Except for Brad Wenstrup and a couple of new guys who don't have much standing. Ohio has NO Representatives. Even Brad would like to, but the really tough issues, he won't touch them. WE can try this:
Jonathan E Meyer
General Counsel of the Department of Homeland Security
245 Murray Lane SW
Mail Stop 0485
Washington, DC 20528-0485
Re: Notice of Prospective Litigation; Demand for Records Retention
Dear Mr Meyer,
I am an aggrieved citizen of the United States and of the [NAME OF STATE] and I am contemplating filing a lawsuit, including the possibility of joining a class action proceeding against the relevant parties pertaining to the concerns I have regarding the censorship that has been or may have been implemented or encouraged by your organization, the US Department of Homeland Security, pertaining to certain users’ social media accounts (Facebook, Instagram, Twitter, YouTube, etc). Moreover, I am concerned regarding the sharing of data obtained from my social media accounts by your organization, other government agencies and/or private companies. Accordingly, I hereby notify and instruct you to retain any and all documents and other materials related to the following social media accounts, which I created:
[SOCIAL MEDIA OUTLET (Ex: Facebook); USERNAME (ex: @JohnDoe123)] [SOCIAL MEDIA OUTLET (Ex: Instagram); USERNAME (ex: @JohnDoe123)] [SOCIAL MEDIA OUTLET (Ex: Twitter); USERNAME (ex: @JohnDoe123)] [SOCIAL MEDIA OUTLET (Ex: YouTube); USERNAME (ex: @JohnDoe123)]
Given the litigation I am contemplating commencing or joining regarding the above issues, I demand that you retain any and all documents and data relating to or concerning the censorship or flagging of the above-listed social media accounts and/or the use or exchange of data obtained by the social media accounts by your organization and any other government agency or private company. All such documents and data must be maintained and preserved. This means that any documents and data in your possession or control regarding the censorship or flagging of the above-listed social media accounts and/or the use or exchange of data obtained from these social media accounts obtained by your organization and any other government agency or private company must not be destroyed or deleted until you are notified in writing that it is permissible to do so.
“Documents and data”, as used here includes hard and electronic copies of documents, including letters, correspondence, memoranda, reports, tabulations, calculations, invoices, vouchers, ledgers, journals, external and internal literature, books, notes, schedules, worksheets, plans, minutes, bulletins, brochures, catalogs, notices, press releases, transcripts, calendars, appointment books, diaries, charts and drafts of all such documents that mention or relate to the censorship or flagging of the above-listed social media accounts and/or the use or exchange of data obtained from these social media accounts by your organization and any other government agency or private company. This includes handwritten notes, drafts, tabulations, calculations, summaries and work papers; it is not limited to any “formal” or “final” documents.
“Documents and data” includes photographs, audio or video tapes or recordings. “Documents and data” also includes electronically stored information, such as e-mail, voicemail, word processing files, spreadsheets, databases, calendars, digital audio or video recordings, instant messages, text messages, social media posts, telephone logs, internet files and any other electronic information created, maintained or received by you.
This list is not exhaustive, all documents and data relating in any way to the censorship or flagging of the above-listed social media accounts and/or the use or exchange of data obtained from these social media accounts by your organization and any other government agency or private company must be preserved.
This records retention hold and notice suspends any normal deletion requirements for documents, e-mails, and other information that may otherwise apply. Do not destroy, delete or in any way alter any paper or electronic information relating to my prospective claims or the other areas of interest mentioned above. Be sure to communicate this to the employees who work under your supervision.
If you have possession, custody or control of any information, whether in paper form or electronic form pertaining to my prospective claims, you are instructed to take immediate steps to preserve it in its original form. For example, do not delete any e-mails, internet files or other computer files containing information pertaining to the claims. You should also take steps to ensure that e-mails and files will not automatically be deleted by the system. Once you have identified any relevant information in your possession, please coordinate with me to ensure that I am provided with a copy of it.
If you are aware of any person employed by or otherwise affiliated with your organization, whether presently or formerly who may have information pertinent to my prospective claims, please provide me with that information. Additionally, please ensure that any person(s) who is assigned to manage the computers or files of your organization that may contain information pertinent to my claims is immediate informed of the requirements set forth in this letter. You must ensure that any such person not only does not delete any information but also makes arrangements to preserve the information contained on the computer or in the files.
To the extent you may have any concerns or questions in this regard, please contact me. Thank you for your cooperation in this matter.
Sincerely,
/s/[ELECTRONIC OR MANUAL SIGNATURE] [PRINT NAME] [STREET ADDRESS] [CITY, STATE][ZIP] [EMAIL ADDRESS]
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