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FBI Informant motion for limited discovery Trentadue

FBI Informant motion for limited discovery Trentadue

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Published by Dan Feidt
Jesse Trentadue motion pursuing system of illegal secret government & FBI informant systems embedded in major power structures. SOURCE http://bobmccarty.com/wp-content/uploads/2013/01/MOTION-FOR-LIMITED-DISCOVERY_ecf.pdf
http://bobmccarty.com/2013/01/30/brother-of-murder-victim-seeks-details-of-fbis-sensitive-informant-program/
Jesse Trentadue motion pursuing system of illegal secret government & FBI informant systems embedded in major power structures. SOURCE http://bobmccarty.com/wp-content/uploads/2013/01/MOTION-FOR-LIMITED-DISCOVERY_ecf.pdf
http://bobmccarty.com/2013/01/30/brother-of-murder-victim-seeks-details-of-fbis-sensitive-informant-program/

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Published by: Dan Feidt on Jan 31, 2013
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01/31/2013

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Jesse C. Trentadue (#4961)8 East Broadway, Suite 200Salt Lake City, UT 84111Telephone: (801) 532-7300Facsimile: (801) 532-7355 jesse32@sautah.com
Pro Se Plaintiff 
UNITED STATES DISTRICT COURTFOR THE DISTRICT OF UTAH, CENTRAL DIVISION
JESSE C. TRENTADUE,Plaintiff,vs.FEDERAL BUREAU OFINVESTIGATION,Defendant.:::::::::::::::
PLAINTIFF’S MOTION TOCONDUCT LIMITED DISCOVERYRE: SCOPE AND DURATION OFFBI’s SENSITIVE INFORMANTPROGRAM
Case No.: 2:12cv974Judge Dale A. KimballMagistrate Evelyn J. Furse
MOTION
This matter is currently set for an
 Initial Pretrial Conference
on March 21,2013, the purpose of which is to, among other things, settle discovery issues. Thatis also the purpose of this
Motion,
which is to determine whether Plaintiff isentitled to limited discovery into Defendant Federal Bureau of Investigation’s
Case 2:12-cv-00974-DAK Document 22 Filed 01/28/13 Page 1 of 19
 
Sensitive Informant Program
,”
1
which is used by the Bureau to recruit and/orplace informants on the staffs of members of the United States Congress andperhaps even federal judges, in the national media,
2
within other federal agenciesas well as the White House, on defense teams in high profile federal and/or statecriminal prosecutions,
3
inside state and local law enforcement agencies, and evenamong the clergy of organized religions.In response to Plaintiff’s
Freedom of Information Act 
(“
FOIA
”) request forthe policies, rules, protocols and/or procedures (collectively the “
 Manual
”)governing the FBI’s recruitment and use of such informants in this secretsurveillance program, the FBI acknowledged the existence of this program andproduced to Plaintiff a small portion of the
 Manual
, which was heavily redacted.
4
 But the FBI also withheld from Plaintiff what appear to be hundreds of pages from
1
 
Plaintiff further certifies that he and counsel for the FBI have conferred in goodfaith to resolve this discovery dispute but, despite those efforts, they have beenunsuccessful.
2
 
The FBI’s use of 
Sensitive Informants
in the national news media is welldocumented in the record of this case.
See, e.g.
, Exhibits 1, 2 and 3, hereto.
3
 
As patently unconstitutional as the use of such informants would be, there isevidence that the FBI had such an informant with access to members of the defense teamin the prosecution of Timothy McVeigh.
See
Exhibit 4 hereto.
4
 
See
Exhibit 5 hereto
. See also
Doc. Nos. 14-8, 14-9 and 14-10.
2
Case 2:12-cv-00974-DAK Document 22 Filed 01/28/13 Page 2 of 19
 
the
 Manual.
The FBI did so under a claim that this material was exempt fromdisclosure under
FOIA
.Counsel for the FBI has advised Plaintiff that the FBI intends to file a
 Motion for Summary Judgment 
, and that the only purpose of the
SchedulingConference
is to set the time for the FBI’s
 Motion
and Plaintiff’s response.Plaintiff disagrees with the FBI’s position of no discovery, especially in anextraordinary case such as this wherein the FBI acknowledges the existence of anunlawful and unconstitutional domestic spying program, and attempts to use theexemption provided by
FOIA
to not disclose the
 Manual
that it uses to carry outthis illegal activity.Plaintiff has brought this lawsuit to obtain those potions of the
 Manual
being withheld by the FBI, which will necessarily involve the Court reviewing anddetermining the applicability, legitimacy and/or lawfulness of the exemptionsproffered by the Bureau for withholding this material.
5
Plaintiff submits that the
5
 
The FBI states that it redacted and/or withheld entire portions of the
Manual
from Plaintiff on the basis of 5
U.S.C.
§§ (b)(1) (exempting documents classified asinvolving national security); (b)(5) (exempting inter-agency or intra-agency memorandathat would not be available to a party in litigation with that agency); (b)6)(exemptingpersonnel, medical and similar files the disclosure of which would clearly constitute anunwarranted invasion of privacy); (b)(7)(C) (further exempting material the release of which would be an unwarranted invasion of personal privacy); (b)(7)(D)(exempting
3
Case 2:12-cv-00974-DAK Document 22 Filed 01/28/13 Page 3 of 19

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