civil Rights Division ("CRT," and together with NSD, "Defendant").

Plaintiff asserts that Defendant failed to timely respond to requests for production of records under FOIA. Plaintiff's complaint must be dismissed because Plaintiff lacks standing to bring this claim. The FOIA requests at issue were submitted by Abbie Casteel. This Complaint was filed by Logan Martin Isaac. Only the original FOIA requester may bring a FOIA lawsuit based on an allegedly deficient response to a FOIA request; Isaac's name has appeared on neither of the FOIA requests at issue.

Additionally, Plaintiff claims that NSD failed to respond to Casteel's FOIA request. This claim must be dismissed as moot because NSD has since issued its final response letter, including releasing all non-exempt records responsive to Casteel's request. Declaration of David O'Dowd ("O'Dowd Decl.") ¶ 9, Ex. 2.

With respect to Plaintiff's claim arguing that CRT's response to Casteel's FOIA request was deficient, the Court must dismiss that claim. Casteel's FOIA request was deficient because it failed to reasonably describe the records sought. As a result, CRT's FOIA obligations were not triggered by the request. In the alternative, the Court should grant summary judgment because neither Plaintiff nor Casteel exhausted available administrative remedies before filing this suit. Declaration of John Buchko ("Buchko Decl.") ¶¶ 10-14.

## BACKGROUND

### I. FOIA Request to NSD

On March 19, 2026, Casteel submitted a FOIA request to NSD. *See* O'Dowd Decl. ¶ 5, Ex. 1\. This request sought:

> Any cases opened, prosecuted, or formally declined by the National Security Division in which 18 U.S.C. § 1389 was charged or considered as a charging vehicle (November 1, 2009 to present).Any internal guidance, memoranda, or policy documents addressing the National Security Division's use of or enforcement responsibilities under 18 U.S.C. § 1389 (November 1, 2009 to present).

*Id.* The request was sent from abbiecasteel@proton.me and was signed "Abbie Casteel." The name "Logan Isaac," or "Logan Martin Isaac," or any variation thereof, did not appear on the request. O'Dowd Decl. ¶¶ 5-7, Ex. 1.\[^1\]

On September 23, 2026, the NSD issued its final response letter to Casteel and produced all non-exempt records responsive to Casteel's request. O'Dowd Decl. ¶ 9, Ex. 2.

\[^1\]: With the Complaint, Plaintiff submitted Exhibit B, which purports to be a copy of Casteel's FOIA Request to the NSD. In Exhibit B, the name "Logan M. Isaac" appears in the recipient line of the email. *See* Exhibit B to Complaint, ECF 1-2 at 2\. This exhibit appears to have been altered; the FOIA request received by the NSD did not contain the name "Logan M. Isaac" or any email address other than NSDFOIA@usdoj.gov in the recipient line. O'Dowd Decl. ¶ 11, Ex. 1.

### II. FOIA Request to CRT

On March 19, 2026, Casteel submitted a FOIA request to CRT. *See* Buchko Decl. ¶ 6, Ex. 1\. This request sought:

> Any complaints, reports, or referrals received by the Civil Rights Division alleging violations of 18 U.S.C. § 1389 (November 1, 2009 to present).Any internal guidance, memoranda, or policy documents addressing the Civil Rights Division's jurisdiction over or enforcement responsibilities under 18 U.S.C. § 1389 (November 1, 2009 to present).Any communications between the Civil Rights Division and any other DOJ component regarding enforcement responsibility for 18 U.S.C. § 1389 (November 1, 2009 to present).

*Id.* The request was sent from abbiecasteel@proton.me and was signed "Abbie Casteel." The name "Logan Isaac" or "Logan Martin Isaac," or any variation thereof, did not appear on the request. Buchko Decl. ¶ 7, Ex. 1.\[^2\]

On April 11, Casteel sent a follow-up email to the Civil Rights Division, inaccurately claiming that the statutory response period had lapsed. Buchko Decl. ¶ 8, Ex. 2\. The Civil Rights Division responded to Casteel's FOIA request on April 14, 2026 — before the statutory response period lapsed — with a letter informing Casteel that his/her FOIA request "fail\[ed\] the 'reasonably described' requirement of 5 U.S.C. § 552(a)(3)(A)." Buchko Decl. ¶¶ 9-10, Ex. 3 (citing *Power the Future v. White House Council on Environmental Quality*, 2025 WL 2206947 (D.D.C. Aug. 4, 2025) and *AFGE v. U.S. Dep't of Commerce*, 907 F.2d 203, 209 (D.C. Cir. 1990)). The letter informed Casteel that "\[o\]nce we have received your response with narrowed search terms, we will continue processing this request." Buchko Decl. ¶ 10, Ex. 3\. The letter states that, if "not satisfied with the Civil Rights Division's determination in response to this request," Casteel could administratively appeal within 90 days of the date of the response letter. Buchko Decl. ¶ 11, Ex. 3.

Also on April 14, 2026, Casteel responded to this letter, declining to narrow his/her FOIA requests to the Civil Rights Division. Buchko Decl. ¶ 12, Ex. 4\. Casteel never sent narrowed search terms to the Civil Rights Division and did not file an administrative appeal within 90 days of the date of the Civil Rights Division's response letter. Buchko Decl. ¶¶ 12-14.

\[^2\]: With the Complaint, Plaintiff submitted Exhibit A, which purports to be a copy of Casteel's FOIA Request to the CRT. In Exhibit A, the name "Logan M. Isaac" appears in the recipient line of the email. *See* Exhibit A to Complaint, ECF 1-1 at 2\. This exhibit appears to have been altered; the FOIA request received by the CRT did not contain the name "Logan M. Isaac" or any email address other than CRT.FOIArequests@usdoj.gov in the recipient line. Buchko Decl. ¶ 7, Ex. 1.

## LEGAL STANDARD

### I. Rule 12(b)(1)

"Federal courts are courts of limited jurisdiction" and an action is presumed to lie "outside this limited jurisdiction\[.\]" *Kokkonen v. Guardian Life Ins. Co. of Am.*, 511 U.S. 375, 377 (1994). When jurisdiction is challenged under Federal Rule of Civil Procedure 12(b)(1), the plaintiff has the burden of establishing jurisdiction. *See Safe Air for Everyone v. Meyer*, 373 F.3d 1035, 1039 (9th Cir. 2004). Unlike a Rule 12(b)(6) motion, no "presumptive truthfulness attaches to plaintiff's allegations." *Robinson v. United States*, 586 F.3d 683, 685 (9th Cir. 2009) (internal citation and quotation omitted).

"A Rule 12(b)(1) jurisdictional attack may be facial or factual." *Safe Air for Everyone*, 373 F.3d at 1039\. "In a facial attack, the challenger asserts that the allegations contained in a complaint are insufficient on their face to invoke federal jurisdiction. By contrast, in a factual attack, the challenger disputes the truth of the allegations that, by themselves, would otherwise invoke federal jurisdiction." *Id.* In evaluating a factual attack, the court may consider evidence outside the complaint and resolve factual disputes, if necessary. *See Colwell v. Dep't of Health and Hum. Servs.*, 558 F.3d 1112, 1121 (9th Cir. 2009) (stating that the court may consider declarations and other evidence to resolve disputes over subject-matter jurisdiction); *McCarthy v. United States*, 850 F.2d 558, 560 (9th Cir. 1988) ("\[T\]he district court is not restricted to the face of the pleadings, but may review any evidence, such as affidavits and testimony, to resolve factual disputes concerning the existence of jurisdiction.").

When a court "lacks subject-matter jurisdiction, the court must dismiss the complaint\[.\]" *Pistor v. Garcia*, 791 F.3d 1104, 1111 (9th Cir. 2015) (citation omitted).

### II. Rule 56

Summary judgment is appropriate if the pleadings and evidence show "there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a). The party seeking summary judgment bears the initial burden of demonstrating no genuine dispute of material fact exists. *See Celotex Corp. v. Catrett*, 477 U.S. 317, 323 (1986). To meet this burden, the moving party may point to the absence of evidence proffered by the non-moving party. *Id.* at 325.

To avoid summary judgment, the non-moving party must produce significant probative evidence showing a genuine issue of material fact exists. *T.W. Elec. Serv., Inc. v. Pac. Elec. Contractors Ass'n*, 809 F.2d 626, 630 (9th Cir. 1987). "\[M\]ere allegation and speculation do not create a factual dispute for purposes of summary judgment." *Nelson v. Pima Cmty. Coll.*, 83 F.3d 1075, 1081-82 (9th Cir. 1996). Summary judgment is appropriate if the non-moving party fails to offer "evidence on which the jury could reasonably find for the plaintiff." *Anderson v. Liberty Lobby, Inc.*, 477 U.S. 242, 252 (1986). "FOIA cases typically and appropriately are decided on motions for summary judgment." *Berryhill v. Bonneville Power Admin.*, 509 F. Supp. 3d 1288, 1295 (D. Or. 2020) (quoting *Defenders of Wildlife v. U.S. Border Patrol*, 623 F. Supp. 2d 83, 87 (D.D.C. 2009)).

## ARGUMENT

### I. Plaintiff Lacks Standing to Litigate this Matter Because Plaintiff's Name Does Not Appear on the FOIA Requests at Issue

Plaintiff lacks standing to sue under FOIA, and the Court therefore lacks subject-matter jurisdiction over this case. The standing doctrine stems from Article III of the Constitution, which limits federal judicial power to cases and controversies. *Lujan v. Defenders of Wildlife*, 504 U.S. 555, 559-60 (1992). Under that doctrine, to proceed with a case in federal court, a "plaintiff must have (1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) is likely to be redressed by a favorable judicial decision." *Spokeo, Inc. v. Robins*, 578 U.S. 330, 330 (2016) (citing *Lujan*, 504 U.S. at 560-61). In the context of FOIA, standing is conferred on the person or entity whose FOIA request has been denied in whole or part.

"\[A\] person whose name does not appear on a request for records has not made a formal request for documents within the meaning of the statute." *McDonnell v. United States*, 4 F.3d 1227, 1236-1237 (3rd Cir. 1993); *see also Mahtesian v. United States OPM*, 388 F. Supp. 2d 1047, 1048 (N.D. Cal. 2005) (same); *Thome v. U.S. Food & Drug Admin.*, No. C 11-00676 PSG, 2011 WL 3206910, at \*2 (N.D. Cal. July 27, 2011) (same). As a result, "\[a\] person whose name does not appear on the request for disclosure lacks standing to sue under FOIA." *Unigard Ins. Co. v. Department of the Treasury*, 997 F. Supp. 1339, 1342 (S.D. Cal. 1997); *see also McDonnell*, 4 F.3d at 1236-1237 ("a person like \[Plaintiff\] whose name does not appear on a FOIA request for records may not sue in district court . . . because he has not administratively asserted a right to receive them in the first place.").

Here, the FOIA requests at issue were made by "Abbie Casteel." Plaintiff's name does not appear on either of the requests, although the exhibits that Plaintiff has attached to the complaint that purport to be the FOIA requests to CRT and NSD have been altered to include Isaac's name in the recipient field. *Compare* Compl. Ex. A, *and* Compl. Ex. B, *with* Buchko Decl. Ex. 1, *and* O'Dowd Decl. Ex. 1\. As a result, Isaac does not have standing to sue for the records requested in Abbie Casteel's FOIA requests "because \[Isaac\] has not administratively asserted a right to receive them in the first place." *McDonnell*, 4 F.3d at 1236-1237.

Plaintiff claims that Plaintiff is the person who made the FOIA requests at issue and "submitted the requests at issue under a pseudonym." Compl. ¶ 3\. Even if true, this explanation does not cure the standing issue. Courts have consistently held that the only person who has standing to sue under FOIA is the person who was *named* in the FOIA request *as the person making the request*. *See, e.g.*, *Mahtesian*, 388 F. Supp. 2d at 1050 (holding that a FOIA request made on behalf of an anonymous client did not confer standing on that client); *Unigard*, 997 F. Supp. at 1342 ("a person whose name does not appear on the request for disclosure lacks standing to sue under FOIA, even if his interest was asserted in the request."); *McDonnell*, 4 F.3d at 1236-37 (finding that a plaintiff lacked standing to bring a FOIA claim because "\[a\]lthough his interest was asserted, \[plaintiff's\] signature does not appear on any of the FOIA requests."); *Burka v. United States Dept. of Health and Human Services*, 142 F.3d 1286, 1290-91 (D.C. Cir. 1998) (pointing out the "dangers inherent in recognizing an 'undisclosed' client as the real plaintiff", and finding "\[a\]ny arrangements \[plaintiff's attorney\] had with a third party are legally irrelevant for the purposes of this FOIA request.").

Courts have found that this requirement means that *not only* does a person's name have to appear on a FOIA request to confer standing, but that person must be *specifically identified* as *the person making the request*. For that reason, even if the court accepts the exhibits attached to Plaintiff's complaint, that would not be sufficient to confer standing for Plaintiff to bring this suit. For example, in *McDonnell*, the Third Circuit found that a "passing reference" to the plaintiff's name in a FOIA request was insufficient to confer standing because that reference did "not sufficiently identify him with the person making the request to confer standing" under FOIA. 4 F.3d at 1238 n.6\. Similarly, in *Three Forks Ranch Corp. v. Bureau of Land Mgmt.*, the court found that a plaintiff did not have standing where an attorney stated in a FOIA request that he was "an attorney representing \[a named client\]" because the attorney did not specifically state that the FOIA request was being made "on behalf of" that client. 358 F. Supp. 2d 1, 2 (D.D.C. 2005). Therefore, Plaintiff does not have standing to bring this suit, since Casteel's FOIA requests do not mention Isaac, or any other individual, let alone explicitly stating that the requests are made *on behalf of* Isaac, as is required to confer standing. *See id.* As a result, Plaintiff's suit must be dismissed.

### II. Plaintiff's Claim that NSD Failed to Timely Respond to Casteel's FOIA Request is Moot

"Article III of the Constitution limits the jurisdiction of the federal courts to 'Cases' or 'Controversies.'" *Pitts v. Terrible Herbst, Inc.*, 653 F.3d 1081, 1086 (9th Cir. 2011). "A case is moot when the issues presented are no longer 'live' or the parties lack a legally cognizable interest in the outcome." *City of Erie v. Pap's A.M.*, 529 U.S. 277, 287 (2000).

Plaintiff alleges that the Department of Justice did not timely respond to Casteel's FOIA requests. Compl. ¶ 9\. However, on September 23, 2026, NSD issued its final response letter and released all non-exempt records to Casteel. O'Dowd Decl. ¶ 9, Ex. 2\. Because NSD released the records and its final response letter to Casteel, Plaintiff no longer has any legally cognizable interest in the outcome of the claims against NSD; Casteel has already received all non-exempt records responsive to his/her request and there is no remedy that can be ordered to redress any purported injury. Therefore, Plaintiff's claim that NSD did not timely respond to Casteel's FOIA request is moot and must be dismissed. *See Sieverding v. U.S. Dep't of Just.*, 910 F. Supp. 2d 149, 157 (D.D.C. 2012), *aff'd*, No. 13-5060, 2013 WL 6801184 (D.C. Cir. Dec. 11, 2013).

### III. Casteel's FOIA Requests Are Too Vague and Overbroad to Reasonably Describe the Records Sought

"Under FOIA, an agency is only obligated to release nonexempt records if it receives a request that 'reasonably describes such records.'" *Evans v. Bureau of Prisons*, 951 F.3d 578, 583 (D.C. Cir. 2020) (quoting 5 U.S.C. § 552(a)(3)(A)). When a request fails to reasonably describe the records sought, a plaintiff cannot establish a cause of action under FOIA because an agency's FOIA obligations are triggered only when the agency has received a *proper* request. *See Citizens for Resp. & Ethics in Wash. ("CREW") v. Fed. Election Comm'n*, 711 F.3d 180, 185 n.3 (D.C. Cir. 2013) ("duties that FOIA imposes on agencies . . . apply only once an agency has received a proper FOIA request."). As such, where a FOIA request fails to "reasonably describe" the requested records, it "is not a proper request that obliges Defendant to respond," and a Plaintiff who brings a lawsuit alleging FOIA violations related to such request "has failed to state a claim." *Protect the Pub.'s Tr. v. U.S. Dep't of Lab.*, No. CV 22-2849 (TJK), 2023 WL 6160014, at \*3 (D.D.C. Sept. 21, 2023). Congress enacted the requirement that a FOIA request "reasonably describe" the records sought to ensure that "a professional employee of the agency, familiar with the general subject area, could reasonably be expected to find the desired documents." *Hudgins v. I.R.S.*, 620 F. Supp. 19, 21 (D.D.C. 1985), *aff'd*, 808 F.2d 137 (D.C. Cir. 1987). A request fails to "reasonably describe\[\]" a record if it is "too vague" to allow the "requested record to be reasonably identified." *Krohn v. Department of Justice*, 628 F.2d 195, 198 (D.C. Cir. 1980).

Here, Casteel's FOIA requests failed to satisfy the "reasonably described" standard and therefore did not constitute proper FOIA requests triggering Defendant's FOIA obligations. Casteel's FOIA requests seek "any complaints, reports, or referrals;" "any internal guidance, memoranda, or policy documents;" and "any communications" "regarding" or "addressing" a broad statute, over a period of nearly seventeen years. *See* Buchko Decl. Ex. 1\. Similarly broad requests have been found to fail the "reasonably describe" FOIA requirement. *See, e.g.*, *Freedom Watch v. Department of State*, 925 F. Supp. 2d 55 (D.D.C. 2013) (finding that requests for "all" records that "refer or relate" to various subjects did not reasonably describe the records sought); *American Federation of Government Employees, Local 2782 v. United States Dep't of Commerce*, 632 F. Supp. 1272, 1278 (D.D.C. 1986) (finding that requests for "\[e\]very" record related to a certain subject was overly broad and did not meet the "reasonably describe" requirement, "\[p\]articularly in light of plaintiff's refusal to reformulate its request to make it more specific, as it was invited to do"). Given such broadly encompassing requests, CRT could not "reasonably be expected to find the desired documents." *See Hudgins*, 620 F. Supp. at 21\. This is especially so given that CRT itself is *not* "familiar with the general subject area" of Casteel's FOIA requests, since the statute which Casteel's requests reference is not within CRT's jurisdiction. *See id.*; Buchko Decl. ¶¶ 15-18.

Because Casteel's requests are facially vague and overbroad in a manner similar to others that courts have deemed to fail the "reasonably describe" requirement, Casteel's requests, likewise, do not reasonably describe the records being sought. These requests therefore do not constitute proper FOIA requests, and CRT's FOIA obligations were never triggered. *See CREW*, 711 F.3d at 185 n.3\. As a result, the Court must dismiss Plaintiff's FOIA requests based on Plaintiff's failure to state a claim upon which relief can be granted.

### IV. Plaintiff and Casteel Failed to Administratively Exhaust Any Challenge to CRT's FOIA Response

Before challenging an agency's response in court, a requester "must first exhaust available administrative remedies, including an appeal within the agency." *Aguirre v. United States NRC*, 11 F.4th 719, 725 (9th Cir. 2021) (citing 5 U.S.C. § 552(a)(6)(A)(i)-(ii), (C)(i)). Such exhaustion is required in order to "prevent\[\] premature interference with agency processes" and to allow an agency to "function efficiently" and "to have an opportunity to correct its own errors, to afford the parties and the courts the benefit of its experience and expertise, and to compile a record which is adequate for judicial review." *Corbett v. Transp. Sec. Admin.*, 116 F.4th 1024, 1029 (9th Cir. 2024) (quoting *Weinberger v. Salfi*, 422 U.S. 749, 765 (1975)); *see also Oglesby v. U.S. Dep't of Army*, 920 F.2d 57, 64-65 (D.C. Cir. 1990) ("Allowing a FOIA requester to proceed immediately to court to challenge an agency's initial response would cut off the agency's power to correct or rethink initial misjudgments or errors.").

Here, neither Plaintiff nor Casteel exhausted administrative remedies to challenge CRT's response to Casteel's FOIA request. CRT issued a response letter to Casteel on April 14, 2026, within the statutory response deadline. Buchko Decl. ¶ 9; Ex. 3\. This letter informed Casteel that his/her request failed the "reasonably described" requirement of 5 U.S.C. § 552(a)(3). Buchko Decl. ¶ 10; Ex. 3 (citing *Power the Future*, 2025 WL 2206947 and *AFGE*, 907 F.2d at 209). This letter asked Casteel to "narrow \[his/her\] request to identify a topic, subject matter or issue that would allow CRT to conduct a reasonable search for the records . . . and respond substantively" and informed Casteel that "\[o\]nce \[CRT\] ha\[s\] received \[Casteel's\] response with narrowed search terms, \[CRT\] will continue processing this request." Buchko Decl. ¶ 10; Ex. 3\. The letter also informed Casteel that if he/she was "not satisfied with the Civil Rights Division's determination in response to this request, \[he/she\] may administratively appeal . . . within 90 days of the date of \[CRT's\] response to \[Casteel's\] request." Buchko Decl. ¶ 11; Ex. 3.

Casteel responded to CRT's letter by refusing to narrow the search terms of his/her request. Buchko Decl. ¶¶ 12-14, Ex. 4\. Neither Casteel nor Plaintiff filed an administrative appeal through the process described in CRT's response letter and required by DOJ's regulations. Buchko Decl. ¶¶ 11-14; *see* 28 C.F.R. § 16.8\. Instead, Plaintiff filed a complaint less than two weeks later — effectively stripping CRT of its ability to "correct or rethink" what Casteel perceived to be CRT's "initial misjudgments or errors." *Oglesby*, 920 F.2d at 64\. Because Casteel and Plaintiff failed to exhaust administrative remedies by filing an appeal to challenge any perceived deficiencies in CRT's response to Casteel's FOIA request, *see* Buchko Decl. ¶¶ 10-14, the Court should grant summary judgment against Plaintiff as to Plaintiff's claims challenging CRT's response to Casteel's FOIA request. *See Pinson v. U.S. Dep't of Just.*, 69 F. Supp. 3d 125, 131 (D.D.C. 2014) ("If the \[FOIA\] requester fails to exhaust administrative remedies before filing suit, a court can dismiss the complaint or grant summary judgment for the agency.") (citations omitted).

## CONCLUSION

For the foregoing reasons, the Court should dismiss Plaintiff's FOIA claim with prejudice and enter judgment in favor of the Department of Justice.

Respectfully submitted this 9th day of October, 2026.

SCOTT E. BRADFORD United States Attorney District of Oregon

/s/ Chelsea Wein CHELSEA WEIN Assistant United States Attorney Attorneys for Defendant

## CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was placed within a first-class postage prepaid envelope and deposited in the United States Mail within the offices of the United States Attorney or at a United States Post Office according to established office practice at Portland, Oregon, on October 13, 2026\. At the time of this filing, no more outgoing mail through the U.S. Attorney's Office was accepted for today's date, and the weekend includes a federal holiday on Monday, October 12\. This mailed copy was addressed to:

Logan M. Isaac 250 Broadalbin St. SW, Ste. 104 Albany, Oregon 97321 *Plaintiff Pro Se*

/s/ Samantha Schultz SAMANTHA SCHULTZ Legal Administrative Specialist

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