To Whom It May Concern:
Pursuant to the Connecticut Freedom of Information Act, I hereby request the following records:
To: Freedom of Information Officers
Connecticut Commission on Human Rights and Opportunities (CHRO)
Subject: Comprehensive FOIA Request for All Records Related to CHRO Case 2410220
Dear Freedom of Information Officers,
I am writing to formally request complete access to all records associated with CHRO Case 2410220 under the Connecticut Freedom of Information Act (C.G.S. 1-200 to 1-242). This request pertains to any and all documentation related to the service, handling, and outcome of CHRO Case 2410220. My objective is to obtain the fullest understanding possible of the case details, procedures, and decisions involved.
Scope of Request
I am requesting access to the following records:
Service of Complaint Documentation:
All records detailing the service of the complaint in CHRO Case 2410220, including dates, methods of service, confirmation of receipt, and any associated communications.
Internal and External Correspondence:
All internal and external communications, including emails, letters, memos, and any other forms of correspondence related to CHRO Case 2410220, especially regarding the handling, processing, or adjudication of this case.
Case Handling and Decision-Making Documentation:
Any and all status reports, progress notes, internal briefings, policy memoranda, and other documents related to the decision-making and resolution of CHRO Case 2410220.
Documentation regarding the policies, protocols, or legal considerations applied in the case review and adjudication process.
Personnel and Oversight Records:
Non-confidential employment records, including job descriptions, training, and performance evaluations of personnel directly involved in the handling and oversight of CHRO Case 2410220.
Organizational charts or departmental breakdowns that detail the roles and responsibilities of individuals managing this case.
Final Decision, Findings, and Resolutions:
Finalized findings, resolutions, reports, or conclusions reached for CHRO Case 2410220, including documentation of any actions taken or corrective measures applied.
Financial and Operational Data Related to Case Handling:
Any financial records, operational budgets, or expenditure reports relevant to the management of CHRO Case 2410220, including any funding allocations or resources used in the investigation or case processing.
Records Related to Compliance and Consumer Rights:
Documentation regarding compliance with ADA standards, consumer protection protocols, and civil rights obligations as they relate to the processing of CHRO Case 2410220.
Accommodation Requests
To ensure this FOIA request is processed in alignment with my accessibility requirements, please adhere to the following accommodations. These accommodations are essential for my full participation in all aspects of this request:
Email-Only Communication:
All responses, updates, and communications must be sent exclusively via email to AabiWR@live.com. I request no physical mail, phone calls, portal-based communications, external links, or any platform outside of direct email.
Format Requirement:
Include the full text of each response within the body of the email, with all documents attached. This ensures immediate accessibility without requiring downloads or access to external sites.
Complete and Transparent Documentation:
Provide all requested documents in full, with no redactions unless legally required. For any necessary redactions, cite the specific legal exemption or statute applied, and include a summary to ensure complete transparency.
Detailed Explanations for Any Denials:
If any portion of this request is denied, please include a clear, detailed explanation for each denial, citing relevant legal statutes or exemptions.
Guidance for Complex Records:
For records containing complex financial, legal, or procedural language, please provide summaries or simplified explanations to ensure full comprehension.
Identification of FOIA Officer:
Provide the full name, title, and direct contact information of the FOIA officer assigned to my request. This information is necessary for transparency and records.
Confirmation of Accommodations:
Confirm receipt of this request and explicitly acknowledge that each accommodation listed will be applied in all responses and communications.
Request for Expedited Processing
Due to the pressing public interest in understanding and addressing civil rights protections within Connecticut's Medicaid ABI Waiver Program, I am requesting expedited processing in accordance with FOIA standards.
Please provide immediate acknowledgment of the expedited processing request. If denied, provide a detailed written explanation citing specific legal grounds, in compliance with FOIA statutes.
Fee Waiver Request
I request a waiver of all fees associated with this FOIA request under Conn. Gen. Stat. 1-212(d), as this information serves the public interest and is not being requested for commercial purposes. All requested records will be made publicly available on MuckRock.com to contribute to the understanding of CHROs operations in handling cases of public importance.
In the event fees are anticipated, please inform me of the total cost in advance.
Legal Grounds for Request
This request is made under:
Connecticut Freedom of Information Act (C.G.S. 1-200 to 1-242)
Americans with Disabilities Act (ADA) (42 U.S.C. 12101 et seq.) for accommodations and accessibility
Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 794) to ensure non-discriminatory access to public records
Thank you for your prompt attention to this matter. I look forward to receiving a response within the statutory timeframe, as required by Connecticut FOIA law.
Sincerely,
David Medeiros
ABI Resources
215 Mountain Street
Willimantic, CT 06226
Email: AabiWR@live.com
I also request that, if possible and pursuant to Conn. Gen. Stat. 1-212(d), fees be waived as I believe this request is in the public interest and not made for commercial gain. The requested documents will be made available to the public at MuckRock.com.
In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 4 business days, as the statute requires.
Sincerely,
DAVID MEDEIROS
[Share image]
Perry, Charles shared a folder with you
Hi Mr. Medeiros,
Per your request please find attached a complete electronic copy of the above-requested discrimination complaint file. If you have any questions or need any additional assistance, please feel free to contact me.
Sincerely,
Charles Perry
<https://ctgovexec.sharepoint.com/:f:/s/CHROCHRO/Emy73-Eeqb9OlfOME5I1880Bh-FbR0_DTWKDwTNkvzV6gw?e=5%3AULJE47>
[icon] 2410220 David Medeiros v. Department of Social Services
[permission globe icon] This link only works for the direct recipients of this message.
Open <https://ctgovexec.sharepoint.com/:f:/s/CHROCHRO/Emy73-Eeqb9OlfOME5I1880Bh-FbR0_DTWKDwTNkvzV6gw?e=5%3AULJE47>
[cid:7ff742ef-1086-42f8-93f1-6468393c8e7b]
This email is generated through State of Connecticut's use of Microsoft 365 and may contain content that is controlled by State of Connecticut.
Hello,
For security purposes, you must enter the code below to verify your account to access 2410220 David Medeiros v. Department of Social Services. The code will only work for 15 minutes and if you request a new code, this code will stop working.
Account verification code:
98358179
Having problems with the code?
View the error and make sure that the email identifier is "XSTG1HC". If it's not, look for an updated email or try requesting a new code.
PrivacyStatement (https://go.microsoft.com/fwlink/?LinkId=521839)
This email is generated through State of Connecticut's use of Microsoft 365.
FOIA Appeal and Demand for Comprehensive Disclosure CHRO Case No. 2410220
To:
Connecticut Commission on Human Rights and Opportunities (CHRO) FOIA Officer, Supervisory Personnel, and Relevant State Authorities
CC:
Connecticut Department of Social Services (DSS) FOIA Officer
Federal and State Oversight Bodies: U.S. Department of Justice Civil Rights Division, Office of the Inspector General, ADA Compliance Authorities, Senators Richard Blumenthal and Chris Murphy, Governor Ned Lamont, and Attorney General William Tong
Dear FOIA Officer, Supervisory Personnel, and Relevant State Authorities,
This letter serves as a formal FOIA appeal under the Connecticut Freedom of Information Act (C.G.S. 1-200 to 1-242), the Americans with Disabilities Act (42 U.S.C. 12101 et seq.), and Section 504 of the Rehabilitation Act (29 U.S.C. 794). It is submitted in response to incomplete disclosures and obstructions following my initial FOIA request regarding CHRO Case No. 2410220. I am demanding complete, unredacted, and fully inclusive disclosure of all records associated with this case to ensure transparency and accountability in the handling of ADA compliance, alleged discriminatory practices, whistleblower retaliation, and related procedural issues within CHRO and DSS.
Scope of Requested Records
To eliminate ambiguity and ensure full compliance, I specify each category of records required. This appeal seeks comprehensive disclosure of all records related to CHRO Case No. 2410220 without redactions that compromise transparency. Records must include references to the following individuals and officials directly involved in or overseeing this case:
CHRO and DSS Personnel: Debra Morris, Kimberly D. Morris, Jennifer Nicole Zakrzewski, Michael Slitt, Matthew S. Antonetti, Andrea Barton Reeves (DSS Commissioner), and Judge Dr. Cherron Payne.
Oversight Authorities: Senator Richard Blumenthal, Senator Chris Murphy, Governor Ned Lamont, and Attorney General William Tong.
Categories of Records Required:
Complete Internal and External Communications
All emails, internal messages, memos, letters, meeting notes, attachments, text messages, and digital communications related to CHRO Case No. 2410220, including communications from the CHRO and DSS officials named above.
Correspondence with federal and state oversight representatives, including Senators Blumenthal and Murphy, Governor Lamont, and Attorney General Tong, on matters regarding complaints, ADA accommodations, whistleblower protections, or any aspect of procedural handling associated with this case.
Detailed email and phone logs covering all communication channels used for this case to ensure a comprehensive record of contacts between CHRO, DSS, and external oversight entities.
Personnel Documentation and Role-Specific Information
Non-confidential records detailing job descriptions, titles, responsibilities, ADA compliance training certifications, and performance evaluations for each CHRO and DSS employee involved in this case, including Debra Morris, Kimberly D. Morris, Jennifer Nicole Zakrzewski, Matthew S. Antonetti, Andrea Barton Reeves, Michael Slitt, and Judge Dr. Cherron Payne.
Organizational charts showing the chain of command and oversight responsibilities within CHRO and DSS as they relate to this case, identifying each officials specific role and involvement level in decision-making and case management.
Case Processing, Management, and Decision-Making Documentation
Internal and external reports, case processing logs, decision-making records, and case status updates associated with CHRO Case No. 2410220. Include workflow charts, status reports, meeting minutes, progress logs, and any rationale documenting each procedural step taken by CHRO and DSS personnel in handling this case.
Guidance documents and internal policies used in determining responses to FOIA requests, ADA accommodations, and whistleblower complaints. Include specific directives or instructions provided to Debra Morris, Kimberly D. Morris, Jennifer Nicole Zakrzewski, and other involved personnel.
Financial, Operational, and Compliance Records Related to Case Handling
All financial records, budgets, and expenditure reports specifically allocated to the handling and oversight of CHRO Case No. 2410220, including any state or federal funds earmarked for ADA compliance and FOIA administration.
Audit findings, compliance reviews, and corrective actions taken by CHRO or DSS related to ADA and FOIA compliance requirements, including any internal reviews or third-party audits examining procedural adequacies, delays, or omissions in ADA compliance.
Complaint Histories, Retaliation Protections, and Investigation Records
Full records of prior complaints, retaliation protections, and whistleblower claims involving personnel assigned to CHRO Case No. 2410220, including Michael Slitt, Judge Dr. Cherron Payne, Debra Morris, and Andrea Barton Reeves. Documentation should cover each internal or external investigation and any resolutions or corrective measures following these complaints.
Additional documentation of patterns of reported conduct within CHRO or DSS relating to ADA non-compliance, retaliatory practices, or procedural misconduct relevant to my case.
Document Drafts, Revisions, and Full Document Histories
All versions, drafts, edits, annotated notes, and revisions of documents related to CHRO Case No. 2410220, including every change made by Debra Morris, Andrea Barton Reeves, and other involved CHRO or DSS personnel. Document histories should trace edits, intended outcomes, and procedural compliance decisions.
Tracked revision histories illustrating the evolution of each document to establish a clear record of transparency and accountability in official decision-making processes.
Policies and Internal Guidelines Governing ADA, FOIA, and Whistleblower Compliance
Full, unredacted copies of CHRO and DSS internal policies and procedural guidelines on ADA accommodations, FOIA request handling, whistleblower protections, and complaint investigation practices. This includes policies on ADA accommodations for brain injury survivors and CHROs non-retaliation and transparency standards.
Any guidelines or memos on best practices or procedural compliance related to ADA, FOIA, or whistleblower handling circulated among CHRO and DSS personnel.
Accommodation Requests for Full Compliance
To ensure this FOIA request is processed accurately and meets my accessibility requirements, please adhere to the following accommodations. These accommodations are essential to allow my full and equitable participation in every aspect of this request, as supported by ADA and Section 504 standards.
1. Exclusive Email Communication Requirement
Directive: All responses, updates, and communications must be sent directly via email to AabiWR@live.com. Do not use physical mail, phone calls, portal-based communications, external links, or any platform outside of direct email.
Purpose: This ensures uninterrupted, immediate access to all correspondence and records without barriers, facilitating a fully accessible review process.
2. Full Text in Email Body with Attachment
Directive: Provide the full text of each response within the body of the email, alongside any attached documents available for download.
Purpose: Including the full text in the email body allows for seamless, direct access to information, ensuring that all content is accessible without the need for additional downloads or platform navigation.
3. Accessible Document Formatting
Directive: Attach all records as individually labeled PDFs, organized by category and date. Each document should be clearly indexed for ease of reference.
Purpose: This organization and accessible format support ADA accommodations, allowing for clear, barrier-free document review and navigation.
4. Complete and Transparent Documentation
Directive: Provide all requested records in full, without redactions unless legally mandated. If redactions are necessary, cite the specific legal exemption or statute applied and include a summary where possible to maintain context.
Purpose: This ensures full transparency and access to all relevant information, allowing for a comprehensive understanding of each record without unnecessary limitations.
5. Detailed Justifications for Redactions or Denials
Directive: For any redactions or denials, provide a clear, detailed explanation for each item, including the specific legal statute or exemption used.
Purpose: This accommodation ensures transparency and accountability in the review process, allowing for clarity on any withheld information.
6. Guidance for Complex Records
Directive: For records containing complex financial, legal, or medical terminology, provide summaries or simplified explanations to facilitate understanding.
Purpose: This accommodation supports accurate interpretation of information, particularly in areas requiring specialized knowledge, to ensure full comprehension.
7. Identification of Responsible FOIA Officer(s) and Decision-Makers
Directive: Provide the full names, titles, direct email addresses, and phone numbers of each FOIA officer, decision-maker, or supervisory personnel responsible for this request.
Purpose: Clear identification of all involved personnel supports accountability and enables direct communication if clarification or follow-up is required.
8. Confirmation of Accommodation Compliance
Directive: Confirm receipt of this request and explicitly acknowledge that each accommodation will be fully applied in all responses and communications.
Purpose: This confirmation ensures that my accessibility needs are fully understood and respected by all handling this request, providing assurance of compliance.
9. Expedited Processing
Directive: Due to the urgency of the public interest in this matter, I request expedited processing of this FOIA request as mandated by 5 U.S.C. 552(a)(6)(E) and Conn. Gen. Stat. 1-210(a).
Purpose: Expedited processing supports timely access to records essential for immediate public and legal oversight, especially in matters affecting vulnerable populations or public welfare.
Legal Standards for Compliance
This request and appeal are based on the following legal mandates:
Connecticut FOIA (C.G.S. 1-200 to 1-242) Mandates full, prompt, and unambiguous access to public records.
Americans with Disabilities Act (42 U.S.C. 12101 et seq.) Requires equitable access to all records and processes for individuals with disabilities.
Section 504 of the Rehabilitation Act (29 U.S.C. 794) Guarantees equal access and ADA accommodations, particularly in public agency processes affecting disabled individuals.
Immediate Response Required: Confirm receipt of this appeal, provide a timeline for compliance with the requested accommodations, and commit to a specific delivery date for comprehensive disclosure of all requested records. Partial compliance, unjustified redactions, or further obstruction will prompt escalated legal and federal oversight to enforce adherence to FOIA, ADA, and federal whistleblower protections.
By meeting these statutory requirements, CHRO and DSS can fulfill their legal and ethical obligations for transparency, accountability, and procedural integrity.
Sincerely,
David Medeiros
Founder, ABI Resources
Email: AabiWR@live.com
FOIA Appeal and Comprehensive Disclosure Request CHRO Case No. 2410220
To:
Connecticut Commission on Human Rights and Opportunities (CHRO) FOIA Officer, Supervisory Personnel, and Relevant State Authorities
CC:
Connecticut Department of Social Services (DSS) FOIA Officer
Federal and State Oversight Bodies: U.S. Department of Justice Civil Rights Division, Office of the Inspector General, ADA Compliance Authorities, Senators Richard Blumenthal and Chris Murphy, Governor Ned Lamont, and Attorney General William Tong
Dear FOIA Officer, Supervisory Personnel, and Relevant State Authorities,
I am submitting this FOIA appeal directly to CHRO, DSS, and relevant oversight bodies. Please note that all records requested are in the public interest and pertain to CHRO Case No. 2410220, focusing on transparency in ADA compliance, whistleblower protections, and procedural accountability within CHRO and DSS.
Scope of Requested Records
I am requesting a comprehensive disclosure of all public records associated with CHRO Case No. 2410220. To facilitate accurate and complete processing, I outline each category of records required and reiterate my accommodations to ensure accessibility.
Internal and External Communications
All emails, internal messages, memos, and meeting notes involving CHRO and DSS personnel (Debra Morris, Kimberly D. Morris, Jennifer Nicole Zakrzewski, Michael Slitt, Matthew S. Antonetti, Andrea Barton Reeves, and Judge Dr. Cherron Payne).
Correspondence with federal and state oversight representatives on ADA accommodations and procedural handling related to this case.
Complete email and phone logs of communication channels for this case.
Personnel Documentation and Role-Specific Information
Public records on job descriptions, responsibilities, ADA compliance training certifications, and performance reviews of CHRO and DSS personnel involved in the case.
Organizational charts showing the chain of command for CHRO and DSS as it relates to this case.
Case Processing, Management, and Decision-Making Documentation
Case processing logs, decision records, meeting minutes, and procedural steps taken by CHRO and DSS personnel in handling Case No. 2410220.
Financial, Operational, and Compliance Records Related to Case Handling
Financial records and budget reports allocated to handling and oversight of Case No. 2410220, including ADA and FOIA compliance reviews or third-party audits.
Complaint Histories, Retaliation Protections, and Investigation Records
Records of prior complaints, retaliation protections, and whistleblower claims involving relevant personnel, including investigation outcomes.
Document Drafts, Revisions, and Full Document Histories
All versions, edits, and revision histories of documents related to Case No. 2410220 to provide transparency in decision-making.
Policies and Internal Guidelines Governing ADA, FOIA, and Whistleblower Compliance
Full copies of CHRO and DSS policies on ADA accommodations, FOIA handling, and whistleblower protections, specifically for brain injury survivors.
Accommodation Requests
To ensure equal access under ADA and Section 504, please apply the following accommodations:
Exclusive Email Communication: Send all responses directly via this platform.
Full Text in Email Body and Attachment: Include the full text of each response in the email body and attach files as PDFs for ease of review.
Accessible Formatting: Label and organize PDFs by category and date, with each document indexed for accessibility.
Transparent Documentation: Provide records in full, without redactions, unless legally required. For necessary redactions, include the specific legal exemption and a summary for context.
Detailed Justifications for Redactions or Denials: Specify any legal statutes applied for redactions.
Guidance for Complex Records: Summaries or simplified explanations for records with technical terminology.
Identification of Responsible Personnel: Full names, titles, and email addresses of each FOIA officer, decision-maker, or supervisory personnel responsible for this request.
Confirmation of Accommodation Compliance: Confirm receipt and accommodation compliance.
Expedited Processing: Expedite processing per 5 U.S.C. 552(a)(6)(E) and Conn. Gen. Stat. 1-210(a).
These accommodations are in alignment with ADA and Section 504 standards, as they ensure my equitable access to all records without unnecessary barriers.
Legal Standards for Compliance
This request is based on Connecticut FOIA (C.G.S. 1-200 to 1-242), the ADA (42 U.S.C. 12101 et seq.), and Section 504 of the Rehabilitation Act (29 U.S.C. 794). These statutes require CHRO and DSS to provide full, equitable access to records and reasonable accommodations for individuals with disabilities.
Immediate Response Required
Please confirm receipt of this appeal within 3 business days, provide a timeline for compliance with requested accommodations within 10 business days, and a specific delivery date for comprehensive disclosure. If full compliance or accommodation adherence is not met, further federal and state-level action will be pursued.
Thank you for ensuring transparency, accessibility, and compliance in addressing this FOIA appeal, which serves the public interest in protecting ADA rights and upholding procedural accountability.
Sincerely,
David Medeiros
Founder, ABI Resources
Appeal: Comprehensive Disclosure and ADA Compliance for CHRO Case No. 2410220
Date: November 22, 2024
From: David Medeiros
To: Freedom of Information Officers, Connecticut Commission on Human Rights and Opportunities (CHRO)
Subject: FOIA Appeal for Complete Disclosure and ADA Compliance CHRO Case No. 2410220
Dear FOIA Officer, Supervisory Personnel, and Relevant State Authorities:
This letter serves as a formal FOIA appeal under the Connecticut Freedom of Information Act (C.G.S. 1-200 to 1-242), the Americans with Disabilities Act (ADA, 42 U.S.C. 12101 et seq.), and Section 504 of the Rehabilitation Act (29 U.S.C. 794). It follows an incomplete response to my initial request regarding CHRO Case No. 2410220. This appeal demands complete, unredacted, and ADA-compliant disclosure of all relevant public records.
Grounds for Appeal
Failure to Provide Full Disclosure:
The response to my initial FOIA request omitted key categories of records. This is a violation of Connecticut FOIAs requirement for full and prompt disclosure.
ADA Non-Compliance:
The agency failed to meet its legal obligation to provide records in an accessible format and apply the accommodations requested.
Unjustified Redactions or Withheld Information:
The agency did not provide proper statutory justifications or summaries for redactions or withheld records.
Procedural Failures in Communication:
The agency has not adhered to the clear communication requirements outlined in my original request, specifically accommodations for MuckRock platform-exclusive communication.
Requested Records
To ensure transparency and compliance, this appeal specifies the following categories of records required:
Internal and External Communications:
All emails, letters, memos, meeting notes, and phone logs related to CHRO Case No. 2410220.
Correspondence between CHRO, DSS, and state/federal oversight entities, including:
Debra Morris, Kimberly D. Morris, Andrea Barton Reeves, Judge Dr. Cherron Payne, and Senators Blumenthal and Murphy.
Personnel Information (Non-Confidential):
Job descriptions, training certifications, and ADA compliance roles of all personnel handling CHRO Case No. 2410220.
Organizational charts identifying decision-makers and supervisory personnel involved.
Case Management and Decision-Making Documentation:
Logs, notes, and reports tracking procedural steps, status updates, and decisions made in the case.
Guidance documents used in evaluating this case.
Financial and Compliance Records:
Budgets, financial allocations, and compliance reviews specific to ADA enforcement and FOIA administration for this case.
Complaint Histories and Whistleblower Protections:
Prior complaints, investigation records, and retaliation claims involving personnel overseeing CHRO Case No. 2410220.
Document Drafts and Revisions:
All document versions, drafts, and annotated notes related to this case.
Policies and Guidelines:
Internal policies on ADA accommodations, whistleblower protections, and FOIA processing.
ADA Accommodations
To ensure equitable access, this appeal reiterates the following ADA accommodations:
MuckRock Platform-Exclusive Communication:
All responses must be processed and communicated exclusively via the MuckRock platform, with text embedded in emails and screen-reader-compatible PDFs for attachments. Physical mail, external portals, or phone calls are not permitted.
Accessible Document Formatting:
All documents must be labeled and indexed by category and date.
Detailed Justifications for Redactions:
Provide specific legal exemptions and summaries for all redactions.
Clear Explanations for Complex Records:
Include simplified summaries for technical or complex records.
Expedited Processing
This appeal requests expedited processing under Connecticut FOIA (C.G.S. 1-210(a)) due to the urgent public interest in ADA compliance and whistleblower protections.
Legal Framework for Compliance
This appeal is supported by the following statutes:
Connecticut FOIA (C.G.S. 1-200 to 1-242): Mandates timely, complete disclosure of public records.
ADA (42 U.S.C. 12101 et seq.): Requires reasonable accommodations for individuals with disabilities.
Section 504 of the Rehabilitation Act (29 U.S.C. 794): Ensures equitable access to public records and processes.
Required Actions
To resolve this appeal, I demand the following:
Confirmation of ADA Accommodations:
Acknowledge receipt of this appeal and confirm compliance with all ADA accommodations within 3 business days.
Comprehensive Disclosure:
Provide all requested records in full, organized by category, within 10 business days.
Detailed Justifications:
For any withheld or redacted records, include detailed legal citations and summaries.
Identification of FOIA Officers:
Provide the full names, titles, and contact information of personnel responsible for this appeal.
Next Steps
If compliance is not achieved within the specified timeframe, I will escalate this matter to:
Connecticut Freedom of Information Commission (FOIC).
U.S. Department of Justice Civil Rights Division.
Office of Government Information Services (OGIS).
State and Federal Courts.
Sincerely,
David Medeiros
Founder, ABI Resources
Email: AabiWR@live.com
CC List:
Andrea Barton Reeves DSS Commissioner
Governor Ned Lamont Office of the Governor
Attorney General William Tong State of Connecticut
Senator Richard Blumenthal
Senator Chris Murphy
U.S. Department of Justice Civil Rights Division
Connecticut FOIC (Freedom of Information Commission)
Office of Government Information Services (OGIS)
Complaint and Appeal
Date: January 1, 2025
To: Connecticut Commission on Human Rights and Opportunities (CHRO) FOIA Officers and Supervisory Officials
Subject: Formal FOIA Appeal: Comprehensive Disclosure and ADA Compliance for CHRO Case No. 2410220
Introduction
This appeal is submitted under the Connecticut Freedom of Information Act (C.G.S. 1-200 to 1-242), the Americans with Disabilities Act (ADA, 42 U.S.C. 12101 et seq.), and Section 504 of the Rehabilitation Act (29 U.S.C. 794). It addresses CHROs failure to provide comprehensive disclosure and to adhere to required ADA accommodations following my FOIA request regarding CHRO Case No. 2410220. The violations outlined herein include:
Non-compliance with statutory FOIA obligations.
Failure to provide reasonable ADA accommodations.
Omission of key records and incomplete responses.
This appeal demands immediate compliance to ensure transparency, accountability, and equitable access to information under applicable state and federal laws.
Violations and Legal Basis for Appeal
1. Non-Compliance with Connecticut FOIA Deadlines and Disclosure Requirements
Under C.G.S. 1-210(a), agencies must provide prompt access to public records or a legally sufficient response within four business days of receipt. CHRO failed to:
Provide complete responses to my FOIA request.
Disclose critical records, such as case management logs, personnel documentation, and communications involving CHRO Case No. 2410220.
Legal Precedents Supporting Appeal:
NARA v. Favish, 541 U.S. 157 (2004): Reinforces the publics right to access government records for oversight.
Conn. FOIC v. Dept. of Public Health, 228 Conn. 158 (1994): Establishes the duty of agencies to disclose records promptly and comprehensively.
Demand:
CHRO must immediately produce all records outlined in the scope of this appeal or provide detailed statutory justifications for any withheld documents.
2. Failure to Provide ADA-Compliant Accommodations
My initial FOIA request explicitly included ADA accommodation requirements due to cognitive challenges related to a traumatic brain injury (TBI). These accommodations, mandated under 42 U.S.C. 12132 and 28 C.F.R. 35.160, are non-negotiable and essential for equitable participation. CHRO has failed to:
Transition communications to the MuckRock platform as requested.
Provide documents in screen-reader-compatible PDF format.
Include simplified summaries for complex records.
Legal Precedents Supporting Appeal:
Alexander v. Choate, 469 U.S. 287 (1985): Protects the rights of individuals with disabilities to access public services equally.
Tennessee v. Lane, 541 U.S. 509 (2004): Enforces ADA mandates for accessibility in public processes.
Demand:
CHRO must confirm compliance with ADA accommodations in all future communications and rectify past violations by providing reformatted, accessible documents as outlined in this appeal.
3. Whistleblower and Taxpayer Protections
This appeal also implicates whistleblower rights under 5 U.S.C. 2302(b)(8) and taxpayer protections by ensuring transparency in CHRO and DSS operations. The failure to disclose requested records obstructs public accountability and compromises the ethical administration of state programs.
Legal Precedents Supporting Appeal:
DOJ v. Reporters Committee, 489 U.S. 749 (1989): Recognizes FOIA as a critical tool for government accountability.
Conn. FOIC v. Freedom of Information Officer, 302 Conn. 724 (2012): Confirms the role of FOIA in ensuring ethical administration of public funds.
Demand:
CHRO must disclose all requested records to uphold transparency and ensure proper use of taxpayer funds.
Scope of Requested Records
To ensure comprehensive compliance, this appeal specifies the following record categories:
1. Communications
All internal and external communications (emails, memos, meeting notes) related to CHRO Case No. 2410220.
Correspondence involving key personnel, including Debra Morris, Kimberly D. Morris, Andrea Barton Reeves, Judge Dr. Cherron Payne, and Senators Blumenthal and Murphy.
2. Case Management Documentation
Logs, notes, and status updates tracking procedural steps in CHRO Case No. 2410220.
Internal policies and guidance documents applied in the case review and decision-making process.
3. Personnel Information (Non-Confidential)
Job descriptions, training certifications, and ADA compliance roles of personnel managing this case.
Organizational charts showing supervisory relationships and decision-making authority.
4. Financial and Compliance Records
Budgets, expenditures, and funding allocations related to the handling of this case.
Compliance reviews and audit findings addressing FOIA and ADA adherence.
5. Complaint Histories and Investigation Records
Whistleblower complaints and retaliation claims involving personnel managing this case.
Investigation outcomes and corrective measures applied to address procedural failures.
6. Document Drafts and Revisions
All versions, drafts, and revision histories of documents related to this case.
Accommodation Requests
To ensure equitable access, this appeal reiterates the following ADA accommodations:
ADA Accommodations Request
This request includes explicit ADA accommodations to address cognitive processing challenges resulting from my traumatic brain injury (TBI). These accommodations are legally required under Title II of the ADA (42 U.S.C. 12132) and Section 504 of the Rehabilitation Act (29 U.S.C. 794).
Requested ADA Accommodations
To ensure accessibility and compliance with ADA standards (42 U.S.C. 12101 et seq.), I request the following accommodations for all communications and records:
Screen-Reader Compatible Formats
All documents must be provided in properly labeled PDFs or plain-text files.
Ensure the documents are screen-reader compatible and retain clear formatting.
Exclusive MuckRock Platform Communication
All communications must occur via the MuckRock platform.
Do not send external links, emails, portals, passwords, codes, or require phone calls for access.
Text Embedded in Email Bodies
Key information must be embedded directly in the email body to facilitate comprehension.
Simplified Summaries
Provide plain-language summaries for complex or legal documents to ensure clarity.
Identification of Responsible Officers
Include the full name, title, and contact information of all responsible officers handling this request.
Non-Negotiable Compliance
These accommodations are non-negotiable and are essential for ensuring equal access to information. Any failure to provide the requested accommodations may constitute a violation of the ADA and the Rehabilitation Act. Thank you for ensuring compliance and accessibility in addressing this request.
Detailed Justifications for Redactions: Cite specific legal exemptions for all redactions and include summaries where applicable.
Required Actions
To resolve this appeal, CHRO must take the following steps:
Comprehensive Disclosure: Provide all requested records, organized by category, within 10 business days.
ADA Compliance Confirmation: Confirm receipt of this appeal and adherence to ADA accommodations in all future communications.
Detailed Justifications: For any withheld or redacted records, provide a detailed explanation citing applicable statutes.
Expedited Processing: Expedite processing due to the public interest in ADA compliance and whistleblower protections.
Consequences of Non-Compliance
If CHRO fails to comply with this appeal, I will pursue the following actions:
Administrative Complaints: File complaints with the Connecticut FOIC and federal ADA enforcement agencies.
Judicial Remedies: Initiate legal action to enforce my rights under FOIA and ADA statutes.
Public Advocacy: Engage oversight organizations, media, and advocacy groups to highlight systemic non-compliance.
Conclusion
This appeal serves as a final request for comprehensive disclosure and ADA-compliant processing. CHRO must fulfill its legal obligations to ensure transparency, accountability, and equitable access.
I expect a complete response addressing all aspects of this appeal within 10 business days.
Sincerely,
David Medeiros
Founder, ABI Resources
Email: AabiWR@live.com
cc:
Andrea Barton Reeves, DSS Commissioner
Senator Richard Blumenthal
Senator Chris Murphy
Governor Ned Lamont
Attorney General William Tong
U.S. Department of Justice Civil Rights Division
Connecticut FOIC
Office of Government Information Services (OGIS)
ADA Accommodations Request
This request includes explicit ADA accommodations to address cognitive processing challenges resulting from my traumatic brain injury (TBI). These accommodations are legally required under Title II of the ADA (42 U.S.C. 12132) and Section 504 of the Rehabilitation Act (29 U.S.C. 794).
Requested ADA Accommodations
To ensure accessibility and compliance with ADA standards (42 U.S.C. 12101 et seq.), I request the following accommodations for all communications and records:
Screen-Reader Compatible Formats
All documents must be provided in properly labeled PDFs or plain-text files.
Ensure the documents are screen-reader compatible and retain clear formatting.
Exclusive MuckRock Platform Communication
All communications must occur via the MuckRock platform.
Do not send external links, emails, portals, passwords, codes, or require phone calls for access.
Text Embedded in Email Bodies
Key information must be embedded directly in the email body to facilitate comprehension.
Simplified Summaries
Provide plain-language summaries for complex or legal documents to ensure clarity.
Identification of Responsible Officers
Include the full name, title, and contact information of all responsible officers handling this request.
Non-Negotiable Compliance
These accommodations are non-negotiable and are essential for ensuring equal access to information. Any failure to provide the requested accommodations may constitute a violation of the ADA and the Rehabilitation Act. Thank you for ensuring compliance and accessibility in addressing this request.
Sincerely,
David Medeiros
Founder, ABI Resources
CC: Congressional Oversight Committees, DOJ Civil Rights Division, OGIS, and relevant stakeholders.
Copies To:
Office of the Attorney General, Connecticut
Connecticut Department of Social Services
Centers for Medicare & Medicaid Services
Office of Government Information Services (OGIS)
CC: Oversight and Accountability Authorities
Robert F. Kennedy Jr.
Title: Secretary of Health and Human Services (HHS) (Nominated)
Email: kennedy.robert@hhs.gov
Office Address: U.S. Department of Health and Human Services, 200 Independence Avenue, SW, Washington, DC 20201
Phone: (877) 696-6775
Kash Patel
Title: Director of the Federal Bureau of Investigation (FBI) (Nominated)
Email: kash.patel@fbi.gov
Office Address: FBI Headquarters, 935 Pennsylvania Avenue, NW, Washington, DC 20535-0001
Phone: (202) 324-3000
Dr. Mehmet Oz
Title: Administrator of the Centers for Medicare & Medicaid Services (CMS) (Nominated)
Email: dr.oz@cms.hhs.gov
Office Address: Centers for Medicare & Medicaid Services, 7500 Security Boulevard, Baltimore, MD 21244
Phone: (800) 633-4227
Vivek Ramaswamy
Title: Co-Chair, Department of Government Efficiency (DOGE)
Email: vivek.ramaswamy@doge.gov
Office Address: Department of Government Efficiency, 1600 Pennsylvania Avenue NW, Washington, DC 20500
Phone: (202) 456-1414
Elon Musk
Title: Co-Chair, Department of Government Efficiency (DOGE)
Email: elon.musk@doge.gov
Office Address: Department of Government Efficiency, 1600 Pennsylvania Avenue NW, Washington, DC 20500
Phone: (202) 456-1414
State of Connecticut
Ned Lamont
Title: Governor of Connecticut
Phone: (860) 566-4840
Email: governor.lamont@ct.gov
William Tong
Title: Attorney General of Connecticut
Phone: (860) 808-5318
Email: attorney.general@ct.gov
Andrea Barton Reeves
Title: Commissioner, Connecticut Department of Social Services (DSS)
Phone: (860) 424-5053
Email: andrea.bartonreeves@ct.gov
Connecticut Freedom of Information Commission (FOIC)
Phone: (860) 566-5682
Email: foi@ct.gov
Matthew S. Antonetti
Title: Legal Director, Connecticut Department of Social Services
Phone: (860) 424-5386
Email: matthew.antonetti@ct.gov
U.S. Department of Health and Human Services (HHS)
Xavier Becerra
Title: Secretary, U.S. Department of Health and Human Services
Phone: (202) 690-7000
Email: HHS_FOIA@hhs.gov
Chiquita Brooks-LaSure
Title: Administrator, Centers for Medicare & Medicaid Services (CMS)
Phone: (410) 786-3000
Email: FOIA_Request@cms.hhs.gov
Lisa Pino
Title: Director, Office for Civil Rights (OCR), HHS
Phone: (800) 368-1019
Email: ocrmail@hhs.gov
Emmett Nicholson
Title: Senior Medicaid Compliance Official, Centers for Medicare & Medicaid Services (CMS)
Phone: (410) 786-7623
Email: emmett.nicholson@cms.hhs.gov
Michelle A. James
Title: Medicaid Oversight Official, CMS
Phone: (410) 786-3033
Email: michelle.james@cms.hhs.gov
U.S. Department of Justice (DOJ)
Merrick B. Garland
Title: Attorney General, U.S. Department of Justice
Phone: (202) 514-2000
Email: doj.oag@usdoj.gov
Kristen Clarke
Title: Assistant Attorney General, Civil Rights Division
Phone: (202) 514-4609
Email: civilrights.justice@usdoj.gov
Michael E. Horowitz
Title: Inspector General, DOJ Office of Inspector General
Phone: (202) 514-3435
Email: oig.hotline@usdoj.gov
Priscilla Jones
Title: Supervisory Administrative Specialist, Office of Information Policy (OIP)
Phone: (202) 514-3642
Email: oip.foia@usdoj.gov
Michael G. Seidel
Title: Section Chief, Record/Information Dissemination Section, FBI
Phone: (202) 324-3000
Email: foipaquestions@fbi.gov
Alina M. Semo
Title: Director, Office of Government Information Services (OGIS), National Archives and Records Administration (NARA)
Phone: (202) 741-5770 | Toll-Free: 1-877-684-6448
Email: ogis@nara.gov
Congressional Oversight Committees
James Comer
Title: Chair, House Committee on Oversight and Accountability
Phone: (202) 225-5074
Email: oversightpress@mail.house.gov
Gary Peters
Title: Chair, Senate Committee on Homeland Security and Governmental Affairs
Phone: (202) 224-2627
Email: committee@hsgac.senate.gov
Jamie Raskin
Title: Chair, House Subcommittee on Civil Rights and Civil Liberties
Phone: (202) 225-5341
Email: civilrights@mail.house.gov
Dick Durbin
Title: Chair, Senate Judiciary Committee
Phone: (202) 224-2152
Email: judiciary@senate.gov
Rosa DeLauro
Title: Ranking Member, House Appropriations Committee
Phone: (202) 225-3661
Email: appropriations@mail.house.gov
Bernie Sanders
Title: Chair, Senate Health, Education, Labor, and Pensions Committee
Phone: (202) 224-5141
Email: helpcommittee@senate.gov
Catherine Lhamon
Title: Chair, U.S. Commission on Civil Rights
Phone: (202) 376-7533
Email: contact@usccr.gov
Richard Blumenthal
Title: Senator, Connecticut
Phone: (202) 224-2823
Email: blumenthal@senate.gov
Chris Murphy
Title: Senator, Connecticut
Phone: (202) 224-4041
Email: murphy@senate.gov
Sincerely,
David Medeiros
Founder, ABI Resources
DB.42.131.Inf. https://www.ctbraininjury.com/blog/tags/db-42-131-inf
https://x.com/ABIresources/status/1866212331279339765 https://www.youtube.com/@ABI.RESOURCES-CT-ABI-MFP-CARE/videos?view=0&sort=dd&shelf_id=2
Reference: OPM ID # 24-85 A-2025-00307 FCC-FOIA-2025-000358-A FIC 2024-0683 R000748-102524 2025-F-01035 R000354-102024 R000737-102024 AD2414036 A-2025-00351 2025-00027-A-PHS A-2025-00395 2025-00434-FOIA-OS A-2025-00393 OPM ID # 24-83 A-2025-00393 2025-00446-FOIA-PHS A-2025-00399 A-2025-00392 25-00142-FOIA PRI-25-023 2025-00032-A-PHS 110620247022 24-86 AD2414644 R000770-110424 2025-F-01651 A-2025-00467 A-2025-00401 2025-00481-FOIA-PHS 112020247009 112020247039 2025-00024-A-OS A-2025-00420 25-00044-F A-2025-00069 A-2025-00469 OPM ID# 24-88 & 89 2025-00638-FOIA-OS AP-2025-001FOIA-2025-00562FOIA-2025-00563 EMRUFOIA111524 F-2025-03523 2025-00574-FOIA-PHS 145-FOI-21320 OPM ID #24-94 25-OIG-177 FOIA-2025-01054FOIA-2025-01052 EMRUFOIA120324-7 FOIA-2025-01053 OPM ID #24-95 FOIA-2025-01056 EMRUFOIA120324-7 FOIA-2025-01055FOIA-2025-01057 R005487-120324 2025-01079-FOIA-PHS 2025-01078-FOIA-PHS FOIA-2025-056 PRI-25-045 FOIA-2025-01060FOIA-2025-01059FOIA-2025-060FOIA-2025-01203 EMRUFOIA121324 #FOIA-2025-063 11034 539330-JBZ, 539298-RJM, 534659-XGL, 534094-QZH, 534069-BRQ, 534060-HWM, 533252-GXC, 535276-FSL, 532832-MJV, 532674-QMM, 532671-PPV, 532667-DRF, 523966-VSF, 497211-PFB, 490797-TJJ, 489456-MCB, 490814-TPF, 490215-DKH, 478957-DPX, 478956-NSD, 473045-JNW, 452335-DDT, 413343-FZP, 405540-ZXW, 397760-PRZ, 395050-TWW, 392179-NCW, 385105-BPN, 376153-JVL, 357494-WND, 354718-LTZ, 275528-PKR, 301882-TRG, 327008-WFC, 339860-FQG, 352533-WJH.6779 7959 17303 17304 3033 5282 14733 6577 10 10527 3519 28368 8560 63 3814 4923 4126 6612 4809 4850 35673 74 239 4850 3519 166 10661 14578 239 3033 4923 166 4850 6779 14733 3519 166 4850 10661 14578 3033 4923 166 6779 4850 166 3519 152 4121 10661 74 3033 239 5282 4850 14733 4923 4850 6612 4923 10672 63 6959 115 35673 10661 239 74 6779 3033 239 4923 166 3519 3033 14578 35673 166 4297 14 3519 5123 287 35673 14 59 3519 287 14733 4809 23077 4923 74 4735 4850 2667 3519 796 59 166 856 22238 35673 14 10835 3033 239 4297 3519 14733 796 3519 856 35673 22005 5123 59 4923 3033 239 14733 166 4297 3519 35673 5123 59 3124 14578 7683 74 10661 3033 239 7982 14587 2667 4121 287 129 11109 856 3519 59 2667 35673 22238 2667 11034: Commission on Fiscal Stability and Economic Growth 6779: Connecticut Commission on Human Rights and Opportunities 7959: Senate Office of Public Records 17303: Republican State Central Committee Of Connecticut 17304: Connecticut House Of Representatives 3033: Centers for Medicare and Medicaid Services 5282: Office of the State Comptroller 14733: Office Of Policy And Management 6577: Office of State Ethics 10: Federal Bureau of Investigation 10527: Federal Communications Commission Office of the Inspector General 3519: Department of Justice, Civil Rights Division 28368: Department Of Labor 8560: Department of Public Health - Medical Examining Board 63: Department of Labor 3814: Department of Consumer Protection 4923: Department of Social Services 4126: Department of Economic and Community Development 6612: Department of Public Health 4809: Office of the Governor 4850: Office of the Attorney General - Connecticut 35673: Department Of Justice 74: Department of Health and Human Services 239: Department of Health and Human Services, Centers for Medicare & Medicaid Services 166: Department of Justice, Disability Rights Division 10661: Department of Health and Human Services Office of Inspector General 14578: Department Of Health And Human Services, Office For Civil Rights 152: Centers for Disease Control and Prevention 4121: Government Accountability Office 10672: Department of Labor, Wage and Hour Division 6959: Department of Justice, Office of Justice Programs 115: Department of Justice, Criminal Division 4297: Department of Justice, Civil Division 14: U.S. Department of State 5123: Director, Office of Information Policy 287: Office of Government Information Services 59: Department of Justice, Office of Information Policy 23077: CT Freedom Of Information Agency 4735: Department of State, Office of the Inspector General 2667: Office of Special Counsel 796: Department of Justice, Office of the Inspector General 856: Department of Justice, Office of the Attorney General 22238: U.S. Department Of Justice 10835: Department of Health and Human Services 22005: Department Of Justice Office Of Administration 3124: Department of Health 7683: U.S. Department of Health and Human Services, Health Resources and Services Administration 7982: Office of Special Counsel, Office of General Counsel [APPEALS] 14587: Office Of The Special Counsel Of Robert Mueller 129: National Archives and Records Administration 11109: Office of the Attorney General for the District of Columbia OPM FCC FIC DOJ DOL DSS CMS HHS CDC GAO OSC OIG PHS DPH DOT DOGE Department of Government Efficiency CHRO FOIA FOIC DI-25-000310DI-25-000325DI-25-000379
DI-12192024714 DI-12112024134 FBI
Hi Mr. Medeiros,
Per your FOI request please find attached copies of emails from both Dr. Cherrone Payne and Kimberly Morris. In speaking with Dedra Morris, she states that any emails sent from you were placed in your current file(s). If you have any questions or need any additional assistance, please feel free to contact me.
Sincerely,
[Logo Description automatically generated]
www.ct.gov/chro<http://www.ct.gov/chro>
[See the source image]<https://www.facebook.com/CTCHRO/>[See the source image]<https://www.instagram.com/ct_chro/> [Logo Description automatically generated] <https://www.youtube.com/channel/UCn9tiERvIeZqtxGd1i1xKiw>
Charles E. Perry
Paralegal Specialist/FOI Officer
Legal Division
Commission on Human Rights and Opportunities
450 Columbus Boulevard, Suite 2
Hartford, CT 06103
P: 860-541-3438 | F: 860-241-4869
Charles.Perry@CT.Gov<http://www.ct.gov/chro>
[Share image]
Perry, Charles shared a folder with you
Hi Mr. Medeiros,
I am again forwarding you a copy of your complaint file above. If you have any questions or need any additional assistance, please feel free to contact me.
Sincerely,
Charles Perry
<https://ctgovexec.sharepoint.com/:f:/s/CHROCHRO/Emy73-Eeqb9OlfOME5I1880Bh-FbR0_DTWKDwTNkvzV6gw?e=5%3AL3r0m5>
[icon] 2410220 David Medeiros v. Department of Social Services
[permission globe icon] This link only works for the direct recipients of this message.
Open <https://ctgovexec.sharepoint.com/:f:/s/CHROCHRO/Emy73-Eeqb9OlfOME5I1880Bh-FbR0_DTWKDwTNkvzV6gw?e=5%3AL3r0m5>
[cid:97b65221-749a-4a45-97ee-858d809f485c]
This email is generated through State of Connecticut's use of Microsoft 365 and may contain content that is controlled by State of Connecticut.
Summary of Escalated FOIA Complaint and Appeal
On January 3, 2025, David Medeiros submitted a formal complaint and appeal to the Connecticut Commission on Human Rights and Opportunities (CHRO) regarding its failure to comply with FOIA, ADA, and Section 504 of the Rehabilitation Act obligations. The appeal highlights CHROs lack of comprehensive, ADA-compliant disclosures in response to a FOIA request for records related to CHRO Case No. 2410220.
Key Issues Identified:
FOIA Violations:
CHRO failed to provide complete records, including internal communications, personnel documentation, and compliance records, violating Connecticut FOIA statutes.
No sufficient legal justifications were provided for withheld or redacted records.
ADA Non-Compliance:
CHRO ignored accommodation requests for screen-reader-compatible formats, plain-text summaries, and communication through the MuckRock platform, creating barriers for individuals with disabilities.
Procedural Failures:
CHRO continues to use inaccessible external portals and improperly formatted documents despite explicit instructions, violating accessibility standards.
Demands for Immediate Action:
Full Disclosure: Release all requested records, including internal communications, case management logs, personnel information, and financial and compliance documentation.
ADA Compliance: Reissue past communications in accessible formats and commit to ADA-compliant practices for future responses.
Accountability: Provide statutory justifications for redactions or denials and identify personnel responsible for handling the request.
Escalation Plan: If CHRO fails to comply within 10 business days, Medeiros will escalate by filing administrative complaints with the Connecticut FOIC and DOJ Civil Rights Division, pursuing legal action, and notifying state and federal officials, including Senators Blumenthal and Murphy, Governor Lamont, and media outlets.
This complaint underscores the urgency of ensuring transparency, accessibility, and accountability in government operations. CHROs compliance is critical to maintaining public trust and safeguarding the rights of individuals with disabilities.
Escalated FOIA Complaint and Appeal
Date: January 3, 2025
01.03.2025
To: Connecticut Commission on Human Rights and Opportunities (CHRO), FOIA Officers, and Relevant State Authorities
Introduction
This document serves as a formal complaint and appeal under the Connecticut Freedom of Information Act (C.G.S. 1-200 to 1-242), the Americans with Disabilities Act (42 U.S.C. 12101 et seq.), and Section 504 of the Rehabilitation Act (29 U.S.C. 794). It addresses the failure of CHRO to provide comprehensive, ADA-compliant disclosures following my Freedom of Information request for records related to CHRO Case No. 2410220.
Key Issues and Legal Violations
Non-Compliance with FOIA Deadlines and Disclosure Requirements
Statutory Requirement: Under C.G.S. 1-210(a), agencies must provide prompt access to public records or a legally sufficient response within four business days.
Violation: CHROs responses omit critical records, including complete internal correspondence, personnel documentation, and ADA compliance records.
Relevant Precedent:
Conn. FOIC v. Dept. of Public Health, 228 Conn. 158 (1994): FOIA demands full and prompt disclosure to ensure transparency.
Demand: CHRO must immediately disclose all records specified in the original request or provide detailed legal justifications for any withheld records.
Failure to Provide ADA-Compliant Accommodations
Legal Obligation: The ADA (42 U.S.C. 12132) mandates equitable access to public services and accommodations for individuals with disabilities.
Violation: CHRO failed to meet ADA accommodation requests, including:
Screen-reader-compatible document formats.
Text embedded in email bodies.
Use of the MuckRock platform for all communications.
Relevant Precedent:
Tennessee v. Lane, 541 U.S. 509 (2004): Public entities must ensure accessibility to their programs.
Demand: CHRO must confirm compliance with all ADA accommodations in future responses and reissue past communications in accessible formats.
Procedural Failures in Communication
Violation: Despite explicit instructions, CHRO continues to send external portal links and improperly formatted documents, creating accessibility barriers.
Relevant Precedent:
Alexander v. Choate, 469 U.S. 287 (1985): Denial of accommodations is unlawful discrimination.
Demand: CHRO must cease using external portals and adhere to specified communication methods, including plain-text summaries for complex records.
Demands for Immediate Action
Comprehensive Record Disclosure
CHRO must provide the following:
Internal and external communications, including emails, memos, and meeting notes.
Personnel information, including job descriptions and ADA compliance roles of involved staff.
Case management documentation, including logs, notes, and decisions made.
Financial and compliance records related to CHRO Case No. 2410220.
All document drafts, revisions, and guidance used in handling this case.
ADA Accommodation Compliance
Reissue past communications in screen-reader-compatible PDF formats with embedded text.
Confirm compliance with MuckRock platform-exclusive communication and eliminate external portals or file-sharing links.
Detailed Justifications for Redactions or Denials
Provide specific statutory citations for each redaction or denial.
Include plain-language summaries for withheld records where appropriate.
Identification of Responsible Officers
Provide the full name, title, and contact information for all FOIA officers and decision-makers handling this request.
Escalation Path
If CHRO fails to comply within 10 business days, I will escalate this matter by:
Administrative Complaints:
Filing with the Connecticut Freedom of Information Commission (FOIC).
Reporting ADA violations to the U.S. Department of Justice Civil Rights Division.
Judicial Action:
Pursuing legal remedies under FOIA and ADA statutes to enforce compliance and ensure accountability.
Congressional Oversight and Media Advocacy:
Notifying state and federal oversight authorities, including Senators Blumenthal and Murphy, Governor Lamont, and media outlets, to highlight systemic failures.
Conclusion
This appeal is a final demand for full compliance with FOIA, ADA, and Rehabilitation Act obligations. CHROs failure to act transparently undermines public trust and accountability.
Action Required:
Confirm receipt of this appeal within 3 business days.
Provide a timeline for compliance and a comprehensive response within 10 business days.
Failure to meet these demands will trigger immediate escalation as outlined above.
Sincerely,
David Medeiros
Founder, ABI Resources
ADA Accommodations Request
This request includes explicit ADA accommodations to address cognitive processing challenges resulting from my traumatic brain injury (TBI). These accommodations are legally required under Title II of the ADA (42 U.S.C. 12132) and Section 504 of the Rehabilitation Act (29 U.S.C. 794).
Requested ADA Accommodations
To ensure accessibility and compliance with ADA standards (42 U.S.C. 12101 et seq.), I request the following accommodations for all communications and records:
Screen-Reader Compatible Formats
All documents must be provided in properly labeled PDFs or plain-text files.
Ensure the documents are screen-reader compatible and retain clear formatting.
Exclusive MuckRock Platform Communication
All communications must occur via the MuckRock platform.
Do not send external links, emails, portals, passwords, codes, or require phone calls for access.
Text Embedded in Email Bodies
Key information must be embedded directly in the email body to facilitate comprehension.
Simplified Summaries
Provide plain-language summaries for complex or legal documents to ensure clarity.
Identification of Responsible Officers
Include the full name, title, and contact information of all responsible officers handling this request.
Non-Negotiable Compliance
These accommodations are non-negotiable and are essential for ensuring equal access to information. Any failure to provide the requested accommodations may constitute a violation of the ADA and the Rehabilitation Act. Thank you for ensuring compliance and accessibility in addressing this request.
CC:
Andrea Barton Reeves, DSS Commissioner
Governor Ned Lamont
Attorney General William Tong
Senator Richard Blumenthal
Senator Chris Murphy
U.S. Department of Justice Civil Rights Division
Connecticut Freedom of Information Commission (FOIC)
Office of Government Information Services (OGIS)
CC List
Federal Oversight
Merrick Garland, U.S. Attorney General
Kristen Clarke, Assistant Attorney General, Civil Rights Division
Michael E. Horowitz, Inspector General, DOJ
Gene L. Dodaro, Comptroller General, GAO
Congressional Committees
House Committee on Oversight and Accountability
Senate Committee on Homeland Security and Governmental Affairs
Senate Judiciary Committee
Advocacy Organizations
Office of Government Information Services (OGIS)
Transparency and Civil Rights Watchdogs
CC:
William Tong, Attorney General of Connecticut
Andrea Barton Reeves, Commissioner, DSS
Alina M. Semo, Director, OGIS
Aundra Luckey, Chief, FOIA/PA Branch, DOJ
CMS and OCR Leadership
CC: Congressional Oversight Committees, DOJ Civil Rights Division, OGIS, and relevant stakeholders.
Copies To:
Office of the Attorney General, Connecticut
Connecticut Department of Social Services
Centers for Medicare & Medicaid Services
Office of Government Information Services (OGIS)
CC: Oversight and Accountability Authorities
Robert F. Kennedy Jr.
Title: Secretary of Health and Human Services (HHS) (Nominated)
Email: kennedy.robert@hhs.gov
Office Address: U.S. Department of Health and Human Services, 200 Independence Avenue, SW, Washington, DC 20201
Phone: (877) 696-6775
Kash Patel
Title: Director of the Federal Bureau of Investigation (FBI) (Nominated)
Email: kash.patel@fbi.gov
Office Address: FBI Headquarters, 935 Pennsylvania Avenue, NW, Washington, DC 20535-0001
Phone: (202) 324-3000
Dr. Mehmet Oz
Title: Administrator of the Centers for Medicare & Medicaid Services (CMS) (Nominated)
Email: dr.oz@cms.hhs.gov
Office Address: Centers for Medicare & Medicaid Services, 7500 Security Boulevard, Baltimore, MD 21244
Phone: (800) 633-4227
Vivek Ramaswamy
Title: Co-Chair, Department of Government Efficiency (DOGE)
Email: vivek.ramaswamy@doge.gov
Office Address: Department of Government Efficiency, 1600 Pennsylvania Avenue NW, Washington, DC 20500
Phone: (202) 456-1414
Elon Musk
Title: Co-Chair, Department of Government Efficiency (DOGE)
Email: elon.musk@doge.gov
Office Address: Department of Government Efficiency, 1600 Pennsylvania Avenue NW, Washington, DC 20500
Phone: (202) 456-1414
State of Connecticut
Ned Lamont
Title: Governor of Connecticut
Phone: (860) 566-4840
Email: governor.lamont@ct.gov
William Tong
Title: Attorney General of Connecticut
Phone: (860) 808-5318
Email: attorney.general@ct.gov
Andrea Barton Reeves
Title: Commissioner, Connecticut Department of Social Services (DSS)
Phone: (860) 424-5053
Email: andrea.bartonreeves@ct.gov
Connecticut Freedom of Information Commission (FOIC)
Phone: (860) 566-5682
Email: foi@ct.gov
Matthew S. Antonetti
Title: Legal Director, Connecticut Department of Social Services
Phone: (860) 424-5386
Email: matthew.antonetti@ct.gov
U.S. Department of Health and Human Services (HHS)
Xavier Becerra
Title: Secretary, U.S. Department of Health and Human Services
Phone: (202) 690-7000
Email: HHS_FOIA@hhs.gov
Chiquita Brooks-LaSure
Title: Administrator, Centers for Medicare & Medicaid Services (CMS)
Phone: (410) 786-3000
Email: FOIA_Request@cms.hhs.gov
Lisa Pino
Title: Director, Office for Civil Rights (OCR), HHS
Phone: (800) 368-1019
Email: ocrmail@hhs.gov
Emmett Nicholson
Title: Senior Medicaid Compliance Official, Centers for Medicare & Medicaid Services (CMS)
Phone: (410) 786-7623
Email: emmett.nicholson@cms.hhs.gov
Michelle A. James
Title: Medicaid Oversight Official, CMS
Phone: (410) 786-3033
Email: michelle.james@cms.hhs.gov
U.S. Department of Justice (DOJ)
Merrick B. Garland
Title: Attorney General, U.S. Department of Justice
Phone: (202) 514-2000
Email: doj.oag@usdoj.gov
Kristen Clarke
Title: Assistant Attorney General, Civil Rights Division
Phone: (202) 514-4609
Email: civilrights.justice@usdoj.gov
Michael E. Horowitz
Title: Inspector General, DOJ Office of Inspector General
Phone: (202) 514-3435
Email: oig.hotline@usdoj.gov
Priscilla Jones
Title: Supervisory Administrative Specialist, Office of Information Policy (OIP)
Phone: (202) 514-3642
Email: oip.foia@usdoj.gov
Michael G. Seidel
Title: Section Chief, Record/Information Dissemination Section, FBI
Phone: (202) 324-3000
Email: foipaquestions@fbi.gov
Alina M. Semo
Title: Director, Office of Government Information Services (OGIS), National Archives and Records Administration (NARA)
Phone: (202) 741-5770 | Toll-Free: 1-877-684-6448
Email: ogis@nara.gov
Congressional Oversight Committees
James Comer
Title: Chair, House Committee on Oversight and Accountability
Phone: (202) 225-5074
Email: oversightpress@mail.house.gov
Gary Peters
Title: Chair, Senate Committee on Homeland Security and Governmental Affairs
Phone: (202) 224-2627
Email: committee@hsgac.senate.gov
Jamie Raskin
Title: Chair, House Subcommittee on Civil Rights and Civil Liberties
Phone: (202) 225-5341
Email: civilrights@mail.house.gov
Dick Durbin
Title: Chair, Senate Judiciary Committee
Phone: (202) 224-2152
Email: judiciary@senate.gov
Rosa DeLauro
Title: Ranking Member, House Appropriations Committee
Phone: (202) 225-3661
Email: appropriations@mail.house.gov
Bernie Sanders
Title: Chair, Senate Health, Education, Labor, and Pensions Committee
Phone: (202) 224-5141
Email: helpcommittee@senate.gov
Catherine Lhamon
Title: Chair, U.S. Commission on Civil Rights
Phone: (202) 376-7533
Email: contact@usccr.gov
Richard Blumenthal
Title: Senator, Connecticut
Phone: (202) 224-2823
Email: blumenthal@senate.gov
Chris Murphy
Title: Senator, Connecticut
Phone: (202) 224-4041
Email: murphy@senate.gov
Sincerely,
David Medeiros
Founder, ABI Resources
DB.42.131.Inf. https://www.ctbraininjury.com/blog/tags/db-42-131-inf
https://x.com/ABIresources/status/1866212331279339765 https://www.youtube.com/@ABI.RESOURCES-CT-ABI-MFP-CARE/videos?view=0&sort=dd&shelf_id=2
Reference: OPM ID # 24-85 A-2025-00307 FCC-FOIA-2025-000358-A FIC 2024-0683 R000748-102524 2025-F-01035 R000354-102024 R000737-102024 AD2414036 A-2025-00351 2025-00027-A-PHS A-2025-00395 2025-00434-FOIA-OS A-2025-00393 OPM ID # 24-83 A-2025-00393 2025-00446-FOIA-PHS A-2025-00399 A-2025-00392 25-00142-FOIA PRI-25-023 2025-00032-A-PHS 110620247022 24-86 AD2414644 R000770-110424 2025-F-01651 A-2025-00467 A-2025-00401 2025-00481-FOIA-PHS 112020247009 112020247039 2025-00024-A-OS A-2025-00420 25-00044-F A-2025-00069 A-2025-00469 OPM ID# 24-88 & 89 2025-00638-FOIA-OS AP-2025-001FOIA-2025-00562FOIA-2025-00563 EMRUFOIA111524 F-2025-03523 2025-00574-FOIA-PHS 145-FOI-21320 OPM ID #24-94 25-OIG-177 FOIA-2025-01054FOIA-2025-01052 EMRUFOIA120324-7 FOIA-2025-01053 OPM ID #24-95 FOIA-2025-01056 EMRUFOIA120324-7 FOIA-2025-01055FOIA-2025-01057 R005487-120324 2025-01079-FOIA-PHS 2025-01078-FOIA-PHS FOIA-2025-056 PRI-25-045 FOIA-2025-01060FOIA-2025-01059FOIA-2025-060FOIA-2025-01203 EMRUFOIA121324 #FOIA-2025-063 11034 539330-JBZ, 539298-RJM, 534659-XGL, 534094-QZH, 534069-BRQ, 534060-HWM, 533252-GXC, 535276-FSL, 532832-MJV, 532674-QMM, 532671-PPV, 532667-DRF, 523966-VSF, 497211-PFB, 490797-TJJ, 489456-MCB, 490814-TPF, 490215-DKH, 478957-DPX, 478956-NSD, 473045-JNW, 452335-DDT, 413343-FZP, 405540-ZXW, 397760-PRZ, 395050-TWW, 392179-NCW, 385105-BPN, 376153-JVL, 357494-WND, 354718-LTZ, 275528-PKR, 301882-TRG, 327008-WFC, 339860-FQG, 352533-WJH.6779 7959 17303 17304 3033 5282 14733 6577 10 10527 3519 28368 8560 63 3814 4923 4126 6612 4809 4850 35673 74 239 4850 3519 166 10661 14578 239 3033 4923 166 4850 6779 14733 3519 166 4850 10661 14578 3033 4923 166 6779 4850 166 3519 152 4121 10661 74 3033 239 5282 4850 14733 4923 4850 6612 4923 10672 63 6959 115 35673 10661 239 74 6779 3033 239 4923 166 3519 3033 14578 35673 166 4297 14 3519 5123 287 35673 14 59 3519 287 14733 4809 23077 4923 74 4735 4850 2667 3519 796 59 166 856 22238 35673 14 10835 3033 239 4297 3519 14733 796 3519 856 35673 22005 5123 59 4923 3033 239 14733 166 4297 3519 35673 5123 59 3124 14578 7683 74 10661 3033 239 7982 14587 2667 4121 287 129 11109 856 3519 59 2667 35673 22238 2667 11034: Commission on Fiscal Stability and Economic Growth 6779: Connecticut Commission on Human Rights and Opportunities 7959: Senate Office of Public Records 17303: Republican State Central Committee Of Connecticut 17304: Connecticut House Of Representatives 3033: Centers for Medicare and Medicaid Services 5282: Office of the State Comptroller 14733: Office Of Policy And Management 6577: Office of State Ethics 10: Federal Bureau of Investigation 10527: Federal Communications Commission Office of the Inspector General 3519: Department of Justice, Civil Rights Division 28368: Department Of Labor 8560: Department of Public Health - Medical Examining Board 63: Department of Labor 3814: Department of Consumer Protection 4923: Department of Social Services 4126: Department of Economic and Community Development 6612: Department of Public Health 4809: Office of the Governor 4850: Office of the Attorney General - Connecticut 35673: Department Of Justice 74: Department of Health and Human Services 239: Department of Health and Human Services, Centers for Medicare & Medicaid Services 166: Department of Justice, Disability Rights Division 10661: Department of Health and Human Services Office of Inspector General 14578: Department Of Health And Human Services, Office For Civil Rights 152: Centers for Disease Control and Prevention 4121: Government Accountability Office 10672: Department of Labor, Wage and Hour Division 6959: Department of Justice, Office of Justice Programs 115: Department of Justice, Criminal Division 4297: Department of Justice, Civil Division 14: U.S. Department of State 5123: Director, Office of Information Policy 287: Office of Government Information Services 59: Department of Justice, Office of Information Policy 23077: CT Freedom Of Information Agency 4735: Department of State, Office of the Inspector General 2667: Office of Special Counsel 796: Department of Justice, Office of the Inspector General 856: Department of Justice, Office of the Attorney General 22238: U.S. Department Of Justice 10835: Department of Health and Human Services 22005: Department Of Justice Office Of Administration 3124: Department of Health 7683: U.S. Department of Health and Human Services, Health Resources and Services Administration 7982: Office of Special Counsel, Office of General Counsel [APPEALS] 14587: Office Of The Special Counsel Of Robert Mueller 129: National Archives and Records Administration 11109: Office of the Attorney General for the District of Columbia OPM FCC FIC DOJ DOL DSS CMS HHS CDC GAO OSC OIG PHS DPH DOT DOGE Department of Government Efficiency CHRO FOIA FOIC DI-25-000310DI-25-000325DI-25-000379
DI-12192024714 DI-12112024134 FBI
Hello,
For security purposes, you must enter the code below to verify your account to access 2410220 David Medeiros v. Department of Social Services. The code will only work for 15 minutes and if you request a new code, this code will stop working.
Account verification code:
42298857
Having problems with the code?
View the error and make sure that the email identifier is "G966MBD". If it's not, look for an updated email or try requesting a new code.
PrivacyStatement (https://go.microsoft.com/fwlink/?LinkId=521839)
This email is generated through State of Connecticut's use of Microsoft 365.
Lossless ZIP download: extract the original PDF after download. The PDF bytes are unchanged. ZIP 22220061 bytes; ZIP SHA-256: 523dd9f39705ff13b55582ac7ca046affa84e236532cf43de31f0e2666138b4b. Its fixed container timestamp is packaging metadata, not the document date.
