FOIA request 176759 to Director, Office of Information Policy

Numbers extracted from this saved text (not independently verified case identifiers): 000358, 102024, 102524, 110424, 110620247022, 112020247009, 112020247039, 120324, 12112024134, 12192024714, 25-00044, 25-00142-FOIA, 275528, 301882, 327008, 339860, 352533, 354718, 357494, 376153, 385105, 392179, 395050, 397760, 405540, 413343, 452335, 473045, 478956, 478957, 489456, 490215, 490797, 490814, 497211, 523966, 532667, 532671, 532674, 532832

To Whom It May Concern:

Pursuant to the Freedom of Information Act, I hereby request the following records:

Subject: Freedom of Information Act Request: DOJ Complaints 534659-XGL and 539298-RJM, ADA Compliance, and Related Correspondence
Date: November 22, 2024

To Whom It May Concern,

Pursuant to the Freedom of Information Act (5 U.S.C.  552), I am requesting access to records related to the following:

DOJ Complaint Numbers:

534659-XGL
539298-RJM
ADA Accommodation Requests:
All records and communications regarding the Americans with Disabilities Act (ADA) and Rehabilitation Act compliance associated with the above complaints.

FOIA and ADA Compliance:

Correspondence, internal memoranda, and decision-making records related to the FOIA and ADA compliance processes for these cases.
Acknowledgment letters, emails, or other communications from agency personnel involved in responding to these FOIA and ADA-related matters.
State and Federal Coordination:

Any interagency communications between the Department of Justice (DOJ), Connecticut Office of Policy and Management (OPM), Connecticut Department of Social Services (DSS), and related federal entities (e.g., CMS).
Detailed Records Requested:

All records, reports, emails, and internal communications associated with Complaint Nos. 534659-XGL and 539298-RJM.
Names, titles, and contact information of personnel responsible for addressing these complaints.
Statutory justifications for any redactions or withheld records.
Requested ADA Accommodations (Non-Negotiable):
MuckRock Platform Only:
All responses must be delivered exclusively through MuckRock. Portal logins, phone calls, physical mail, or external links are not acceptable.

Accessible Formats:

All response text must be embedded directly into the email body for accessibility.
PDF attachments must be screen-reader compatible, properly formatted, and clearly labeled.
Summarized Complex Records:
Summarize lengthy or technical records for ease of comprehension.

Identification of Responsible Personnel:
Each response must identify all FOIA officers, ADA coordinators, and supervisory personnel involved.

Statutory Justifications:
Provide detailed statutory justifications for all redactions or denials in compliance with 5 U.S.C.  552(b).

Expedited Processing:
Process this request expeditiously due to the public interest and the critical personal impact of the requested information.

Fee Waiver Request:
This request qualifies for a fee waiver under 5 U.S.C.  552(a)(4)(A)(iii), as it is in the public interest and not for commercial use.


Primary DOJ Contacts
U.S. Department of Justice  Office of Information Policy (OIP)

Name: Sean R. ONeill, Director
Email: oip.foia@usdoj.gov
Address:
Office of Information Policy
U.S. Department of Justice
441 G Street NW
Washington, DC 20530-0001
U.S. Department of Justice  Civil Rights Division

Name: Kristen Clarke, Assistant Attorney General for Civil Rights
Email: civilrights.justice@usdoj.gov
Address:
Civil Rights Division
U.S. Department of Justice
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
U.S. Department of Justice  Office of the Inspector General (OIG)

Name: Michael E. Horowitz, Inspector General
Email: oig.hotline@usdoj.gov
Address:
Office of the Inspector General
U.S. Department of Justice
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
State Agencies
Connecticut Office of Policy and Management (OPM)

Name: Jeffrey Beckham, Secretary
Email: opm.foia@ct.gov
Connecticut Department of Social Services (DSS)

Name: Dr. Deidre S. Gifford, Commissioner
Email: foia.dss@ct.gov
Connecticut Office of the Attorney General

Name: William Tong, Attorney General
Email: attorney.general@ct.gov
Federal Agencies
Centers for Medicare & Medicaid Services (CMS)

Name: Chiquita Brooks-LaSure, Administrator
Email: FOIA_Request@cms.hhs.gov
Federal Trade Commission (FTC)

Name: Lina M. Khan, Chair
Email: FOIA@ftc.gov
U.S. Department of Labor (DOL)

Name: Julie Su, Acting Secretary
Email: foiarequests@dol.gov
Escalation Notice
Failure to comply with this FOIA request or provide legally required ADA accommodations will result in escalation to oversight bodies, including federal courts, advocacy organizations, and relevant oversight offices.

Thank you for your prompt attention to this matter.

Sincerely,
David Medeiros
Founder, ABI Resources

DB.42.131.Inf.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

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 20 business days, as the statute requires.

Sincerely,

DAVID MEDEIROS

To Whom It May Concern:

I wanted to follow up on the following Freedom of Information Act request, copied below, and originally submitted on Dec. 3, 2024. Please let me know when I can expect to receive a response.

Thanks for your help, and let me know if further clarification is needed.

On January 2, 2025, David Medeiros, founder of ABI Resources, submitted a legal complaint and appeal to the DOJ and relevant federal and state officials regarding severe breaches of the Freedom of Information Act (FOIA), the Americans with Disabilities Act (ADA), whistleblower protections, and constitutional rights. Despite filing FOIA requests in November 2024 regarding DOJ complaints tied to ADA compliance, the agencies failed to meet legal deadlines, provide accessible documents, or accommodate his disability. The violations include withholding records without justification, neglecting ADA accessibility requirements, and raising concerns of whistleblower retaliation. Medeiros demands immediate corrective action, including unredacted records, ADA-compliant formats, exclusive use of accessible communication platforms, and audits of compliance practices. If unaddressed, he plans to escalate through administrative complaints, litigation, and public advocacy to ensure accountability and transparency.



Date: January 2, 2025


Subject: Expert Legal Complaint and Appeal Regarding DOJ Complaints 534659-XGL and 539298-RJM, FOIA Non-Compliance, ADA Violations, and Constitutional Breaches

To: ALL
Primary DOJ Contacts

Sean R. ONeill, Director, Office of Information Policy (OIP)

Email: oip.foia@usdoj.gov
Address: 441 G Street NW, Washington, DC 20530-0001
Kristen Clarke, Assistant Attorney General for Civil Rights

Email: civilrights.justice@usdoj.gov
Address: 950 Pennsylvania Avenue NW, Washington, DC 20530
Michael E. Horowitz, Inspector General, DOJ

Email: oig.hotline@usdoj.gov
Address: 950 Pennsylvania Avenue NW, Washington, DC 20530
Federal and State Contacts

Chiquita Brooks-LaSure, Administrator, CMS
Email: FOIA_Request@cms.hhs.gov

Jeffrey Beckham, Secretary, Connecticut OPM
Email: opm.foia@ct.gov

Dr. Deidre S. Gifford, Commissioner, DSS
Email: foia.dss@ct.gov

William Tong, Attorney General of Connecticut
Email: attorney.general@ct.gov

Introduction
This legal complaint and appeal address significant breaches of the Freedom of Information Act (5 U.S.C.  552), Americans with Disabilities Act (ADA, Title II, 42 U.S.C.  12132), Section 504 of the Rehabilitation Act (29 U.S.C.  794), whistleblower protection laws (5 U.S.C.  2302(b)(8)), and constitutional guarantees under the First, Fifth, and Fourteenth Amendments.

On November 22, 2024, I submitted a FOIA request regarding DOJ Complaints 534659-XGL and 539298-RJM and associated ADA compliance. Despite statutory deadlines and ADA accommodation requests, I have not received the requested records, acknowledgment of accommodations, or compliance with legal mandates.

Violations and Deficiencies Identified
1. FOIA Non-Compliance
Failure to Provide Records:
Agencies failed to produce records, interim updates, or partial responses within the 20-business-day deadline, violating 5 U.S.C.  552(a)(6)(A).
Absence of Statutory Justifications:
No Vaughn index or legal justification has been provided for withheld or redacted records, as required under 5 U.S.C.  552(b).
Lack of Transparency:
The names, titles, and contact information of personnel handling this FOIA request were omitted, obstructing accountability in violation of 5 U.S.C.  552(a)(6)(C).

2. ADA Non-Compliance
Failure to Provide Accessible Formats:
Requested records have not been delivered in screen-reader-compatible formats, violating 42 U.S.C.  12132 and 29 U.S.C.  794.
Use of Inaccessible Portals:
Agencies directed me to external portals or systems incompatible with my cognitive disability, ignoring explicit requests for MuckRock-only communication.
No Simplified Summaries:
Failure to provide plain-language summaries for complex records as requested impedes accessibility, violating ADA Title II regulations (28 C.F.R.  35.160).

3. Whistleblower Retaliation and Suppression
The lack of response to DOJ Complaints 534659-XGL and 539298-RJM raises concerns about retaliation against whistleblowers, violating 5 U.S.C.  2302(b)(8).

4. Constitutional Violations
First Amendment:
By denying access to records, agencies infringe on my right to petition the government for redress of grievances.
Fifth and Fourteenth Amendments:
Denial of ADA accommodations and FOIA responses violates procedural due process and equal protection rights.

Demands for Corrective Action
1. FOIA Compliance
Release of All Records:
Provide unredacted records, correspondence, and communications related to DOJ Complaints 534659-XGL and 539298-RJM.
Detailed Vaughn Index:
For any withheld information, provide a Vaughn index citing specific statutory exemptions under 5 U.S.C.  552(b).
Identification of Personnel:
Disclose the names, titles, and roles of all personnel handling this FOIA request.

2. ADA Compliance
Accessible Document Formatting:
Reformat records into screen-reader-compatible PDFs with proper tagging and indexing.
Simplified Summaries:
Include plain-language summaries for complex or technical records.
Exclusive MuckRock Use:
Transition all communications to the MuckRock platform to eliminate barriers created by inaccessible portals or external systems.

3. Oversight and Accountability
Audit of Compliance Practices:
Request an audit by GAO or OIG to evaluate DOJ and CMS practices regarding FOIA and ADA compliance.
Bi-Weekly Status Updates:
Provide regular updates on the status of this FOIA request.

4. Expedited Processing
Confirm expedited processing under 5 U.S.C.  552(a)(6)(E) due to the significant public interest in ADA compliance and whistleblower protections.
Legal and Statutory Justifications
FOIA (5 U.S.C.  552):

Agencies are required to respond within statutory deadlines and provide justifications for redactions or denials.
ADA (42 U.S.C.  12132) and Section 504 (29 U.S.C.  794):

Mandate reasonable accommodations for individuals with disabilities to ensure access to public records.
Whistleblower Protection Act (5 U.S.C.  2302(b)(8)):

Protects individuals reporting misconduct or violations of law from retaliation.
First Amendment:

Guarantees the right to petition the government and access public information.
Fifth and Fourteenth Amendments:

Ensure procedural due process and equal protection under the law.

Consequences of Non-Compliance
1. Administrative Complaints
File formal complaints with OGIS, DOJ Civil Rights Division, and Office for Civil Rights (OCR) for ADA and FOIA violations.
2. Judicial Remedies
Pursue litigation under 5 U.S.C.  552(a)(4)(B) and 42 U.S.C.  12133 to compel compliance and seek damages.
3. Public Advocacy
Engage media outlets, transparency organizations, and advocacy groups to highlight systemic failures in FOIA and ADA practices.
Request for Expedited Processing Justifications
Public Interest and Accountability:

This request addresses systemic failures in ADA compliance, whistleblower protections, and government transparencyissues of significant public concern.
Civil Rights and Due Process:

Delays impede legal and advocacy efforts to protect individuals with disabilities and whistleblowers.
Legal Precedent:

Courts have recognized that requests addressing public safety and government accountability warrant expedited processing (Al-Fayed v. CIA, 254 F.3d 300 [D.C. Cir. 2001]).
Conclusion

This complaint demands immediate action to rectify systemic violations of FOIA, ADA, and whistleblower protection laws. Compliance is critical to uphold transparency, accountability, and constitutional guarantees.

Sincerely,
David Medeiros
Founder, ABI Resources


CC List for Oversight and Advocacy
Federal Oversight Officials
Merrick Garland, U.S. Attorney General
Kristen Clarke, Assistant Attorney General for Civil Rights
Michael E. Horowitz, Inspector General, DOJ
Gene L. Dodaro, Comptroller General, GAO
Congressional Oversight Committees
House Committee on Oversight and Accountability
Senate Committee on Homeland Security and Governmental Affairs
Senate Judiciary Committee
Transparency and Advocacy Entities
Office of Special Counsel (OSC)
Government Accountability Office (GAO)
Office of Government Information Services (OGIS)

From: DAVID MEDEIROS

11/13/2024
Subject: Freedom of Information Act Request: Records on Medicaid Billing Actions, ADA Compliance, and Retaliation Against ABI Resources LLC Ticket #539494 Following December 18, 2023, Whistleblower Report (Department of State, Office of the Inspector General)

Email
To Whom It May Concern:

Pursuant to the Freedom of Information Act, I hereby request the following records:

Comprehensive FOIA Request for Records on Medicaid Billing Actions, ADA Compliance, and Retaliation Against ABI Resources, LLC Following December 18, 2023, Whistleblower Report

Subject: Comprehensive FOIA Request for Records on Medicaid Billing Actions, ADA Compliance, and Retaliation Against ABI Resources, LLC Following December 18, 2023, Whistleblower Report
To:

FOIA Officer, Centers for Medicare & Medicaid Services (CMS)
FOIA Officer, Office for Civil Rights (OCR), U.S. Department of Health and Human Services (HHS)
FOIA Officer, Civil Rights Division, U.S. Department of Justice (DOJ)
FOIA Officer, Office of Special Counsel (OSC)
FOIA Officer, Connecticut Department of Social Services (DSS)
FOIA Officer, Office of Inspector General (OIG), Department of Health and Human Services (HHS)
Summary of FOIA Request
This FOIA request demands comprehensive documentation regarding retaliatory actions, ADA non-compliance, and procedural violations by the Connecticut Department of Social Services (DSS) and the Centers for Medicare & Medicaid Services (CMS) following a whistleblower report submitted by David Medeiros, founder of ABI Resources, LLC, on December 18, 2023. It further seeks records held by federal oversight agencies on related actions, communications, and decisions.

Purpose of Request
This request seeks complete, unredacted records to establish evidence of:

Retaliatory Actions: Impacts on ABI Resources, including Medicaid billing restrictions, program changes, and ticket closures.
ADA Non-Compliance: Documenting any failures by DSS, CMS, and associated entities in providing accessible communication for David Medeiros.
FOIA Procedural Violations: Highlighting instances of partial responses and unsupported denials of relevant records.
Scope of Records Sought
The records requested cover December 1, 2023, to present. This scope includes, but is not limited to, emails, text messages, digital communications, internal memoranda, directives, meeting notes, attachments, drafts, and related working documents across all relevant departments, divisions, or offices.

1. Medicaid Billing Suspension and Sandata EVV Ticket #539494 (CMS and DSS)
Comprehensive Communications and Directives: Full records (emails, memos, reports, directives, attachments, text messages) from DSS, CMS, and Sandata Technologies concerning Medicaid billing privileges for ABI Resources, LLC, including names and roles of those involved in discussions and approvals.

Complete Documentation of Sandata EVV Ticket #539494: All records associated with Ticket #539494, including:

Initial ticket details, problem descriptions, resolution requests, and follow-ups.
Communications detailing each stage of the tickets handling, the reason for marking it resolved, and personnel involved in closing it.
2. Retaliatory Actions Following December 18, 2023, Whistleblower Report (DSS, CMS, DOJ, OSC)
Internal and External Correspondence: All records, including emails, directives, text messages, memos, and meeting notes, discussing the whistleblower report filed on December 18, 2023, including responses, assessments, and any retaliatory actions considered or taken against ABI Resources.

Documentation of Investigative Actions: All documentation related to any investigations launched in response to the whistleblower complaint, identifying personnel involved, findings, and any recommendations or disciplinary actions.

3. ADA Compliance Documentation and Accommodation Requests (OCR, DOJ, DSS, CMS)
ADA Accommodation Requests: All records concerning ADA accommodations requested by David Medeiros and ABI Resources, with full documentation of responses, denials, and any internal discussions on ADA compliance obligations.

ADA Compliance Policies and Internal Guidelines: Copies of internal policies, training materials, and guidelines used by DSS and CMS related to ADA compliance, particularly on communication accessibility and auxiliary aids for individuals with disabilities.

4. Records on Program Changes Impacting ABI Resources (DSS, CMS)
Companion Authorizations Termination Records: All communications, policy documents, and assessments on the termination of companion authorizations for the ABI Waiver Program as of December 31, 2023, including any correspondence between DSS, CMS, and Sandata Technologies related to this decision.
5. Documentation of Specific Individuals Involvement (All Relevant Agencies)
Records Involving Named Personnel:
Andrea Barton Reeves, Commissioner, DSS
Matthew S. Antonetti, Legal Director, DSS
Astread Ferron-Poole, DSS Associate
Michelle A. James and Emmett Nicholson, CMS officials overseeing Medicaid compliance
All communications, directives, notes, meeting minutes, or any form of correspondence or records involving the above-named individuals with respect to ABI Resources, LLC, particularly regarding Medicaid billing restrictions, ADA accommodation requests, and actions following the December 18, 2023, whistleblower report.

Legal Basis for FOIA Request and Compliance Mandates
1. FOIA Compliance (5 U.S.C.  552)
FOIA mandates timely responses, full disclosure of non-exempt records, and explicit justifications for any redactions or denials. Any failure by DSS, CMS, or other federal agencies to meet these statutory requirements will constitute non-compliance. All denials must include precise statutory citations under FOIA, and records must be provided in their entirety unless exemptions are clearly and legally justified.

2. ADA Compliance Obligations (42 U.S.C.  12132; 28 C.F.R.  35.160)
Under Title II of the ADA, public entities must ensure effective communication with individuals with disabilities. This includes providing accessible documents in screen-reader-compatible formats and meeting specific requests for auxiliary aids. DSS and CMSs failure to meet these requests for ADA accommodations in communications constitutes non-compliance under federal ADA statutes.

3. Federal Whistleblower Protection Standards
Whistleblower protections prohibit retaliation against individuals who report agency misconduct. The actions taken against ABI Resources and David Medeiros, including billing suspension, premature ticket resolution, and operational disruptions following his whistleblower report, are viewed as retaliatory actions that must be substantiated and documented by all relevant agencies.

Specific Demands for Compliance
To ensure adherence to FOIA and ADA mandates, and to facilitate the transparency required by federal and state law, I formally request:

Delivery of ADA-Compliant Records in Full:

Email-Only Communication via MuckRock Platform: All responses, updates, and records must be sent exclusively via email to eliminate accessibility barriers. CMS must refrain from using phone calls, physical mail, or portal-based responses.
Direct Text in Email Body: Embed response text directly in the email body for immediate readability and accessibility.
PDF Attachments for Documents: All records should be provided as clearly labeled PDF attachments, organized by date and document type, with original formatting preserved for clarity and navigability.
Identification of Responsible Personnel: Each response must include names, titles, and contact information of all FOIA officers, decision-makers, and supervisory personnel responsible for processing my request, ensuring transparency and accountability.

Detailed Justifications for Redactions and Denials: Any information withheld or redacted must include detailed explanations citing specific statutory exemptions, in accordance with 5 U.S.C.  552(b). These explanations must include enough detail to verify the legal basis for each exemption claimed.

Request for Expedited Processing of FOIA Request
Pursuant to 5 U.S.C.  552(a)(6)(E), I formally request expedited processing of this FOIA request. This demand is based on critical statutory factors, including significant public interest, imminent risks to the rights of individuals with disabilities, and the need for urgent transparency to prevent ongoing retaliatory actions by public agencies.

Failure to grant expedited processing within the statutory 10-day review period will constitute non-compliance with FOIAs provisions, necessitating formal escalation of this request to administrative or legal authorities.

Consequences of Non-Compliance
Failure to respond to this FOIA request in full compliance, or any delays without proper statutory explanation, may result in formal escalation through administrative, legal, or public channels. DSS, CMS, and other involved agencies are expected to adhere strictly to statutory timelines, ensuring transparency and adherence to ADA and FOIA standards. Non-compliance will be documented and pursued through all available legal remedies.

Conclusion

This FOIA request seeks full and unambiguous access to records necessary to verify and substantiate claims of retaliation, ADA non-compliance, and procedural violations following the December 18, 2023, whistleblower report. I expect each agency to adhere strictly to both FOIA and ADA standards, ensuring prompt and thorough disclosure of all relevant documentation.

Sincerely,
David Medeiros
Founder, ABI Resources, LLC

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

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 20 business days, as the statute requires.

Sincerely,

DAVID MEDEIROS

From: DAVID MEDEIROS

12/03/2024
Subject: RE: Freedom of Information Act Request: Records on Medicaid Billing Actions, ADA Compliance, and Retaliation Against ABI Resources LLC Ticket #539494 Following December 18, 2023, Whistleblower Report (Department of State, Office of the Inspector General)

None
Formal Complaint and Appeal for Non-Acknowledgment and Non-Compliance with FOIA Request
Date: December 3, 2024
From: David Medeiros, Founder, ABI Resources LLC
Subject: Formal Complaint and Appeal Regarding Non-Acknowledgment and Non-Compliance with FOIA Request Submitted November 13, 2024

To Whom It May Concern,

This complaint and appeal address the failure of the Department of State, Office of the Inspector General (OIG) to acknowledge or respond to my Freedom of Information Act (FOIA) request submitted on November 13, 2024. This request concerns critical records pertaining to Medicaid billing actions, ADA compliance, and retaliation against ABI Resources LLC following a December 18, 2023 whistleblower report (Ticket #539494).

Summary of Violations
Failure to Acknowledge the FOIA Request:

The FOIA request has not been acknowledged within the statutory timeframe of 20 business days as required under 5 U.S.C.  552(a)(6)(A).
There has been no communication confirming receipt or providing an Estimated Date of Completion (EDC) within 10 business days, violating 5 U.S.C.  552(a)(7)(B)(ii).
Failure to Provide ADA-Compliant Communication:

The request outlined specific, non-negotiable ADA accommodations under 42 U.S.C.  12132 and 28 C.F.R.  35.160, including:
Exclusive email communication via the MuckRock platform.
Direct text in the email body for accessibility.
Clearly labeled, screen-reader-compatible PDF attachments.
These accommodations have not been adhered to, violating federal disability rights laws.
Obstruction of Whistleblower Protections:

The requested records are critical to addressing retaliation and systemic violations reported under whistleblower protections outlined in 5 U.S.C.  2302(b)(8) and related laws.
Non-responsiveness obstructs accountability and transparency in public administration.
Failure to Ensure Transparency and Accountability:

Non-compliance with the request denies public access to vital information, violating the principles of transparency mandated under 5 U.S.C.  552 and undermining public trust in the use of taxpayer funds.
Specific Remedies Requested
To rectify these violations, I formally request the following actions:

Immediate Acknowledgment of FOIA Request:

Acknowledge receipt of the request dated November 13, 2024, and provide a written confirmation.
Include an Estimated Date of Completion (EDC) in compliance with 5 U.S.C.  552(a)(7)(B)(ii).
Provision of ADA-Compliant Responses:

Deliver all requested records via the MuckRock platform, with response text embedded directly in the email body and documents attached as clearly labeled, screen-reader-compatible PDFs.
Include simplified summaries for complex or technical records to enhance accessibility for individuals with cognitive impairments.
Comprehensive Release of Records:

Provide all requested records in full without improper redactions. Any withheld information must include detailed statutory justifications as per 5 U.S.C.  552(b).
Identification of Responsible Personnel:

Disclose the names, titles, and contact information of all FOIA officers, decision-makers, and supervisory personnel involved in processing this request.
Expedited Processing:

Expedite the processing of this request based on significant public interest and the urgent need for transparency to address retaliation and ADA violations.
Legal Basis for Complaint and Appeal
Freedom of Information Act (5 U.S.C.  552):

Requires acknowledgment, timely responses, and explicit justification for redactions or denials.
Mandates agencies to provide public records unless specific exemptions are clearly applicable.
Americans with Disabilities Act (42 U.S.C.  12132; 28 C.F.R.  35.160):

Ensures equitable communication and access for individuals with disabilities.
Non-compliance with ADA accommodation requests constitutes discrimination under federal law.
Whistleblower Protection Act (5 U.S.C.  2302(b)(8)):

Protects individuals reporting government misconduct.
Retaliatory actions or obstruction of whistleblower-related inquiries are violations of federal protections.
Consequences of Continued Non-Compliance
Failure to address this complaint promptly will result in the following actions:

Administrative Escalation:

Filing complaints with oversight bodies, including the Office of Government Information Services (OGIS) and the Department of Justice (DOJ) Civil Rights Division.
Judicial Remedies:

Initiating legal action under FOIA and ADA statutes to compel compliance and enforce accountability.
Public Disclosure:

Engaging with media outlets, advocacy organizations, and public forums to highlight systemic failures and the lack of transparency.
Conclusion
This submission reflects a comprehensive effort to secure transparency, accountability, and adherence to legal obligations under FOIA, ADA, and whistleblower protection laws. I expect an immediate acknowledgment of this complaint and a commitment to rectifying the outlined violations without delay.

Sincerely,
David Medeiros
Founder, ABI Resources LLC
DB.42.131.Inf.

CC Agency Leadership:

Andrea Barton Reeves

Commissioner, Connecticut Department of Social Services (DSS)
Email: andrea.barton.reeves@ct.gov
Matthew S. Antonetti

Legal Director, Connecticut Department of Social Services (DSS)
Email: matthew.antonetti@ct.gov
Aundra Luckey

Chief, FOIA/PA Branch, Civil Rights Division, U.S. Department of Justice (DOJ)
Email: civil.routing.FOIA@usdoj.gov
Alina M. Semo

Director, Office of Government Information Services (OGIS), National Archives and Records Administration
Email: alina.semo@nara.gov
Federal Oversight Entities:

Centers for Medicare & Medicaid Services (CMS)

FOIA Officer: Joseph Tripline
Email: FOIA_Request@cms.hhs.gov
Office for Civil Rights (OCR), U.S. Department of Health and Human Services (HHS)

FOIA Officer: Arianne Perkins
Email: FOIARequest@hhs.gov
Office of Inspector General (OIG), U.S. Department of Health and Human Services (HHS)

FOIA Officer
Email: foia@oig.hhs.gov
Office of Special Counsel (OSC)

FOIA Officer
Email: foia@osc.gov
State-Level Entities:

Governors Office, State of Connecticut

Email: governor.lamont@ct.gov
Connecticut Freedom of Information Commission (FOIC)

Email: foic@ct.gov
Attorney Generals Office, Connecticut

William Tong, Attorney General
Email: attorney.general@ct.gov

From: DAVID MEDEIROS

01/01/2025
Subject: RE: Freedom of Information Act Request: Records on Medicaid Billing Actions, ADA Compliance, and Retaliation Against ABI Resources LLC Ticket #539494 Following December 18, 2023, Whistleblower Report (Department of State, Office of the Inspector General)

Email
Complaint and Appeal

Date: January 1, 2025
01/01/2025

From: David Medeiros, Founder, ABI Resources

To: All
Department of State, Office of the Inspector General (OIG)
FOIA/PA Branch

CC:

William Tong, Attorney General of Connecticut
Andrea Barton Reeves, Commissioner, Connecticut Department of Social Services (DSS)
Aundra Luckey, Chief, FOIA/PA Branch, Civil Rights Division, DOJ
Alina M. Semo, Director, Office of Government Information Services (OGIS)
Centers for Medicare & Medicaid Services (CMS)
Office for Civil Rights (OCR), U.S. Department of Health and Human Services (HHS)
U.S. Department of Health and Human Services, Office of Inspector General (HHS OIG)
Connecticut Freedom of Information Commission (FOIC)
Subject: Escalated Complaint and Appeal for FOIA Non-Compliance, ADA Violations, and Whistleblower Retaliation

Summary of the Complaint
This formal complaint and appeal address the failure of the Department of State, Office of the Inspector General (OIG) to respond to my Freedom of Information Act (FOIA) request submitted on November 13, 2024. This request seeks records on Medicaid billing actions, ADA compliance, and retaliation against ABI Resources, LLC, following a whistleblower report submitted on December 18, 2023 (Ticket #539494).

The non-compliance and lack of acknowledgment violate FOIA statutory obligations, the Americans with Disabilities Act (ADA), and federal whistleblower protections. This failure hinders transparency and accountability, obstructing access to public records and whistleblower protections guaranteed by law.

Violations Identified

1. FOIA Non-Compliance
Statutory Obligation: Agencies must acknowledge FOIA requests within 20 business days per 5 U.S.C.  552(a)(6)(A) and provide an Estimated Date of Completion (EDC) within 10 business days under 5 U.S.C.  552(a)(7)(B)(ii).
Violation: No acknowledgment, EDC, or substantive response has been provided as of January 1, 2025.

2. ADA Non-Compliance
Statutory Obligation: Title II of the ADA (42 U.S.C.  12132) and implementing regulations (28 C.F.R.  35.160) require public entities to ensure effective communication with individuals with disabilities, including reasonable accommodations.
Violation: The agency has failed to meet explicit ADA accommodations requested, including:
Communication via the MuckRock platform.
Delivery of documents as screen-reader-compatible PDFs.
Simplified summaries for complex records.

3. Whistleblower Protection Violations
Statutory Obligation: The Whistleblower Protection Act (5 U.S.C.  2302(b)(8)) prohibits retaliation against whistleblowers and ensures protections for reporting government misconduct.
Violation: Lack of response and obstruction in providing requested records impedes my ability to investigate retaliatory actions and hold agencies accountable.

4. Constitutional Violations
First Amendment: Suppression of public records undermines my right to petition the government for redress of grievances.
Fifth Amendment: Denying access to requested records impairs procedural due process rights.
Fourteenth Amendment: Systemic exclusion through non-compliance with ADA accommodations constitutes discrimination.
Specific Records Requested
Medicaid Billing and Sandata EVV Ticket #539494:
All communications, directives, and notes related to billing restrictions for ABI Resources, LLC, and documentation of the resolution process for Ticket #539494.

Retaliatory Actions Following Whistleblower Report:
Correspondence, memos, directives, and investigative actions linked to the whistleblower report submitted on December 18, 2023.

ADA Accommodation Requests and Compliance Records:
Documentation of ADA accommodation requests and responses, internal communications, and policies on ADA compliance.

Program Changes Impacting ABI Resources:
Policies, correspondence, and decisions related to the termination of companion authorizations under the ABI Waiver Program.

Named Individuals Records:
Communications and directives involving Andrea Barton Reeves (DSS Commissioner), Matthew S. Antonetti (DSS Legal Director), and CMS officials overseeing Medicaid compliance.
ADA Accommodation Requirements (Non-Negotiable)
To ensure compliance and equitable access, I reiterate the following:

Exclusive MuckRock Platform Communication: All responses must be delivered through MuckRock. No external portals, emails, or physical mail are acceptable.
Screen-Reader-Compatible Formats: Records must be provided as accessible PDFs with clear labeling.
Simplified Summaries: Complex records must include plain-language summaries.
Identification of Personnel: Names, titles, and contact details of FOIA officers and decision-makers must accompany all responses.

Legal Basis for Appeal
Freedom of Information Act (5 U.S.C.  552): Requires timely acknowledgment, explicit justifications for denials, and transparency in the release of public records.
Americans with Disabilities Act (42 U.S.C.  12132; 28 C.F.R.  35.160): Mandates accessibility and effective communication for individuals with disabilities.
Whistleblower Protection Act (5 U.S.C.  2302(b)(8)): Protects individuals from retaliation and ensures accountability in addressing government misconduct.
Constitutional Protections: The First, Fifth, and Fourteenth Amendments safeguard access to public processes and prohibit discrimination.

Demands for Compliance
Immediate Acknowledgment of FOIA Request: Confirm receipt of the November 13, 2024, request and provide an Estimated Date of Completion (EDC) within two business days.
Expedited Processing: Grant expedited processing per 5 U.S.C.  552(a)(6)(E) due to significant public interest and the urgent need to address retaliation and ADA violations.
Comprehensive Release of Records: Deliver all requested records, adhering to FOIA and ADA standards, without improper redactions.
Justifications for Denials or Delays: Any redactions or withholdings must include detailed statutory justifications per 5 U.S.C.  552(b).
Preservation of Responsive Records: Confirm preservation of all responsive records to prevent spoliation or deletion.
Escalation and Consequences of Non-Compliance

Failure to address this complaint will result in:

Formal Complaints: Filing with oversight bodies, including OGIS, DOJ Civil Rights Division, and Connecticut FOIC.
Legal Remedies: Initiating litigation to compel compliance under FOIA and ADA statutes.
Public Advocacy: Engaging media outlets, advocacy organizations, and public forums to expose systemic failures and non-transparency.
Conclusion

This complaint reinforces the need for transparency, accessibility, and whistleblower protections in government operations. I expect immediate acknowledgment of this appeal and full compliance with the requested remedies by January 10, 2025.

Sincerely,
David Medeiros
Founder, ABI Resources

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

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-2025-001 FOIA-2025-00562 FOIA-2025-00563 EMRUFOIA111524 F-2025-03523 2025-00574-FOIA-PHS 145-FOI-21320 OPM ID #24-94 25-OIG-177 FOIA-2025-01054 FOIA-2025-01052 EMRUFOIA120324-7 FOIA-2025-01053 OPM ID #24-95 FOIA-2025-01056 EMRUFOIA120324-7 FOIA-2025-01055 FOIA-2025-01057 R005487-120324 2025-01079-FOIA-PHS 2025-01078-FOIA-PHS FOIA-2025-056 PRI-25-045 FOIA-2025-01060 FOIA-2025-01059 FOIA-2025-060 FOIA-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-25-000310 DI-25-000325 DI-25-000379
DI-12192024714 DI-12112024134 FBI

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