6:26-cv-00832-MTK

Plaintiff's Declaration in Opposition (ECF 18)

Logan M Isaac

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Plaintiff's Declaration in Opposition (ECF 18)

DECLARATION OF LOGAN MARTIN ISAAC IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS AND MOTION FOR SUMMARY JUDGMENT

I, Logan Martin Isaac, declare as follows under 28 U.S.C. § 1746:

  1. I am the Plaintiff in this action. I am over eighteen and make this declaration on personal knowledge.
  2. On March 19, 2026, I sent two Freedom of Information Act requests by email, one to the Civil Rights Division’s FOIA office and one to the National Security Division’s FOIA office, from the address abbiecasteel@proton.me. Both were signed “Abbie Casteel.” “Abbie Casteel” is a pseudonym I used for investigative purposes. I wrote and sent both requests, and no other person wrote or sent them. True copies of the messages as sent, with full headers, are Exhibit 1. Headers include my private Proton address which I ask to be kept under seal for my protection. 
  3. I created and control abbiecasteel@proton.me, an email alias I created in a private, personal Proton address, [redacted], that I ask be kept confidential.   
  4. Exhibits A and B to my complaint were printed from my sent-mail folder using my web browser’s Print function. The recipient line shows “Logan M. Isaac” because I CCed my public-facing Gmail account, iamloganmi@gmail.com. The messages DOJ received did not contain that name in the recipient line. The requester’s name was redacted from the exhibits for the reason stated at Compl. ¶ 3. Exhibit 1 consists of the original messages with full headers, obtained by saving the file as a PDF using the same Print function without sending it to a printer. 
  5. On April 14, 2026, I received the Civil Rights Division’s letter (ECF 15-3) and replied the same day (ECF 15-4). As of the date of this declaration, I have received no response to my reply and no notice that the request was closed.  
  6. I did not file an administrative appeal with the Office of Information Policy. I understood the April 14 letter to be a request to narrow and not a determination since the correspondence explicitly states, “We are not denying any records at this time.” 
  7. On September 23, 2026, I received the National Security Division’s final response with one page enclosed. A true copy, including the enclosure as received, is Exhibit 3. The same day, I emailed DOJ’s counsel, Chelsea Wein, identifying United States v. McNeil, No. 5:15-cr-00446-DAP (N.D. Ohio), and asking four questions about how NSD searched. A true copy is Exhibit 2. As of the date of this declaration I have received no answer to those specific questions.  
  8. Exhibits 6 and 7 are true copies of filings in United States v. McNeil, No. 5:15-cr-00446-DAP (N.D. Ohio), which I obtained from PACER after searching the internet for information on attacks on soldiers and veterans. Exhibits 8 and 9 are true copies of Department of Justice press releases that I downloaded from justice.gov on October 27, 2026, at the web addresses shown on each.  
  9. Exhibit 4 is a true copy of the November 22, 2019 letter from Representative David Trone and five other Members of the House of Representatives to the Attorney General and the FBI Director. Exhibit 5 is a true copy of the October 4, 2024 letter from Senator Ron Wyden to the Attorney General. I obtained them from the source emails sent by office staff using Congressional email accounts. I am not aware of any response from the Department of Justice to either letter. 
  10. I cannot present by declaration certain facts essential to oppose Defendant’s motion, because they are in Defendant’s possession. They are 
    1. which National Security Division systems, files, and search terms were used to search for records responsive to my request; 
    2. whether the Civil Rights Division conducted any search before its declarant stated that he had no reasonable basis to believe it holds responsive records, and the basis for that statement; and 
    3. whether the 2019 and 2024 congressional inquiries were routed to, or discussed with, the Civil Rights Division or the National Security Division. I would seek these through supplemental declarations or limited discovery.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.

Index of Exhibits

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