Re: Texas Public Information Act Request

Dear Sir or Madam:

Pursuant to the Texas Public Information Act, as codified at Chapter 552 of the Texas Government Code, we hereby request from the Texas Department of Public Safety, true and correct copies of all filings, correspondence, memoranda, documents, reports, records, statements, audits, lists of names, applications, diskettes, letters, expense logs and receipts, calendar or diary logs, facsimile logs, telephone records, call sheets, tape recordings, video recordings, notes, examinations, and/or referenced opinions, folders, files, books, manuals, pamphlets, forms, drawings, charts, photographs, electronic mail, and any other documents or things that refer or relate to the following persons and/or entities in any way:

1.                  Basman Elashi (a/k/a “El-Ashey”);
2.                 Ghassan Elashi;
3.            Bayan Elashi;
4.            Shukri Baker;
5.            Ghassan Dahduli;
6.            Islamic Association for Palestine;
7.            InfoCom Corporation;
8.            Holy Land Foundation for Relief and Development; and
9.            American Middle Eastern League for Palestine;

This request for information should be liberally construed so as to include the publication of all data and/or materials which could reasonably be determined to fall within a given category without regard to any technical classifications, misnomer, statutory definition, regulation or other specialized use of any terms of art.

Further, if any portions of the requested information are claimed to be privileged, those portions should be redacted and an explanation provided while all non-privileged portions should be provided as requested.

Thank you for your anticipated cooperation in responding to our request in a timely manner as required under Texas Government Code §552.221. Further, pursuant to §552.267, Judicial Watch, Inc. is entitled to a waiver of any charges related to this request because such waiver is in the public interest and providing the requested copies of the materials described herein will primarily benefit the general public.

As a 501 (c)(3) not-for-profit organization, Judicial Watch, Inc. has no commercial purpose. It is a non-profit, tax-exempt educational foundation organized to increase public understanding of government operations and activities, as well as the importance of ethics and the rule of law in government. Judicial Watch, Inc. regularly requests information about the operations of government through FOIA, State Open Records Acts and other means, uses it editorial skills to turn this information into distinct works, and regularly publishes and disseminates its work to the public in furtherance of its educational mission.

Judicial Watch, Inc. uses the following means, among others, to disseminate its works to the public:

(1) Judicial Watch, Inc. produces several live radio programs, including a two-hour program entitled “The Judicial Watch Report,” which airs nationally once every week on approximately 43 radio stations. Since September 2001, Judicial Watch, Inc. has produced an hour-long Spanish language program that airs twice weekly on WQBA – 1140 AM in Miami, Florida. Since October 29, 2001, Judicial Watch, Inc. also has produced a two-hour program that airs daily on the USA Radio Network. Judicial Watch, Inc.’s weekly and daily radio programs also can be heard via the Internet at www.USARadio.com and www.JudicialWatch.org.

(2) Judicial Watch also produces and broadcasts a twice weekly television program entitled “The Judicial Watch Report,” which is seen on the Dish Network and the Liberty Network among others. The producer of this program is Brian Doherty, who formerly produced “The O’Reilly Factor” and “The Drudge Report” on the Fox News Channel.

(3) Judicial Watch, Inc. also maintains an Internet site, www.JudicialWatch.org, on which the public can view and inspect records obtained through FOIA, records obtained through civil litigation, press releases, editorial works, deposition transcripts and court opinions, among other materials. This website is viewed by over 1,700 people per day on average, and on several occasions, has logged up to 600,000 visitors in a single day.

(4) Judicial Watch, Inc. also publishes a monthly newsletter, which is sent to approximately 210,000 individuals. It also utilizes an E-mail Infonet service, which sends out updates of Judicial Watch’s activities over the Internet on nearly a daily basis to 13,700 persons.

(5) Judicial Watch, Inc. also produces several editorial works each week in the form of press releases, which are “blast faxed” to hundreds of radio and television stations, as well as newspapers throughout the country.

(6) Judicial Watch also publishes detailed periodic reports. For example, on September 28, 1998, Judicial Watch, Inc. published its Interim Report on Crimes and Other Offenses Committed by President Bill Clinton Warranting His Impeachment and Removal from Elected Office. This 145-page report was accompanied by nearly 4,000 pages of supporting documentation, and was crafted, in part, from the raw materials obtained by Judicial Watch, Inc. through FOIA requests. This distinct work has been disseminated widely to the public. On or around August 10, 1999, Judicial Watch, Inc. published its Filegate Status Report, which is 136 pages long and is supported by nearly 1000 pages of documentation. Another recent report by Judicial Watch, Inc. is The Judicial Watch Florida Recount, an independent, non-partisan analysis of the results of Florida’s hotly contested 2000 Presidential election, based upon a sampling of ballots reviewed by Judicial Watch, Inc. pursuant to Florida’s version of FOIA. This document was published on March 22, 2001. In addition, Judicial Watch, Inc. published The Judicial Watch 2002 “State of the Union” Report, Bush Administration Ethics Enforcement: “A Failure of Leadership,” on February 1, 2002, and its most recent publication is Fatal Neglect: The US Government’s Continuing Failure to Protect American Citizens from Terrorists, published September 11, 2002.

Judicial Watch, Inc. also uses records it obtains pursuant to FOIA, State Open Records Acts or other means at public events such as conferences, seminars and speeches. For example, in October of 2001, Judicial Watch held its third annual “Ethics in Government Conference” in Miami, Florida. Previous conferences were held in Pasadena, California (1999) and Washington, DC (2000). Judicial Watch, Inc. also works with other media organizations to publish news stories that are in the public interest. The Chairman and President of Judicial Watch, Inc. also frequently appear on nationally broadcast television and radio programs. Judicial Watch, Inc. is a member of the National Religious Broadcast Association and has been granted press credentials at a number of national conventions and other events.

In short, disclosure of the requested records will contribute to an understanding of this particular investigation and will further citizen awareness of significant issues, thereby benefiting the general public. We look forward to receiving the requested information and a full public interest waiver fee within ten (10) business days.

Sincerely,

JUDICIAL WATCH, INC.

Todd W. Hutton

TWH/rdd