THE EQUAL EMPLOYM
COMMISSION (EEOC)
CONFIRM OR DENY H
THE EMPLOYMENT HI
ALEXANDRA HUNT, M
HEIDI KAESLIN, NINA
HALAS.
BE WELL. TAKE CARE. KEEP YOURSEL
MICHAEL A. AYELE (a/k/a) W
ASSOCIATION FOR THE ADVANCEMEN
MENT OPPORTUNITY
REFUSE TO
HAVING DISCUSSED
ISTORY OF
MELISSA PETRO,
A SKYE & STACIE
LVES AT ARMS DISTANCE.
NT OF CIVIL LIBERTIES (AACL)
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION 131 M St, N. E., Fifth Floor
Office of Legal Counsel Washington, D. C. 20507
Free: (833) 827-2920
ASL: (844) 234-5122
FAX: (202) 827-7545
Website: www.eeoc.gov
May 13, 2022
VIA: [email protected]
Michael Ayele (aka) W
ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES
P.O. Box 20438
Addis Ababa, ETHIOPIA 10013
Re: FOIA No.: 820-2022-006131
D.C. Bill 318 and Prostitution
Dear Mr. Ayele (aka) W:
Your Freedom of Information Act (FOIA) request, received on 03/15/2022, is processed. The paragraph(s)
checked below apply.
[X] Portions of your request are as follows:
[X] Granted;
[X] Denied pursuant to the subsection(s) of the FOIA indicated at the end of this letter. An
attachment to this letter explains the use of these exemptions in more detail; and
[X] Procedurally denied as no records fitting the description of the records you seek disclosed
exist or could be located after a thorough search. See the Comments page for further
explanation.
[X] You may contact the Acting EEOC FOIA Public Liaison Michael L. Heise for further assistance or
to discuss any aspect of your request. In addition, you may contact the Office of Government
Information Services (OGIS) to inquire about the FOIA mediation services they offer.
The contact information for OGIS is as follows: Office of Government Information Services, National
Archives and Records Administration, 8601 Adelphi Road-OGIS, College Park, Maryland 20740-
6001, email at [email protected]; telephone at (202) 741-5770; toll free 1-877-684-6448; or facsimile
at (202) 741-5769.
The contact information for the FOIA Public Liaison is as follows: Michael L. Heise, EEOC FOIA
Public Liaison, Office of Legal Counsel, FOIA Division, Equal Employment Opportunity
Commission, 131 M. Street, N.E., Fifth Floor, Washington, D.C. 20507, email to [email protected],
telephone at (202) 921-2542; or fax at (202) 827-7545.
[X] If you are not satisfied with the response to this request, you may administratively appeal in writing.
Your appeal must be postmarked or electronically transmitted in 90 days from receipt of this letter
to the Office of Legal Counsel, FOIA Division, Equal Employment Opportunity Commission, 131 M
Street, NE, 5NW02E, Washington, D.C. 20507, email to [email protected]; online at
https://eeoc.arkcase.com/foia/portal/login, or fax at (202) 827-7545. Your appeal will be governed
by 29 C.F.R. § 1610.11.
820-2022-006131
Sincerely,
Michael L. Heise
Assistant Legal Counsel (Acting)
[email protected]
Applicable Sections of the Freedom of Information Act, 5 U.S.C. § 552(b):
Exemption(s) Used:
[X] (b)(3)(A)(i) [X] (b)(7)(C)
[X] § 706(b)
[X] § 709(e)
[X] § 107 of the ADA
[X] § 207 of the GINA
(b)(3)(A)(i)
Exemption 3 to the Freedom of Information Act (FOIA), 5 U.S.C. § 552(b)(3)(A)(i) (2016), as amended by
the FOIA Improvement Act of 2016, Pub. L. No. 114-185, 130 Stat. 538, states that disclosure is not required
for a matter specifically exempted from disclosure by statute if that statute:
(A)(i) requires that the matters be withheld from the public in such a manner as to leave no
discretion on the issue[.]
Sections 706(b) and 709(e) of Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e-5(b), 2000e-
8(e)(2006), are part of such a statute. Section 706(b) provides that:
Charges shall not be made public by the Commission . . . . Nothing said or done during
and as a part of [the Commission's informal endeavors at resolving charges of
discrimination] may be made public . . . .
Section 709(e) of Title VII provides:
It shall be unlawful for any officer of the Commission to make public in any manner
whatever any information obtained by the Commission pursuant to its authority under this
section [to investigate charges of discrimination and to require employers to maintain and
submit records] prior to the institution of any proceeding under this title involving such
information.
Section 107 of the Americans with Disabilities Act (ADA) and § 207 of the Genetic Information
Nondiscrimination Act (GINA) adopt the procedures of Sections 706 and 709 of Title VII. See EEOC v.
Associated Dry Goods Co., 449 U.S. 590 (1981); Frito-Lay v. EEOC, 964 F. Supp. 236, 239-43 (W.D. Ky.
1997); American Centennial Insurance Co. v. EEOC, 722 F. Supp. 180 (D.N.J. 1989); and EEOC v. City of
Milwaukee, 54 F. Supp. 2d 885, 893 (E.D. Wis. 1999).
INFORMATION WITHHELD PURSUANT TO THE THIRD EXEMPTION TO THE FOIA:
Access to privileged charge information, if any exist: EEOC can neither confirm nor deny
the existence, or non-existence, of any Title VII, ADA, and/or GINA, charges filed by an
individual against an entity to which you are not, or do not represent, a party to the charge.
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(b)(7)(C)
Exemption (b)(7)(C) to the Freedom of Information Act (FOIA), 5 U.S.C. § 552(b)(7)(C), as amended by the
FOIA Improvement Act of 2016, Pub. L. No. 114-185, 130 Stat. 538, authorizes the Commission to withhold:
records or information compiled for law enforcement purposes, but only to the extent that
the production of such law enforcement records or information . . . (C) could reasonably be
expected to constitute an unwarranted invasion of personal privacy . . . .
The seventh exemption applies to civil and criminal investigations conducted by regulatory agencies.
Abraham & Rose, P.L.C. v. United States, 138 F.3d 1075, 1083 (6th Cir. 1998). Release of statements and
identities of witnesses and subjects of an investigation creates the potential for witness intimidation that
could deter their cooperation. National Labor Relations Board v. Robbins Tire and Rubber Co., 437 U.S.
214, 239 (1978); Manna v. United States Dep’t. of Justice, 51 F.3d 1158,1164 (3d Cir. 1995). Disclosure of
identities of employee-witnesses could cause "problems at their jobs and with their livelihoods." L&C
Marine Transport, Ltd. v. United States, 740 F.2d 919, 923 (11th Cir. 1984). The Supreme Court has
explained that only "[o]fficial information that sheds light on an agency's performance of its statutory duties"
merits disclosure under FOIA, and noted that "disclosure of information about private citizens that is
accumulated in various governmental files" would "reveal little or nothing about an agency's own conduct."
United States Dep't of Justice v. Reporters Comm. for Freedom of the Press, 489 U.S. 749, 773 (1989).
For the purposes of determining what constitutes an unwarranted invasion of personal privacy under
exemption (b)(7)(C), the term “personal privacy” only encompasses individuals, and does not extend to the
privacy interests of corporations. FCC v. AT&T Inc., 131 S.Ct. 1177, 1178 (2011).
INFORMATION WITHHELD PURSUANT TO EXEMPTION (7)(C) TO THE FOIA:
EEOC cannot grant access to ADEA or EPA charges, filed by an individual against an entity,
in order to prevent an unwarranted invasion of personal privacy by a third party.
COMMENTS
This office’s response to your request is as follows:
(1) Your request for “formal and informal ties that exist between the Central Intelligence Agency (CIA),
the Department of Justice (DOJ), the Department of State (DoS), the District of Columbia (D.C.)
Council, the District of Columbia Government (DC.Gov), and the Equal Employment Opportunity
Commission (EEOC),” is granted.
The EEOC provides leadership and guidance to federal agencies on all aspects of the federal
government's equal employment opportunity program. The requested information is already
available online, via EEOC’s public website. See the following link: https://www.eeoc.gov/federal-
sector.
The EEOC enforces federal laws prohibiting employment discrimination, by an employer, against a
job applicant or an employee. The requested information is already available online, via EEOC’s
public website. See the following link: https://www.eeoc.gov/employers.
(2) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
DC Bill 318 intent to decriminalize prostitution if those involved are 18 years of age or older” is
procedurally denied. No records exist within the EEOC.
(3) Your request for “the researches and studies in use by [EEOC] on the subject of prostitution” is
procedurally denied. No records exist within the EEOC.
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(4) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the contested studies dealing with the median age of entry into prostitution” is procedurally denied.
No records exist within the EEOC.
(5) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
websites such as X-Video, X-Hamster, and Pornhub, being among the most visited throughout the
world” is procedurally denied. No records exist within the EEOC.
(6) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
websites such as X-Video, X- Hamster, and Pornhub, having an estimated worth of between $3
(three) billion to tens of billions of U.S. dollars” is procedurally denied. No records exist within the
EEOC.
(7) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Google as a search engine, which can confirm that there are more searches for Pornhub than U.S.
President Joe Biden,” is procedurally denied. No records exist within the EEOC.
(8) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Google as a search engine, which can confirm that there are more searches for Pornhub than Covid-
19 (the Coronavirus disease),” is procedurally denied. No records exist within the EEOC.
(9) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Google as a search engine, which can confirm that there are more searches for Pornhub than the
online streaming platform Netflix,” is procedurally denied. No records exist within the EEOC.
(10) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the decision of Pornhub to settle a lawsuit brought by 50 women against its website” is procedurally
denied. No records exist within the EEOC.
(11) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the decision of Pornhub to suspend content uploaded to their websites by non-verified users” is
procedurally denied. No records exist within the EEOC.
(12) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Google as a limited liability company (LLC) headquartered in Mountain View, California,” is
procedurally denied. No records exist within the EEOC.
(13) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the publicized 2018 investigation into police officers working for Prince George County, Maryland,
and the Metropolitan Police Department (D.C.) following complaints that were filed against them
alleging extortion of sexual intercourse in exchange for lack of criminal prosecution” is denied
pursuant to the third and seventh exemptions to the FOIA. 5 U.S.C. §§ 552(b)(3)(A)(i) and
(b)(7)(C).
The confidentiality provisions of Title VII of the Civil Rights Act, the ADA, and GINA, prohibit the
EEOC from confirming or denying the existence, or nonexistence, of a charge brought by an individual
to a third party of the charge. The third exemption to the FOIA exempts this information from
disclosure.
The seventh exemption, 7(C), to the FOIA permits the agency to withhold information compiled in
investigative files where disclosure of such information could result in an unwarranted invasion of
personal privacy. In this instance, we cannot grant access to, or copies of, any ADEA and EPA
charges. 29 C.F.R. § 1610.17(g).
(14) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the MPD as law enforcement agency (within the D.C.Gov) that has previously disclosed to Michael
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A. Ayele, a.k.a W, the memorandum of understanding (MOU) they have concluded with the University
of the District of Columbia (UDC)” is procedurally denied. No records exist within the EEOC.
(15) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the University of Maryland (UMD) College Park as a post-secondary academic institution that has
previously disclosed to Michael A. Ayele, a.k.a W, the memorandum of agreement (MOA) they have
concluded with the Prince George County Police Department (PGPD)” is procedurally denied. No
records exist within the EEOC.
(16) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
D.C. Code Section 22-3001 defining consent as words or overt actions indicating a freely given
agreement to the sexual act or contact in question” is procedurally denied. No records exist within
the EEOC.
(17) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
D.C. Code Section 22-3001 noting that the “lack of verbal or physical resistance or submission by the
victim, resulting from the use of force, threats, or coercion (…) shall not constitute consent,” is
procedurally denied. No records exist within the EEOC.
(18) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the UMD as a post-secondary academic institution that defines sexual coercion as the use of
unreasonable pressure in an effort to compel another individual to initiate or continue sexual activity
against the individual’s will” is procedurally denied. No records exist within the EEOC.
(19) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the UMD as a post-secondary academic institution which acknowledges that coercion includes but is
not limited to intimidation, manipulation, threats of emotional or physical harm, and blackmail,” is
procedurally denied. No records exist within the EEOC.
(20) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the decision of Alexandra Hunt to speak on the subject of her work-experience as a stripper, when
she was a college student,” is procedurally denied. No records exist within the EEOC.
(21) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the retaliation faced by Alexandra Hunt at her previous place of employment for speaking on the
subject of her work-experience as a stripper, when she was a college student,” is denied pursuant
to the third and seventh exemptions to the FOIA. 5 U.S.C. §§ 552(b)(3)(A)(i) and (b)(7)(C).
The confidentiality provisions of Title VII of the Civil Rights Act, the ADA, and GINA, prohibit the
EEOC from confirming or denying the existence, or nonexistence, of a charge brought by an individual
to a third party of the charge. The third exemption to the FOIA exempts this information from
disclosure.
The seventh exemption, 7(C), to the FOIA permits the agency to withhold information compiled in
investigative files where disclosure of such information could result in an unwarranted invasion of
personal privacy. In this instance, we cannot grant access to, or copies of, any ADEA and EPA
charges. 29 C.F.R. § 1610.17(g).
(22) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
whether Alexandra Hunt’s previous place of employment was being consistent with Title VII of the
1964 and 1991 Civil Rights Act at the time it retaliated upon her for speaking on the subject of her
work-experience as a stripper, when she was a college student,” is denied pursuant to the third
and seventh exemptions to the FOIA. 5 U.S.C. §§ 552(b)(3)(A)(i) and (b)(7)(C). See Item # 21
above.
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(23) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a woman who opposes the decision of former New York City (NYC) Mayor Michael
Bloomberg calling for the removal of Melissa Petro as a teacher after she admitted to her past in sex
work” is procedurally denied. No records exist within the EEOC.
(24) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
whether the former NYC Mayor Michael Bloomberg was being consistent with Title VII of the 1964
and 1991 Civil Rights Act at the time he recommended the city take legal action” against Melissa
Petro” is denied pursuant to the third and seventh exemptions to the FOIA. 5 U.S.C. §§
552(b)(3)(A)(i) and (b)(7)(C).
The confidentiality provisions of Title VII of the Civil Rights Act, the ADA, and GINA, prohibit the
EEOC from confirming or denying the existence, or nonexistence, of a charge brought by an individual
to a third party of the charge. The third exemption to the FOIA exempts this information from
disclosure.
The seventh exemption, 7(C), to the FOIA permits the agency to withhold information compiled in
investigative files where disclosure of such information could result in an unwarranted invasion of
personal privacy. In this instance, we cannot grant access to, or copies of, any ADEA and EPA
charges. 29 C.F.R. § 1610.17(g).
(25) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a woman who opposes the firing of Heidi Kaeslin from her previous job at the
Lincoln Unified School District located in Northern California” is procedurally denied. No records
exist within the EEOC.
(26) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
whether the Lincoln Unified School District was being consistent with Title VII of the 1964 and 1991
Civil Rights Act when it fired Heidi Kaeslin from her job as a school teacher there” is denied pursuant
to the third and seventh exemptions to the FOIA. 5 U.S.C. §§ 552(b)(3)(A)(i) and (b)(7)(C).
The confidentiality provisions of Title VII of the Civil Rights Act, the ADA, and GINA, prohibit the
EEOC from confirming or denying the existence, or nonexistence, of a charge brought by an individual
to a third party of the charge. The third exemption to the FOIA exempts this information from
disclosure.
The seventh exemption, 7(C), to the FOIA permits the agency to withhold information compiled in
investigative files where disclosure of such information could result in an unwarranted invasion of
personal privacy. In this instance, we cannot grant access to, or copies of, any ADEA and EPA
charges. 29 C.F.R. § 1610.17(g).
(27) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a woman who opposes the firing of Nina Skye from her previous job in a Los
Angeles Christian preschool for moonlighting in the porn industry” is procedurally denied. No
records exist within the EEOC.
(28) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
whether the firing of Nina Skye is consistent with Title VII of the 1964 and 1991Civil Rights Act” is
denied pursuant to the third and seventh exemptions to the FOIA. 5 U.S.C. §§ 552(b)(3)(A)(i)
and (b)(7)(C).
The confidentiality provisions of Title VII of the Civil Rights Act, the ADA, and GINA, prohibit the
EEOC from confirming or denying the existence, or nonexistence, of a charge brought by an individual
to a third party of the charge. The third exemption to the FOIA exempts this information from
disclosure.
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The seventh exemption, 7(C), to the FOIA permits the agency to withhold information compiled in
investigative files where disclosure of such information could result in an unwarranted invasion of
personal privacy. In this instance, we cannot grant access to, or copies of, any ADEA and EPA
charges. 29 C.F.R. § 1610.17(g).
(29) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a woman who opposes the firing of Stacie Halas from her job at the Oxnard School
District for starring in pornographic films” is procedurally denied. No records exist within the EEOC.
(30) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
whether the Oxnard School District was being consistent with Title VII of the 1964 and 1991 Civil
Rights Act when it fired Stacie Halas from her job as a teacher, for starring in pornographic films,” is
denied pursuant to the third and seventh exemptions to the FOIA. 5 U.S.C. §§ 552(b)(3)(A)(i)
and (b)(7)(C).
The confidentiality provisions of Title VII of the Civil Rights Act, the ADA, and GINA, prohibit the
EEOC from confirming or denying the existence, or nonexistence, of a charge brought by an individual
to a third party of the charge. The third exemption to the FOIA exempts this information from
disclosure.
The seventh exemption, 7(C), to the FOIA permits the agency to withhold information compiled in
investigative files where disclosure of such information could result in an unwarranted invasion of
personal privacy. In this instance, we cannot grant access to, or copies of, any ADEA and EPA
charges. 29 C.F.R. § 1610.17(g).
(31) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a woman who is passionate about soccer” is procedurally denied. No records
exist within the EEOC.
(32) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a woman who has graduated with an undergraduate degree in Psychology from
the University of Richmond” is procedurally denied. No records exist within the EEOC.
(33) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a woman who graduated from Temple University with a Master of Public Health
(MPH) degree” is procedurally denied. No records exist within the EEOC.
(34) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a woman who identifies as a public health researcher, a girls’ soccer coach, an
advocate for social, racial, economic, and environmental justice, and an organizer fighting for the 3rd
district of Pennsylvania,” is procedurally denied. No records exist within the EEOC.
(35) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a woman running for Congress on a progressive platform because she believes
(…) politicians should fight for systemic change, ensuring equal opportunity and justice for all,” is
procedurally denied. No records exist within the EEOC.
(36) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a candidate running for Congress in order to decriminalize sex work” is
procedurally denied. No records exist within the EEOC.
(37) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Alexandra Hunt as a candidate running for Congress in order to reform the criminal justice system” is
procedurally denied. No records exist within the EEOC.
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(38) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the criminal complaint filed by the Department of Justice (DOJ) against Brian Jeffrey Raymond in the
United States District Court for the District of Columbia, located at 333 Constitution Avenue,
Washington D.C.)” is procedurally denied. No records exist within the EEOC.
(39) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Brian Jeffrey Raymond as a Caucasian man who was 45 years old at the time the DOJ filed Document
68 with E. Barrett Prettyman Courthouse on July 23, 2021,” is procedurally denied. No records exist
within the EEOC.
(40) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Brian Jeffrey Raymond as a Caucasian man who was a longtime employee of the CIA” is procedurally
denied. No records exist within the EEOC.
(41) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Brian Jeffrey Raymond as a former CIA employee who has admitted to the DOJ having recorded
and/or photographed at least 24 unconscious nude or partially nude women without their consent
from 2006 to 2020” is procedurally denied. No records exist within the EEOC.
(42) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Brian Jeffrey Raymond as a former CIA employee who drugged and incapacitated his sexual partners
before taking nude photographs and videos of them” is procedurally denied. No records exist within
the EEOC.
(43) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
Brian Jeffrey Raymond as a former CIA employee who drugged and incapacitated his sexual partners
for the purpose of touching their breasts, buttocks, groin area, and/or genitalia,” is procedurally
denied. No records exist within the EEOC.
(44) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the federal magistrate judge in the U.S. District Court for the Southern District of California implying
that Brian Jeffrey Raymond is two-faced” is procedurally denied. No records exist within the EEOC.
(45) Your request for “[EEOC] communications in the form of e-mails and postal correspondence about
the Department of Health and Human Services (HHS) as a federal agency which has identified drugs
like flunitrazepam (Rohypnol), gamma-hydroxybutyric acid (GHB), gamma-butyrolactone (GBL), and
ketamine, being commonly used for the purpose of rape and sexual assault following a romantic date”
is procedurally denied. No records exist within the EEOC.
(46) Your request for “the academic backgrounds, the professional responsibilities, and annual salaries,
of Anita Bonds, David Grosso, Brianne Nadeau, Robert White, Charles Allen, Samantha Shero, Jaime
Perry, Danielle Hickman, and April Russo,” is procedurally denied. No records exist within the
EEOC.
This response was prepared by Joanne Murray, Government Information Specialist, who may be reached
by telephone to (202) 921-2541.
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CITY OF NEW YORK
CONFLICTS OF INTEREST BOARD
2 Lafayette Street, Suite 1010
New York, New York 10007
(212) 442-1400; (212) 437-0705 (Fax)
www.nyc.gov/ethics
@NYCCOIB
March 18, 2022
Jeffrey D. Friedlander VIA E-MAIL
Chair W (Michael Ayele)
Nisha Agarwal [email protected]
Board Member
Fernando A. Bohorquez, Dear W:
Jr.
Board Member This is in response to your FOIL request to the New York City
Wayne G. Hawley Conflicts of Interest Board (the “Board”), received March 15, 2022, for: “all
Board Member records within your possession detailing [1] the formal and informal ties that
exist between your office, the Central Intelligence Agency (CIA), the
Board Member Department of Justice (DOJ), the Department of State (DoS), the District of
____________ Columbia (D.C) Council, the District of Columbia Government (DC.Gov) and
Carolyn Lisa Miller the Equal Employment Opportunity Commission (EEOC); [2] your
Executive Director communications about DC Bill 318 intent to ‘decriminalize prostitution if
Ethan A. Carrier those involved are 18 years of age or older;’ [3] the researches and studies
General Counsel in use by your office on the subject of prostitution; [4] your communications
Jeffrey Tremblay about the contested studies dealing with the median age of entry into
Director of Enforcement prostitution; [5] your communications about websites such as X-Video, X-
Katherine J. Miller Hamster and Pornhub being among the most visited throughout the world;
Director of [6] your communications about websites such as X-Video, X-Hamster and
Annual Disclosure & Pornhub having an estimated worth of between $3 (three) billions to tens of
Special Counsel billions of U.S dollars; [7] your communications about Google as a search
Alex Kipp engine, which can confirm that there are more searches for Pornhub than
Director of U.S President Joe Biden; [8] your communications about Google as a
Education & Engagement search engine, which can confirm that there are more searches for Pornhub
Varuni Bhagwant than Covid-19 (the Coronavirus disease); [9] your communications about
Director of Google as a search engine, which can confirm that there are more searches
Administration for Pornhub than the online streaming platform Netflix; [10] your
Derick Yu communications about the decision of Pornhub to settle a lawsuit brought
Director of by 50 women against their website; [11] your communications about the
Information Technology decision of Pornhub to suspend content uploaded to their websites by non-
verified users; [12] your communications about Google as a limited liability
company (LLC) headquartered in Mountain View, California; [13] your
communications about the publicized 2018 investigation into police officers
working for Prince George County, Maryland and the Metropolitan Police
Department (D.C) following complaints that were filed against them alleging
extortion of sexual intercourse in exchange for lack of criminal prosecution;
[14] your communications about the MPD as law enforcement agency
(within the DC.Gov,) that has previously disclosed to Michael A. Ayele
(a.k.a) W the memorandum of understanding (MOU) they have concluded
with the University of the District of Columbia (UDC); [15] your
communications about the University of Maryland (UMD) College Park as a
post-secondary academic institution that has previously disclosed to Michael A. Ayele (a.k.a) W the
memorandum of agreement (MOA) they have concluded with the Prince George County Police
Department (PGPD); [16] your communications about D.C. Code Section 22-3001 defining consent
as ‘words or overt actions indicating a freely given agreement to the sexual act or contact in question;’
[17] your communications about D.C. Code Section 22-3001 noting that the ‘lack of verbal or physical
resistance or submission by the victim, resulting from the use of force, threats, or coercion (…) shall
not constitute consent;’ [18] your communications about the UMD as a post-secondary academic
institution that defines ‘sexual coercion’ as the ‘use of unreasonable pressure in an effort to compel
another individual to initiate or continue sexual activity against the individual’s will;’ [19] your
communications about the UMD as a post-secondary academic institution, which acknowledges that
‘coercion include but is not limited to intimidation, manipulation, threats of emotional or physical harm,
and blackmail;’ [20] your communications about the decision of Alexandra Hunt to speak on the
subject of her work-experience as a stripper (when she was a college student); [21] your
communications about the retaliation faced by Alexandra Hunt at her previous place of employment
for speaking on the subject of her work-experience as a stripper (when she was a college student);
[22] your communications about whether Alexandra Hunt’s previous place of employment was being
consistent with Title VII of the 1964 and 1991 Civil Rights Act at the time it retaliated upon her for
speaking on the subject of her work-experience as a stripper (when she was a college student).”
The Board does not have any responsive documents.
Should you wish to appeal this determination, you must send written notice within thirty days
to Carolyn Lisa Miller, Records Appeals Officer, at [email protected].
Very truly yours,
Katherine J. Miller
Records Access Officer
cc: Carolyn Lisa Miller
CITY OF NEW YORK
CONFLICTS OF INTEREST BOARD
2 Lafayette Street, Suite 1010
New York, New York 10007
(212) 442-1400; (212) 437-0705 (Fax)
www.nyc.gov/ethics
@NYCCOIB
March 21, 2022
Jeffrey D. Friedlander VIA E-MAIL
Chair W (Michael Ayele)
Nisha Agarwal [email protected]
Board Member
Fernando A. Bohorquez, Dear W:
Jr.
Board Member This is in response to your FOIL request to the New York City
Wayne G. Hawley Conflicts of Interest Board (the “Board”), received March 19, 2022, for:
Board Member “records within your possession detailing [1] whether the City of New York
has the right to fire employees (in your city government) for previously (i)
Board Member starring in pornographic films, (ii) working as a prostitute, (iii) working as a
____________ stripper etc; [2] whether the City of New York had contacted federal
Carolyn Lisa Miller agencies such as the Equal Employment Opportunity Commission (EEOC)
Executive Director to inquire about your rights to fire employees (in your city government) for
Ethan A. Carrier previously (i) starring in pornographic films, (ii) working as a prostitute, (iii)
General Counsel working as a stripper etc; [3] whether the City of New York is being
Jeffrey Tremblay consistent with Title VII of the 1964 and 1991 Civil Rights Act when firing
Director of Enforcement employees (in your city government) for previously (i) starring in
Katherine J. Miller pornographic films, (ii) working as a prostitute, (iii) working as a stripper; [4]
Director of the formal/informal opinions held by the City of New York on decriminalizing
Annual Disclosure & prostitution; [5] the formal/informal opinions held by the City of New York on
Special Counsel the benefits of decriminalizing prostitution for the purpose of bolstering
Alex Kipp women’s confidence (as well as their trust) in the U.S government when
Director of reporting the sexual violence they have experienced.”
Education & Engagement
Varuni Bhagwant The Board does not have any responsive documents.
Director of
Administration Should you wish to appeal this determination, you must send written
Derick Yu notice within thirty days to Carolyn Lisa Miller, Records Appeals Officer, at
Director of [email protected].
Information Technology
Very truly yours,
Katherine J. Miller
Records Access Officer
cc: Carolyn Lisa Miller
CITY OF NEW YORK
CONFLICTS OF INTEREST BOARD
2 Lafayette Street, Suite 1010
New York, New York 10007
(212) 442-1400; (212) 437-0705 (Fax)
www.nyc.gov/ethics
@NYCCOIB
March 21, 2022
Jeffrey D. Friedlander VIA E-MAIL
Chair W (Michael Ayele)
Nisha Agarwal [email protected]
Board Member
Fernando A. Bohorquez, Dear W:
Jr.
Board Member This is a supplemental response to your FOIL request to the New
Wayne G. Hawley York City Conflicts of Interest Board (the “Board”), received March 15, 2022,
Board Member for: “all records within your possession detailing . . . [23] your
communications about Alexandra Hunt as a woman who opposes the
Board Member decision of former New York City (NYC) Mayor Michael Bloomberg calling
____________ for the removal of Melissa Petro as a teacher ‘after she admitted to her past
Carolyn Lisa Miller in sex work;’ [24] your communications about whether the former NYC
Executive Director Mayor Michael Bloomberg was being consistent with Title VII of the 1964
Ethan A. Carrier and 1991 Civil Rights Act at the time he ‘recommended the city take legal
General Counsel action’ against Melissa Petro; [25] your communications about Alexandra
Jeffrey Tremblay Hunt as a woman who opposes the firing of Heidi Kaeslin from her previous
Director of Enforcement job (at the Lincoln Unified School District located in Northern California); [26]
Katherine J. Miller your communications about whether the Lincoln Unified School District was
Director of being consistent with Title VII of the 1964 and 1991 Civil Rights Act when it
Annual Disclosure & fired Heidi Kaeslin from her job as a school teacher there; [27] your
Special Counsel communications about Alexandra Hunt as a woman who opposes the firing
Alex Kipp of Nina Skye from her previous job in a Los Angeles Christian preschool for
Director of ‘moonlighting in the porn industry;’ [28] your communications about whether
Education & Engagement the firing of Nina Skye is consistent with Title VII of the 1964 and 1991Civil
Varuni Bhagwant Rights Act; [29] your communications about Alexandra Hunt as a woman
Director of who opposes the firing of Stacie Halas from her job at the Oxnard School
Administration District (for starring in pornographic films); [30] your communications about
Derick Yu whether the Oxnard School District was being consistent with Title VII of the
Director of 1964 and 1991 Civil Rights Act when it fired Stacie Halas from her job as a
Information Technology teacher (for starring in pornographic films); [31] your communications about
Alexandra Hunt as a woman who’s passionate about soccer; [32] your
communications about Alexandra Hunt as a woman who has graduated with
an undergraduate degree in Psychology from the University of Richmond;
[33] your communications about Alexandra Hunt as a woman who
graduated from Temple University with a Master of Public Health (MPH)
degree; [34] your communications about Alexandra Hunt as a woman who
identifies as ‘a public health researcher, a girls’ soccer coach, an advocate
for social, racial, economic, and environmental justice, and an organizer
fighting for the 3rd district of Pennsylvania;’ [35] your communications about
Alexandra Hunt as a woman ‘running for’ Congress on a progressive
platform because she believes (…) politicians should fight for systemic
change, ensuring equal opportunity and justice for all;’ [36] your communications about Alexandra
Hunt as a candidate running for Congress in order to decriminalize sex work; [37] your
communications about Alexandra Hunt as a candidate running for Congress in order to reform the
criminal justice system; [38] your communications about the criminal complaint filed by the
Department of Justice (DOJ) against Brian Jeffrey Raymond in the United States District Court for
the District of Columbia, (located 333 Constitution Avenue, Washington D.C); [39] your
communications about Brian Jeffrey Raymond as a Caucasian man who was 45 years old at the time
the DOJ filed Document 68 with E. Barrett Prettyman Courthouse on July 23rd 2021; [40] your
communications about Brian Jeffrey Raymond as a Caucasian man who was a longtime employee
of the CIA; [41] your communications about Brian Jeffrey Raymond as a former CIA employee who
has admitted to the DOJ ‘having recorded and/or photographed at least 24 unconscious nude or
partially nude women without their consent from 2006 to 2020;’ [42] your communications about Brian
Jeffrey Raymond as a former CIA employee who drugged and incapacitated his sexual partners
before taking nude photographs and videos of them; [43] your communications about Brian Jeffrey
Raymond as a former CIA employee who drugged and incapacitated his sexual partners for the
purpose of touching their ‘breasts, buttocks, groin area, and/or genitalia;’ [44] your communications
about the federal magistrate judge in the U.S District Court for the Southern District of California
implying that Brian Jeffrey Raymond is two-faced; [45] your communications about the Department
of Health and Human Services (HHS) as a federal agency, which has identified drugs like
flunitrazepam (Rohypnol), gamma-hydroxybutyric acid (GHB), gamma-butyrolactone (GBL), and
ketamine being commonly used for the purpose of rape and sexual assault following a romantic date;
[46] the academic backgrounds, the professional responsibilities and annual salaries of Anita Bonds,
David Grosso, Brianne Nadeau, Robert White, Charles Allen, Samantha Shero, Jaime Perry, Danielle
Hickman and April Russo.”
The Board responded to your FOIL requests numbered 1 through 22 by letter dated March
18, 2022. Due to administrative error, the Board did not respond to your FOIL requests numbered 23
through 46 and does so in this supplemental response: the Board does not have any responsive
documents.
Should you wish to appeal this determination, you must send written notice within thirty days
to Carolyn Lisa Miller, Records Appeals Officer, at [email protected].
Very truly yours,
Katherine J. Miller
Records Access Officer
cc: Carolyn Lisa Miller
1 of 11 ofM1ISSOURI DEPARTMENT OF MENTAL HEALTH DEPARTMENT
OPERATING
REGULATION
NUMBER
DOR
6.665
MARK STRINGER, DEPARTMENT DIRECTOR
CHAPTER SUBCHAPTER EFFECTIVE DATE NUMBER OF PAGES PAGE NUMBER
Human Resources Employment Rules 12/14/18 3 1 of 3
SUBJECT AUTHORITY HISTORY
Conflict of Interest/Conflicting Employment 1 CSR 20-1.030(3) See Below
PERSON RESPONSIBLE SUNSET DATE
Deputy Director for Human Resources 7/1/22
PURPOSE: To establish guidelines for monitoring employees’ outside/secondary
employment in order to avoid any conflict with the interests of the department,
and to ensure high principles of conduct and ethical behavior in the fidelity and
efficiency of department operations.
(1) Department employees will not engage in any activity or employment in which there
is a significant potential for or the appearance of a conflict of interest with the
functions of the department. Conflict of interest is any activity or employment which
would tend to influence a decision; create a bias or prejudice which would favor one
side or the other in conflict with the employee’s duties; or which conflicts with the
accomplishment of the department’s mission or goals.
(2) Department employees must report current and anticipated employment that is
secondary to their state employment. A request for approval should be made prior to
accepting secondary employment if possible. Any employee who holds secondary
employment without formal approval should request approval as soon as possible.
(3) Department employees are required to fill out a DMH-8210, ‘Application for
Determination of Conflicting Employment/Conflict of Interest’, specifying the nature of
their secondary employment. After submission to the employee’s supervisor, it will be
forwarded to the appointing authority of that department facility who will determine
appropriateness of the request.
(4) The factors which may be considered in rendering any decision regarding outside
employment include consideration of the presence of:
(A) An actual conflict of interest that would be presented by the secondary
employment in light of the duties of the person’s employment with the department
and/or functions of the division or department;
(B) The appearance of a conflict of interest that would be presented by the
secondary employment in light of the duties of the person’s employment with the
department and the letter notifying an employee of such action shall inform the
employee of this right;
(C) The existence of laws and/or regulations which prohibit the secondary
employment; and,
(D) (When applicable) The employee’s past history concerning secondary
employment issues.