NVDEMS
February 28, 2017
Federal Bureau of Investigation
Record/Information Dissemination Section
Attn: FOIA Request
170 Marcel Drive
Winchester, VA 22602-4843
Re: Freedom of Information Act Request
Dear Freedom of Information Officer:
Pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, we hereby request that
the Federal Bureau of Investigation (“FBI”) produce the following within twenty (20) business
days:
including but not limited to interview memoranda or
notes of any interviews or conversations between the FBI, on the one hand,
and Nevada Gaming Control Board Chairman A.G. Burnet, on the other,
that relate to a then-ongoing wrongful termination lawsuit against the Las
Vegas Sands Corporation that Nevada Attorney General Adam Laxalt asked
Burnett to intercede in. This includes any record created by Chairman
Burnett that was subsequently turned over to the FBI.
The timeframe for this request is April 1, 2015 to February 28, 2017.
If any responsive record or portion thereof is claimed to be exempt from production under FOIA,
please provide sufficient identifying information with respect to each allegedly exempt record or
portion thereof to allow us to assess the propriety of the claimed exception. In addition, any
reasonably segregable portion of the responsive record must be provided, after redaction of any
allegedly exempt material,
For purposes of this request, the term “record” shall mean: (1) any written, printed, or typed
‘material of any kind, including without limitation, all correspondence, memoranda, notes,
messages, faxes, papers, telephone messages, transcriptions or memoranda memorializing
telephone and/or in-person conversations, reports, charts, lists, ledgers, invoices, agreements;
(2) any electronically, magnetically, or mechanically stored material of any kind, including all
electronic mail or e-mail, telephony metadata, and electronic metadata;
@NVDEMS
NVDEMS.COM
P 702.737.8683
F 702.735.2700
6233 DEAN MARTIN DRIVE
LAS VEGAS, NV 89118.3800(3) any audio, aural, visual, or video records, recordings, or representations of any kind; and (4)
any materials created through other means of preserving thought or expression, If a recording of
the conversation is not available, we request a complete transcript of the conversation.
We hereby request a waiver of both search and duplication fees pursuant to 5 U.S.C. §
552(a)(4)(A\iii). Under this provision, records:
Shall be furnished without any charge or at a charge reduced below the fees
established under clause (ii) if disclosure of the information is in the public
interest because itis likely to contribute significantly to public understanding of
the operations or activities of government and is not primarily in the commercial
interest of the requester.
We are also entitled to a complete waiver of search and duplication fees, if records are not
produced within twenty (20) business days, pursuant to Section 6(b) of the OPEN Government
Act of 2007.
We have no commercial purpose in seeking these records. The sole purpose of this request is to
educate and inform the public about a potential ethical violation by the Attorney General of
Nevada, who is alleged to have interceded in a private lawsuit involving one of his political
contributors in violation of Nevada law.' Once we obtain the requested records, we intend to
disseminate the records and educate the public about the results,
Given these circumstances, we are entitled to a public interest fee waiver of search and
duplication costs. In the event our request for a waiver is denied, we are willing to pay up to
$1,000 in search and/or duplication costs.
In order to facilitate record production within the statutory time limit, we are willing to accept
records in electronic formation (e.g., email or pdf8), and on a “rolling” basis, as documents ate
ready to be produced. Paper or hard-copy materials can be sent to the following mailing address:
Nevada State Democratic Party
6233 Dean Martin Drive
Las Vegas, NV 89118
" Jon Ralston, Chief Gaming Regulator Secretly Recorded Conversation with Attorney General, Turned Tape Over
to FBI, The Nevada Independent (Feb. 15, 2017), available at bxtps:/thenevadaindependent.convarticle-shic':
regulator-zave-recording-of-conversation-wiih-4g-t0-fbi
-2-If you do not understand this request, or if you require clarification, please contact us
immediately by email at cwarfield@nvdems.com. We look forward to receiving the requested
records and a waiver of search and duplication costs within twenty (20) business days. Thank
you for your cooperation and prompt attention to this matter.
Sincerely,
Karten Porrigg-
Roberta Lange
Chair, Nevada State Democratic Party