Ken Klippenstein FOIA Lawsuit

Filing # 117323728 E-Filed 11/30/2020 04:26:22 AM
IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT

LEON COUNTY, FLORIDA
CIVIL ACTION
KEN KLIPPENSTEIN,
Plaintiff, Case No.
v.
FLORIDA DEPARTMENT OF LAW ENFORCEMENT,

Defendant.
_______________________________________________/
COMPLAINT FOR WRIT OF MANDAMUS
Plaintiff, Ken Klippenstein, through undersigned counsel and pursuant to
Rule 1.630 of the Florida Rules of Civil Procedure and Chapter 119, Florida
Statutes, petitions the Court for an immediate hearing and the entry of a Writ of
Mandamus directing the Defendant to produce public records requested by
Plaintiff. In support hereof, Plaintiff states:
FACTS ON WHICH PLAINTIFF RELIES FOR RELIEF
1. Plaintiff, Ken Klippenstein, is a journalist and is the DC Correspondent
for The Nation magazine. Plaintiff has written extensively about national security,
and his work has been referenced by The New York Times, The Washington Post,
The Los Angeles Times, The Atlantic, and other major media outlets.
2. Defendant, Florida Department of Law Enforcement (FDLE), oversees
the Network of Florida Fusion Centers, which includes the primary fusion center,
Florida Fusion Center (FFC), two recognized fusion centers, and five regional
fusion centers, which includes three certified nodes of FFC.1 Composite Exhibit A.
According to the Department of Homeland Security, a primary fusion center
“provides information sharing and analysis for an entire state” and a recognized
fusion center “provides information sharing and analysis for a major urban area.”2
3. The Central Florida Intelligence Exchange (CFIX) and the Southeast
Florida Fusion Center (SEFFC) are the two recognized fusion centers.3 Composite
Exhibit B.
4. The Tampa Bay Regional Intelligence Center (TBRIC) is a regional node
of FFC.4 The Northwest Florida Fusion Center (NWFFC),5 the North Florida
Fusion eXchange (NFFX),6 the Northeast Florida Fusion Center (NEFFC),7 and the
Southwest Florida Fusion Center (RSIX)8 are all regional fusion centers
(Composite Exhibit C); it is unknown which of these may be a certified node of
FFC, though RSIX stated it is a node via email. Exhibit D.
5. On July 11, 2020, Plaintiff emailed all fusion centers a public records
request attached to the email as a PDF document, seeking “copies of catalogues,
1
http://www.fdle.state.fl.us/FFC/FFC/FusionCenterHistory
2
https://www.dhs.gov/fusion-center-locations-and-contact-information
3
See FN2.
4
http://www.fdle.state.fl.us/FFC/TBRIC.aspx
5
http://www.fdle.state.fl.us/FFC/NWFFC.aspx
6
http://northfloridafusionexchange.com
7
http://www.fdle.state.fl.us/FFC/Regional-Fusion-Centers.aspx
8
See FN5.
indices or any other list of all intelligence products received and/or generated by
this fusion center, including but not limited to Suspicious Activity Reports, Joint
Intelligence Bulletins, Situational Awareness Reports, and threat assessments.
Please include records generated by this agency but also those received from other
ones, including state and federal partners (e.g., the Federal Bureau of Investigation,
the Department of Homeland Security, etc.).” Having received no reply from any
fusion center, Plaintiff emailed all fusion centers again on August 17, 2020,
seeking the status of Plaintiff’s request as well as an estimated date of completion.
Composite Exhibit E is a copy of the email chain to all fusion centers for both
dates, including replies from RSIX in August, along with the PDF attachment to
the July emailed records request.
6. On August 22, 2020, Plaintiff again emailed all fusion centers with a
records request attached as a PDF document seeking all intelligence products
related to George Floyd protests, including a list of keywords. Composite Exhibit
F.
7. On October 7, 2020, CFIX was the first and only fusion center to produce
responsive records to Plaintiff’s July 11, 2020 request. Composite Exhibit G. No
fusion center produced responsive documents to Plaintiff’s August 22, 2020
request; as a result of the responsive documents by CFIX, Plaintiff decided to
abandon his July and August records requests in favor of new records requests
seeking the same information as the July 11, 2020 request in a more descriptive
fashion based upon the responsive documents received from CFIX on October 7,
2020.
The October Florida Fusion Center (FFC) Requests
8. On October 11, 2020, Plaintiff emailed the Florida Fusion Center a public
records request as a PDF attachment seeking “a document log, alerts log, and/or
product log of all Intelligence Products produced or possessed by the Florida
Fusion Center (FFC) from January 1, 2019, through October 7, 2020. The
document log, alerts log, and/or product log should include the Intelligence
Product metadata, such as the document number, the date of the document, the
document type, and the document topic or title, along with any additional metadata
kept by FFC.” Plaintiff’s email stated FFC may disregard any prior records
request and treat that email and its attachment as the only records request to FFC.
Composite Exhibit H is the email and its PDF attachment. Plaintiff received no
response to this email.
9. Based upon a response from a fusion center (RSIX), on October 21,
2020, Plaintiff did a second public records request seeking the titles to all
intelligence products as it first appears in the document, in the event FFC did not
store intelligence products and product metadata in the same manner as CFIX’s
October 7, 2020 records production, and Plaintiff’s email requested a status on his
prior records request. Composite Exhibit I. Plaintiff received no response to this
email.
10. On October 27, 2020, Plaintiff emailed a third public records request to
FFC as a PDF attachment, which combined the October 11 and October 21
requests into one request, seeking the following:
I respectfully request records sufficient to show the titles of intelligence

products and all corresponding metadata (e.g. a document number,
document type, document date), which may be in the form of a document
log, alerts log, and/or product log, for all finished intelligence products
produced or possessed by the Florida Fusion Center from January 1, 2019,
through October 27, 2020. An example of the records I am seeking is
attached hereto as Appendix 1.
If no such record exists as detailed above and shown by example in

Appendix 1, I then alternatively respectfully request records sufficient to
show the titles of all finished intelligence products generated by or for your
agency. Please provide copies of each intelligence product’s title as it first
appears in the document; should the title first appear on the document on a
page that contains information beyond the title, the additional information
may be redacted so as to provide only the title of the finished intelligence
product.
Additionally, Plaintiff’s email noted he had not received an acknowledgment of his
prior two requests. Composite Exhibit J is a copy of the email and its PDF
attachment.
11. On October 29, 2020, Plaintiff received two emails from FFC replying
to his October 27, 2020 email with his third records request. The first email reply
stated Plaintiff’s request was submitted to their office and previously received on
October 21, 2020 and docketed as PRR-2020-2811 and PRR-2020-2817, noting

that PRR-2020-2811 was emailed to info@fdle.state.fl.us (public records request
email for media requests to FDLE) and PRR-2020-2817 was “sent to the North
Florida Fusion Center” and provided NFFX’s email address. The second email
reply stated Plaintiff had previously submitted his request on October 21, 2020,
and it was docketed as PRR-2020-2811 and was sent to FDLE’s Public
Information Office (info@fdle.state.fl.us). Composite Exhibit K contains both
email replies from October 29, 2020.
12. To date Plaintiff has received no responsive documents from FDLE
related to the requests to FFC from October, 2020, all of which seek information
that would be researched in the same manner as each other and in the same manner
as the July 11, 2020 request which was abandoned on October 11, 2020, in favor of
a clearer request for the same records.
13. Defendant’s unjustified delay in producing the records sought
constitutes an unlawful refusal to provide access to public records under Chapter
119.
The October North Florida Fusion eXchange (NFFX) Requests
14. On October 11, 2020, Plaintiff emailed NFFX a public records request
as a PDF attachment seeking “a document log, alerts log, and/or product log of all
Intelligence Products produced or possessed by the North Florida Fusion eXchange
(NFFX) from January 1, 2019, through October 7, 2020. The document log, alerts
log, and/or product log should include the Intelligence Product metadata, such as
the document number, the date of the document, the document type, and the
document topic or title, along with any additional metadata kept by NFFX.”
Plaintiff’s email stated NFFX may disregard any prior records request and treat
that email and its attachment as the only records request to NFFX. Composite
Exhibit L is the email and its PDF attachment.
15. On October 12, 2020, NFFX emailed acknowledging receipt of
Plaintiff’s October 11, 2020 request and stating generally that “NFFX and FDLE”
may not have responsive records and provided FDLE’s phone number and public
records request email for additional information, as well as a link to FDLE’s Office
of the General Counsel Public Records/Records Custodian web page. Composite
Exhibit M contains NFFX’s email and the web page from the link.
intelligence products as it first appears in the document, in the event NFFX did not
store intelligence products and product metadata in the same manner as CFIX’s
prior records request. Composite Exhibit N.
17. On October 22, 2020, NFFX responded to Plaintiff’s October 21, 2020
request in the same manner it responded on October 12, 2020. Exhibit O.

NFFX as a PDF attachment, which combined the October 11 and October 21

produced or possessed by the North Florida Fusion eXchange (NFFX) from
January 1, 2019, through October 27, 2020. An example of the records I
am seeking is attached hereto as Appendix 1.

product.
Composite Exhibit P is a copy of the email and its PDF attachment.
19. On October 28, 2020, NFFX emailed a response acknowledging receipt
of Plaintiff’s October 27, 2020 request in the same manner it had on October 12
and October 22, 2020. Exhibit Q.
20. To date Plaintiff has received no responsive documents from NFFX or
FDLE related to the requests to NFFX from October, 2020, all of which seek
information that would be researched in the same manner as each other, as well as
the exact same manner as FFC, and in the same manner as the July 11, 2020
request to NFFX and FFC which were abandoned on October 11, 2020, in favor of
a clearer request for the same records.
119.
The October Northwest Florida Fusion Center (NWFFC) Requests
22. On October 11, 2020, Plaintiff emailed NWFFC a public records request
as a PDF attachment seeking “a document log, alerts log, and/or product log of all
Intelligence Products produced or possessed by the Northwest Florida Fusion
Center (NWFFC) from January 1, 2019, through October 7, 2020. The document
log, alerts log, and/or product log should include the Intelligence Product metadata,
such as the document number, the date of the document, the document type, and
the document topic or title, along with any additional metadata kept by NWFFC.”
Plaintiff’s email stated NWFFC may disregard any prior records request and treat
that email and its attachment as the only records request to NWFFC. Composite
Exhibit R is the email and its PDF attachment. Plaintiff received no response to
this email.
intelligence products as it first appears in the document, in the event NWFFC did
not store intelligence products and product metadata in the same manner as CFIX’s
prior records request. Composite Exhibit S.
24. On October 22, 2020, NWFFC responded to Plaintiff’s October 21,
2020 request stating that both of his requests were forwarded to NWFFC’s public
records section, and provided FDLE’s phone number and email for public records
requests made by media. Exhibit T.
NWFFC as a PDF attachment, which combined the October 11 and October 21

produced or possessed by the Northwest Florida Fusion Center (NWFFC)
from January 1, 2019, through October 27, 2020. An example of the
records I am seeking is attached hereto as Appendix 1.

product.
Composite Exhibit U is a copy of the email and its PDF attachment. Plaintiff has
not received a response to this email.

26. To date Plaintiff has received no responsive documents from NWFFC or
FDLE related to the requests to NWFFC from October, 2020, all of which seek
information that would be researched in the same manner as each other, as well as
the exact same manner as FFC and NFFX, and in the same manner as the July 11,
2020 request to NWFFC, NFFX and FFC which were abandoned on October 11,
2020, in favor of a clearer request for the same records.
119.
Email Responses from RSIX, TBRIC and SEFFC
28. On October 11, 2020, Plaintiff emailed RSIX and TBRIC the same
requests as he had emailed FFC, NFFX and NWFFC. TBRIC did not respond to
Plaintiff’s email; RSIX responded to Plaintiff’s email and noted it does not store
intelligence product titles and corresponding metadata in a catalog, so via email
Plaintiff altered his request to seek titles of the products.
29. Many emails were exchanged between Plaintiff and RSIX discussing
fees to produce records and the estimate of hours to fulfill the request due to the
manner in which RSIX holds records, but one notable reply from RSIX on October
27, 2020, stated the following: “Have you contacted the Florida Fusion Center for
these records? We work under their umbrella. They maintain and keep a catalog of
all the documents we produce.” Composite Exhibit V.
30. Plaintiff submitted the same October 21, 2020 records request that he
submitted to FFC, NFFX and NWFFC to TBRIC and again received no email
reply. TBRIC’s address being listed as the Hillsborough County Sheriff’s office
led Plaintiff to submit a request for TBRIC through the Hillsborough Sheriff’s
online records request portal on October 27, 2020. On October 28, 2020, the
records center responded “No records responsive. Refer to FDLE Florida Fusion
Center.” Composite Exhibit W contains the request submitted via the online portal,
along with the response from the records center.
31. Plaintiff submitted the same October requests to the Southeast Florida
Fusion Center (SEFFC) as he submitted to FFC, NFFX, NWFFC and TBRIC. On
November 25, 2020, SEFFC responded to Plaintiff’s request stating it does not
keep a log or master list of its products, but that in an effort to provide him with the
records sought, it was attaching a screenshot of its sharepoint system, which
contained the information sought in the October records requests. Composite
Exhibit X contains the email reply and responsive screenshot.
COUNT FOR WRIT OF MANDAMUS
32. Paragraphs 1 through 31 are realleged as if fully set forth herein.

33. Plaintiff has a clear legal right to the documents requested in Composite
Exhibits H through J, L, N, P, R, S and U.
34. Based upon email responses from FFC in Composite Exhibit K, NFFX
in Composite Exhibits M, O and Q, NWFFC in Composite Exhibit T, RSIX in
Composite Exhibit V and TBRIC in Composite Exhibit W, it is believed Defendant
maintains records not just for those fusion centers, but for the entire Network of
Florida Fusion Centers and thus holds responsive documents for CFIX, NEFFC,
and SEFFC as well.
35. Based upon the email response from RSIX in Composite Exhibit V, it is
believed Defendant maintains the records as a catalog.
36. Defendant has breached its duty to provide access to records and has
unlawfully refused access to records via an unjust delay.
37. No other effective legal remedy is available to Plaintiff.
38. Because Defendant has unlawfully refused to permit public records to
be inspected or copied, Plaintiff is entitled to recover the reasonable costs incurred
in enforcement, including reasonable attorney’s fees pursuant to Section 119.12,
Florida Statutes.
ARGUMENT
39. “Public records” include “all documents . . . regardless of the physical
form . . . made or received . . . in connection with the transaction of official

business by any agency.” § 119.011(12), Fla. Stat. This includes any material made
or received in connection with official agency business “which is intended to
perpetuate, communicate, or formalize knowledge of some type.” Shevin v. Byron,
Harless, Schaffer, Reid and Associates, Inc., 379 So. 2d 633, 640 (Fla. 1980).
40. Plaintiff has a clear legal right to access public records. Article I,
Section 24(a) of the Florida Constitution grants “[e]very person ... the right to
inspect or copy any public record made or received in connection with the official
business of any public body, officer, or employee of the state, or persons acting on
their behalf.” The right is enforced through the Public Records Law, Chapter 119
of the Florida Statutes.
41. Florida’s public records law “is to be construed liberally in favor of
openness, and all exemptions from disclosure are to be construed narrowly and
limited in their designated purpose.” Board of Trustees, Jacksonville Police & Fire
Pension Fund, 189 So. 3d 120, 125 (Fla. 2016) (internal citations omitted).
42. To be entitled to mandamus, a party must allege a violation of a clear
legal right and the breach of an indisputable legal duty. E.g., Polley v. Gardner, 98
So. 3d 648, 649 (Fla. 1st DCA 2012). A public official’s disclosure of public
records in compliance with Chapter 119 is a ministerial duty and mandamus is an
appropriate means of compelling compliance. Weeks v. Golden, 764 So. 2d 633,
634 (Fla. 1st DCA 2000).

43. The titles of intelligence products and its corresponding metadata are
public records because they are produced or received by the fusion centers in
connection with the transaction of official business by the Defendant and under its
umbrella. Defendant has a ministerial duty to produce the records to Plaintiff.
44. If Defendant seeks an exemption, the burden is on Defendant to
demonstrate its entitlement to an exemption. Weeks v. Golden, 764 So. 2d 633, 635
(Fla. 1st DCA 2000). Some documents received in the course of official business
may originate from federal agencies; if a federal statute requires particular records
to be closed and the state is clearly subject to the provisions of such statute, then
pursuant to the Supremacy Clause of the United States Constitution, Art. VI, U.S.
Const., the state must keep the records confidential. State ex rel. Cummer v. Pace,
159 So. 679 (Fla. 1935); AGOs 90-102, 85-03, 81-101, 80-31, and 74-372. See
also Wallace v. Guzman, 687 So. 2d 1351, 1353 (Fla. 3d DCA 1997) (exemptions
from disclosure set forth in federal Freedom of Information Act apply to
federal agencies but not to state agencies) (emphasis added).
45. Should the Court find that some of the documents requested may fall
within a claimed exemption, the proper procedure would be to require Defendant
to furnish the documents to the Court for an in camera inspection. Walton v.
Dugger, 634 So. 2d 1059, 1061-62 (Fla. 1993).

46. Delays in records production are allowed in limited circumstances. See
Promenade D’Iberville, LLC v. Sundy, 145 So. 3d 980, 983 (Fla. 1st DCA, 2014).
Otherwise, the only delay in producing records permitted under Ch. 119, F.S., “is
the limited reasonable time allowed the custodian to retrieve the record and delete
those portions of the record the custodian asserts are exempt.” Id. at 983, citing
Tribune Company v. Cannella, 458 So. 2d 1075, 1078 (Fla. 1984), appeal
dismissed sub nom., DePerte v. Tribune Company, 105 S.Ct. 2315 (1985).
Officials are held accountable where delays aren’t justified by the Public Records
Act. Siegmeister v. Johnson, 240 So. 3d 70, 74 (Fla. 1st DCA 2018). An agency’s
unjustified delay in producing public records constitutes an unlawful refusal to
provide access to public records. See Lilker v. Suwannee Valley Transit Authority,
133 So. 3d 654, 655 (Fla. 1st DCA 2014) (“Unlawful refusal under section 119.12
includes not only affirmative refusal to produce records, but also unjustified delay
in producing them”).
47. When an agency fails to produce public records as required in Chapter
119, a writ of mandamus is proper. City of Gainesville v. State ex rel. Int'l Ass'n of
Fire Fighters, 298 So. 2d 478 (Fla. 1st DCA 1974).
48. Upon a finding by the trial court that a public agency violated a
provision of the Public Records Act in failing to permit a public record to be
inspected or copied, the plaintiff is entitled to an award of reasonable attorney’s

fees and costs. § 119.12, Fla. Stat.; Board of Trustees, Jacksonville Police & Fire
Pension Fund, 189 So. 3d 120, 128 (Fla. 2016).
RELIEF REQUESTED
Wherefore, Plaintiff respectfully requests an immediate video or telephonic
hearing pursuant to Section 119.11, Florida Statutes, following which Plaintiff
requests the Court enter a Writ of Mandamus:
A. Directing the Defendant to produce the records requested by Plaintiff;
B. Awarding Plaintiff reasonable attorney’s fees and costs; and
C. Granting such other and further relief as the Court deems appropriate.
______________________________
Elizabeth E. Bourdon, B.C.S.
Florida Bar No. 946591
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that this original document has been E-Filed with the
Clerk of Court through the E-Portal and a copy of the foregoing has been E-Served
to Kate Holmes, Assistant General Counsel of FDLE, this 30th day of November,
2020.
______________________________
Elizabeth E. Bourdon, B.C.S.
Florida Bar No. 946591
435 North Orange Avenue, Suite 400
Orlando, Florida 32801
bbourdon@circuit9.org;
bbourdon@me.com
(407) 797-1012
11/30/2020 F da F Ce e H e
The Florida Fusion Center
:// .fd e. a e. . /FFC/FFC.a 1/4

11/30/2020 F da F Ce e H e
:// .fd e. a e. . /FFC/FFC.a 2/4

Fusion Center Locations and Contact Information | Homeland Security 11/29/20, 5:36 PM
Official website of the Department of Homeland Security
U.S. Department of
Homeland Security
Fusion Center Locations and

Contact Information
State and major urban area fusion centers (/fusion-centers) (fusion centers) are owned and
operated by state and local entities, and are designated by the governor of their state.
In accordance with the Federal Resource Allocation Criteria (RAC) policy

(https://www.dni.gov/files/ISE/documents/DocumentLibrary/RAC_final.pdf) (PDF, 144 KB, 4 pages),
which defines objective criteria and a coordinated approach for prioritizing federal resource
allocation to fusion centers, the federal government recognizes these designations and has
a shared responsibility with state and local governments to support the national network of
fusion centers.
There are two types of fusion centers:
Primary Fusion Centers

Centers: A primary fusion center typically provides information
sharing and analysis for an entire state. These centers are the highest priority for the
allocation of available federal resources, including the deployment of personnel and
connectivity with federal data systems.
Recognized Fusion Centers
Centers: A recognized fusion center typically provides
information sharing and analysis for a major urban area. As the Federal Government
respects the authority of state governments to designate fusion centers, any
designated fusion center not designated as a primary fusion center is referred to as a
recognized fusion center.
Alabama (#)
https://www.dhs.gov/fusion-center-locations-and-contact-information Page 1 of 13
Alabama Fusion Center (/redirect?url=https%3A%2F%2Falabamafusioncenter.org%2F)

(Primary) – 334-517-2660
Alaska (#)
Alaska Criminal Intelligence Center (Primary) – 907-269-8900 / 855-692-5425
Arizona (#)
Arizona Counter Terrorism Information Center (http://www.azactic.gov/) (Primary) – 602-
644-5805 / 877-272-8329
Arkansas (#)
Arkansas State Fusion Center (Primary) – 501-618-8001/866-787-2332
California (#)
California State Threat Assessment Center (https://www.caloes.ca.gov/cal-oes-divisions/state-
threat-assessment-center) (Primary) – 916-636-2900
Central California Intelligence Center; Sacramento, CA (/redirect?

url=http%3A%2F%2Fwww.sacrtac.org%2F) (Recognized) – 916-808-8383 / 888-884-8383
Los Angeles Joint Regional Intelligence Center; Los Angeles, CA (/redirect?

url=http%3A%2F%2Fwww.jric.org%2F) (Recognized) – 562-345-1100
Northern California Regional Intelligence Center; San Francisco, CA (/redirect?

url=http%3A%2F%2Fwww.ncric.org%2F) (Recognized) – 866-367-8847
Orange County Intelligence Assessment Center; Orange County, CA

(http://www.ociac.ca.gov) (Recognized) – 714-289-3949
San Diego Law Enforcement Coordination Center (/redirect?url=https%3A%2F%2Fsd-

lecc.org%2F) ; San Diego, CA (/redirect?url=http%3A%2F%2Fsd-lecc.org%2F) (Recognized) –
858-495-7200
Colorado (#)
Colorado Information Analysis Center (https://www.colorado.gov/pacific/dhsem/ciac)
(Primary) – 877-509-2422
Connecticut (#)
Connecticut Intelligence Center (https://portal.ct.gov/DEMHS/Homeland-Security/Intelligence-
and-Counter-Terrorism) (Primary) – 860-706-5500
Delaware (#)
Delaware Information and Analysis Center (/redirect?
url=http%3A%2F%2Fwww.dediac.org%2F) (Primary) – 302-739-5996
District of Columbia (#)
The National Capital Region Threat Intelligence Consortium (/redirect?

url=https%3A%2F%2Fwww.ncrintel.org%2F) (Primary) – 202-481-3075
Florida (#)
Florida Fusion Center (/redirect?url=http%3A%2F%2Fwww.fdle.state.fl.us%2FFFC%2FFFC.aspx)
(Primary) – 850-410-7060
Central Florida Intelligence Exchange; Orlando, FL (/redirect?

url=http%3A%2F%2Fwww.ocso.com%2Fcfix%2F) (Recognized) – 407-858-3950
Southeast Florida Fusion Center; Miami, FL

(https://www.miamidade.gov/global/police/home.page) (Recognized) – 305-470-3880
Georgia (#)
Georgia Information Sharing and Analysis Center (https://investigative-
gbi.georgia.gov/specialized-units/ga-information-sharing-analysis-center) (Primary) – 404-561-
8497
Guam (#)
Mariana Regional Fusion Center (/redirect?
url=https%3A%2F%2Fmlrin.org%2Fdefault.aspx%2FMenuItemID%2F547%2FMenuGroup%2FMLRIN%2BPublic%2BH
(Primary) – 671-478-0281
Hawaii (#)
Hawaii State Fusion Center (http://dod.hawaii.gov/ohs/fusion-center) (Primary) – 808-628-
2336
Idaho (#)
Idaho Criminal Intelligence Center (http://www.isp.idaho.gov/icic/) (Primary) – 208-846-

7676
Illinois (#)
11/30/2020 Re a F Ce e
Net ork of Florida F sion Centers
:// .fd e. a e. . /FFC/Re a -F -Ce e 1/3

11/30/2020 Re a F Ce e

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25 messages
Ke K e e <kenjklippens ein@gmail.com> Sa , J l 11, 2020 a 3:55 PM

To: FloridaF sionCen er@fdle.s a e.fl. s
Cc: Noelle Llamas <noelleraellamas@gmail.com>
Dear C s odian of Records,
This is a req es nder he Florida S nshine La . A pdf cop of m req es is a ached belo .
Thank o for o r a en ion in his ma er,
Ken Klippens ein

Noelle Llamas
da ce e ec d e e . d
85K

To: CFIX@ocfl.ne
Cc: noelle Llamas <noelleraellamas@gmail.com>
Ken Klippens ein

Noelle Llamas
85K

To: n floridaf sion@fdle.s a e.fl. s
h :// a .g g e.c / a / /2? =f9fcbcffe8& e = & ea ch=a & e h d= h ead-f%3A1671951606599553943&d =1& = g-f%3A16719516065995 1/18
11/29/2020 G a -F da S h e La e e
Ken Klippens ein
Noelle Llamas
85K

To: nff @flcjn.ne
Cc: noelle Llamas <noelleraellamas@gmail.com>
Ken Klippens ein

Noelle Llamas
85K

To: con ac @nor heas floridaf sion.org
Ken Klippens ein

Noelle Llamas
85K

To: TBRIC@fdle.s a e.fl. s
Ken Klippens ein

Noelle Llamas
11/29/2020 G a -F da S h e La e e
85K

To: RSIX@fdle.s a e.fl. s
Ken Klippens ein

Noelle Llamas
85K
Ke K e e <kenjklippens ein@gmail.com> Mon, A g 17, 2020 a 7:11 PM

Cc: Noelle Llamas <noelleraellamas@gmail.com>, Be h Bo rdon <bbo rdon@me.com>
Respec f ll , I ha e e o recei e a response or e en an ackno ledgemen of receip for m S nshine La req es sen
o o ia email on J l 11 of his ear. If o co ld please respond and incl de an es ima ed imeline for comple ion, I
o ld grea l apprecia e i .
Sincerel ,
Ken Klippens ein
Noelle Llamas
> On J l 11, 2020, a 3:01 PM, Ken Klippens ein <kenjklippens ein@gmail.com> ro e:
>
> Dear C s odian of Records,
>
> This is a req es nder he Florida S nshine La . A pdf cop of m req es is a ached belo .
>
> <florida f sion cen ers records req es .pdf>
>
> Thank o for o r a en ion in his ma er,
>
> Ken Klippens ein
> Noelle Llamas

Sincerel ,
11/29/2020 G a -F da S h e La e e
Ken Klippens ein
Noelle Llamas
>
>
>
>
>
> Ken Klippens ein
> Noelle Llamas

Sincerel ,
Ken Klippens ein
Noelle Llamas
>
>
>
>
>
> Ken Klippens ein
> Noelle Llamas

To: nff @flcjn.ne
Sincerel ,
Ken Klippens ein
Noelle Llamas
11/29/2020 G a -F da S h e La e e
>
>
>
>
>
> Ken Klippens ein
> Noelle Llamas

Sincerel ,
Ken Klippens ein
Noelle Llamas
>
>
>
>
>
> Ken Klippens ein
> Noelle Llamas

To: CFIX@ocfl.ne
Sincerel ,
Ken Klippens ein
Noelle Llamas
>
>
>
11/29/2020 G a -F da S h e La e e
>
>
> Ken Klippens ein
> Noelle Llamas

Sincerel ,
Ken Klippens ein
Noelle Llamas
>
>
>
>
>
> Ken Klippens ein
> Noelle Llamas
RSIX F Ce e <RSIX@colliersheriff.org> Mon, A g 17, 2020 a 7:27 PM

To: Ken Klippens ein <kenjklippens ein@gmail.com>
Mr. Klippens ein,

Yo r req es has been rned o er o he Florida F sion Cen er. RSIX is a node of he Florida F sion Cen er, so heir
legal and records depar men ill handle his req es . Ho e er, RSIX does no main ain ca alogs of recei ed b lle ins or
prod c s dissemina ed from he cen er.
Thank o .
-----Original Message-----
From: Ken Klippens ein <kenjklippens ein@gmail.com>
Sen : Monda , A g s 17, 2020 7:12 PM
Cc: Noelle Llamas <noelleraellamas@gmail.com>; Be h Bo rdon <bbo rdon@me.com>
S bjec : Re: Florida S nshine La req es
E ernal Message: Please se ca ion hen opening a achmen s, clicking links, or repl ing o his message.
11/29/2020 G a -F da S h e La e e
Sincerel ,
Ken Klippens ein
Noelle Llamas
>
>
>
>
>
> Ken Klippens ein
> Noelle Llamas
This comm nica ion is confiden ial and ma con ain pri ileged informa ion in ended solel for he named addressee(s). I
ma no be sed or disclosed e cep for he p rpose for hich i has been sen . If o are no he in ended recipien , o
m s no cop , dis rib e or ake an ac ion ind ced b or in reliance on informa ion con ained in his message. Unless
e pressl s a ed, opinions in his message are hose of he indi id al sender and no of he Collier Co n Sheriff's Office.
If o ha e recei ed his comm nica ion in error, please no if he Collier Co n Sheriff's Office b emailing
helpdesk@colliersheriff.org q o ing he sender and dele e he message and an a ached doc men s. The Collier Co n
Sheriff's Office accep s no liabili or responsibili for an on ard ransmission or se of emails and a achmen s ha ing
lef he colliersheriff domain.

To: RSIX F sion Cen er <RSIX@colliersheriff.org>
I ha e no recei ed a response from he Florida F sion Cen er ei her; co ld o please pro ide me i h con ac
informa ion for hem?
As for he ca alogs, allo me o clarif ha m req es so gh i les of he in elligence prod c s ( in elligence prod c
me ada a e.g. doc men al i le, da e, e c. ). B ca alog es I mean o refer o hese i les in ha e er manner he are
s ored or main ained.
Please preser e all records rela ed o his req es ha ma be s bjec o dele ion.
Sincerel ,
Ken Klippens ein
Noelle Llamas
> On A g 17, 2020, a 6:27 PM, RSIX F sion Cen er <RSIX@colliersheriff.org> ro e:

>
> Mr. Klippens ein,
> Yo r req es has been rned o er o he Florida F sion Cen er. RSIX is a node of he Florida F sion Cen er, so heir
> Thank o .
>
>
> -----Original Message-----
> From: Ken Klippens ein <kenjklippens ein@gmail.com>
> Sen : Monda , A g s 17, 2020 7:12 PM
> To: RSIX@fdle.s a e.fl. s
> Cc: Noelle Llamas <noelleraellamas@gmail.com>; Be h Bo rdon <bbo rdon@me.com>
> S bjec : Re: Florida S nshine La req es
11/29/2020 G a -F da S h e La e e
>
> E ernal Message: Please se ca ion hen opening a achmen s, clicking links, or repl ing o his message.
>
>
>
> Respec f ll , I ha e e o recei e a response or e en an ackno ledgemen of receip for m S nshine La req es
sen o o ia email on J l 11 of his ear. If o co ld please respond and incl de an es ima ed imeline for comple ion,
I o ld grea l apprecia e i .
>
> Sincerel ,
> Ken Klippens ein
> Noelle Llamas
>
>> On J l 11, 2020, a 3:01 PM, Ken Klippens ein <kenjklippens ein@gmail.com> ro e:
>>
>> Dear C s odian of Records,
>>
>> This is a req es nder he Florida S nshine La . A pdf cop of m req es is a ached belo .
>>
>> <florida f sion cen ers records req es .pdf>
>>
>> Thank o for o r a en ion in his ma er,
>>
>> Ken Klippens ein
>> Noelle Llamas
>
>
>
>
> This comm nica ion is confiden ial and ma con ain pri ileged informa ion in ended solel for he named addressee(s).
I ma no be sed or disclosed e cep for he p rpose for hich i has been sen . If o are no he in ended recipien ,
o m s no cop , dis rib e or ake an ac ion ind ced b or in reliance on informa ion con ained in his message.
Unless e pressl s a ed, opinions in his message are hose of he indi id al sender and no of he Collier Co n Sheriff's
Office. If o ha e recei ed his comm nica ion in error, please no if he Collier Co n Sheriff's Office b emailing
>

Allo me o clarif ha m req es so gh i les of all in elligence prod c s ( in elligence prod c me ada a e.g.
doc men al i le, da e, e c. ) in he aforemen ioned imeframe. B ca alog es I mean o refer o hese i les in ha e er
manner he are s ored or main ained.
> On A g 17, 2020, a 6:13 PM, Ken Klippens ein <kenjklippens ein@gmail.com> ro e:
>
>
>
> Sincerel ,
> Ken Klippens ein
> Noelle Llamas
>
>
11/29/2020 G a -F da S h e La e e
>>
>>
>>
>>
>>
>> Ken Klippens ein
>> Noelle Llamas
>

To: CFIX@ocfl.ne
>
>
>
> Sincerel ,
> Ken Klippens ein
> Noelle Llamas
>
>
>>
>>
>>
>>
>>
>> Ken Klippens ein
>> Noelle Llamas
>

11/29/2020 G a -F da S h e La e e
>
>
>
> Sincerel ,
> Ken Klippens ein
> Noelle Llamas
>
>
>>
>>
>>
>>
>>
>> Ken Klippens ein
>> Noelle Llamas
>

To: nff @flcjn.ne
>
>
>
> Sincerel ,
> Ken Klippens ein
> Noelle Llamas
>
>
>>
>>
>>
>>
>>
>> Ken Klippens ein
>> Noelle Llamas
11/29/2020 G a -F da S h e La e e
>

>
>
>
> Sincerel ,
> Ken Klippens ein
> Noelle Llamas
>
>
>>
>>
>>
>>
>>
>> Ken Klippens ein
>> Noelle Llamas
>

>
>
>
> Sincerel ,
> Ken Klippens ein
> Noelle Llamas
>
11/29/2020 G a -F da S h e La e e
>
>>
>>
>>
>>
>>
>> Ken Klippens ein
>> Noelle Llamas
>
RSIX F Ce e <RSIX@colliersheriff.org> Mon, A g 17, 2020 a 8:24 PM

RSIX ill a emp o acq ire he con ac informa ion for his req es and ill for ard his secondar req es pon receip
of ha informa ion.
RSIX does no main ain a record in an form of he prod c s ha come in or ge dissemina ed o of he cen er.
Sen : Monda , A g s 17, 2020 8:18 PM
Sincerel ,
Ken Klippens ein
Noelle Llamas

>
> Mr. Klippens ein,
> Thank o .
>
>
> Sen : Monda , A g s 17, 2020 7:12 PM
11/29/2020 G a -F da S h e La e e
>
>
>
>
>
> Sincerel ,
> Ken Klippens ein
> Noelle Llamas
>
>>
>>
>>
>>
>>
>> Ken Klippens ein
>> Noelle Llamas
>
>
>
>
>

To: Eli abe h Bo rdon <bbo rdon@me.com>
Lol
---------- For arded message ---------

From: RSIX F Ce e <RSIX@colliersheriff.org>
Da e: Mon, A g 17, 2020 a 7:24 PM
S bjec : RE: Florida S nshine La req es
11/29/2020 G a -F da S h e La e e
RSIX ill a emp o acq ire he con ac informa ion for his req es and ill for ard his secondar req es pon receip
of ha informa ion.
RSIX does no main ain a record in an form of he prod c s ha come in or ge dissemina ed o of he cen er.
Sen : Monda , A g s 17, 2020 8:18 PM
Sincerel ,
Ken Klippens ein
Noelle Llamas
>
> Mr. Klippens ein,
11/29/2020 G a -F da S h e La e e
> Thank o .
>
>
> Sen : Monda , A g s 17, 2020 7:12 PM
>
>
>
>
>
> Sincerel ,
> Ken Klippens ein
> Noelle Llamas
>
>>
>>
>>
>>
11/29/2020 G a -F da S h e La e e
>>
>> Ken Klippens ein
>> Noelle Llamas
>
>
>
>
>
RSIX F Ce e <RSIX@colliersheriff.org> T e, A g 18, 2020 a 12:44 PM

Good af ernoon,
FDLE is processing he req es b o can reach o o he FDLE Office of General Co nsel a 850-410-7676, or o
p blicrecords@fdle.s a e.fl. s.
Thank o .
Sen : Monda , A g s 17, 2020 8:18 PM
11/29/2020 G a -F da S h e La e e
Sincerel ,
Ken Klippens ein
Noelle Llamas

>
> Mr. Klippens ein,
> Thank o .
>
>
> Sen : Monda , A g s 17, 2020 7:12 PM
>
>
>
>
>
> Sincerel ,
> Ken Klippens ein
> Noelle Llamas
>
>>
>>
>>
>>
>>
>> Ken Klippens ein
>> Noelle Llamas
>
>
>
>
>
11/29/2020 G a -F da S h e La e e
Florida Fusion Center (FCC)
Email: FloridaFusionCenter@fdle.state.fl.us
Telephone: (850) 410-7645
Website: http://www.fdle.state.fl.us/FFC/
Central Florida Intelligence eXchange (CFIX)

Email: CFIX@ocfl.net
Telephone: (407) 858-3950
Website: https://cfix.ocso.com/
Southeast Florida Fusion Center (SEFFC)

Email: seffc@mdpd.com & fusion@pbso.org
Telephone: (305) 470-3880
Website: http://www.miamidade.gov/Police/
Northwest Florida Fusion Center (NWFFC)

Email: nwfloridafusion@fdle.state.fl.us
Telephone: (850) 595-2082
Website: http://www.fdle.state.fl.us/NWFCC
North Florida Fusion eXchange (NFFX)

Email: nffx@flcjn.net
Website: http://northfloridafusionexchange.com/
Northeast Florida Fusion Center (NEFFC)

Email: contact@northeastfloridafusion.org
Telephone: (904) 256-5950
Tampa Bay Regional Intelligence Center (TBRIC)

Email: TBRIC@fdle.state.fl.us
Telephone: (813) 318-5600
Website: http://www.fdle.state.fl.us/ffc/TBRIC
Southwest Florida Fusion Center (RSIX)

Email: RSIX@fdle.state.fl.us
Dear Custodian of Records,
This is a request under the Florida Sunshine Law, Fla. Stat. § 119.011(12)
REQUESTER INFORMATION
Name: Ken Klippenstein

Position: DC Correspondent/The Nation
Address: 110 D St SE Apt 407, Washington, DC 20003
Email: kenjklippenstein@gmail.com
Phone: (202)510-1268
Name: Noelle Llamas

Address: 4420 Leola Lane, Orlando, FL 32812
Email: noelleraellamas@gmail.com
Phone: (407) 454-4984
RECORDS SOUGHT
I respectfully request copies of catalogues, indices or any other list of all intelligence products
received and/or generated by this fusion center, including but not limited to Suspicious Activity
Reports, Joint Intelligence Bulletins, Situational Awareness Reports, and threat assessments.
Please include records generated by this agency but also those received from other ones,
including state and federal partners (e.g., the Federal Bureau of Investigation, the Department of
Homeland Security, etc.).
You may limit your search to records produced between January 1, 2019 and the present day.
BACKGROUND
As part of a good faith effort to ensure that my request is as narrow as possible and will not be
unduly burdensome for you, please note the following: I am only requesting catalogues or any
other lists enumerating intelligence product metadata (e.g. document title, date, etc.), not the
intelligence products themselves.
FEE CATEGORY AND REQUEST FOR A FEE WAIVER
As a reporter and DC correspondent for The Nation magazine, I am a representative of the news
media. Disclosure of the requested information to me is in the public interest because it is likely
to contribute significantly to public understanding of the operations or activities of the
government and is not primarily in my commercial interest. Intelligence product catalogues
would provide the general public with information about what kinds of intelligence the
government is using their tax dollars to generate or access. It would also provide the general
public with document titles and control codes that they can use to subsequently request any of
the documents they may wish to learn more about. I have written extensively about national
security matters and will do the same here. My work has been referenced by The New York
Times, The Washington Post, The Los Angeles Times, The Atlantic, and other major media
outlets.
EXEMPTIONS AND SEGREGABILITY

If any responsive record or portion thereof is claimed to be exempt from production, the Florida
Sunshine Law provides that even if some of the requested material is properly exempt from
mandatory disclosure, all segregable portions must be released.
“(d) A person who has custody of a public record who asserts that an exemption applies
to a part of such record shall redact that portion of the record to which an exemption has
been asserted and validly applies, and such person shall produce the remainder of such
record for inspection and copying. (e) If the person who has custody of a public record
contends that all or part of the record is exempt from inspection and copying, he or she
shall state the basis of the exemption that he or she contends is applicable to the record,
including the statutory citation to an exemption created or afforded by statute.” Fla. Stat.
§ 119.07(d)
If documents are denied in part or in whole, please specify which exemption(s) is (are) claimed
for each passage or whole document denied. Please provide a complete itemized inventory and a
detailed factual justification of total or partial denial of documents. Specify the number of pages
in each document and the total number of pages pertaining to this request. In excising material,
please “black out” the material rather than “white out” or “cut out.” I expect, as provided by
FOIA, that the remaining non-exempt portions of documents will be released.
Please release all pages regardless of the extent of excising, even if all that remains are stationary
headings or administrative markings. In addition, I ask that your agency exercise its discretion to
release records which may be technically exempt, but where withholding serves no important
public interest.
Thank you for your time and attention in this matter.
Ken Klippenstein
Noelle Llamas
11/29/2020 G ail - ida hi e la e e
Ken Kli en ein <kenjkli en ein@gmail.c m>
florida sunshine law request

10 me age
Ken Kli en ein <kenjkli en ein@gmail.com> Sa , A g 22, 2020 a 2:19 AM

To: Flo idaF ionCen e @fdle. a e.fl.
Cc: Be h Bo don <bbo don@me.com>, Noelle Llama <noelle aellama @gmail.com>
Dea C odian of Reco d ,
Thi i a e e nde he Flo ida S n hine La . A df co of m e e i a ached belo .
Thank o fo o a en ion in hi ma e ,
Ken Kli en ein

Noelle Llama
FL ec d e e 2. df
55K

To: CFIX@ocfl.ne
Cc: Be h Bo don <bbo don@me.com>, Noelle Llama <noelle aellama @gmail.com>
Ken Kli en ein

Noelle Llama
FL ec d e e 2. df
55K

To: f ion@ b o.o g, effc@md d.com
Cc: Noelle Llama <noelle aellama @gmail.com>
Ken Kli en ein

Noelle Llama
FL ec d e e 2. df
55K
h :// ail.g gle.c / ail/ /2?ik=f9fcbcffe8& ie = & ea ch=all& e hid= h ead-f%3A1675705380728145235&d =1& i l= g-f%3A167570538072814 1/6
To: nff @flcjn.ne
Ken Kli en ein

Noelle Llama
FL ec d e e 2. df
55K

To: TBRIC@fdle. a e.fl.
Cc: noelle Llama <noelle aellama @gmail.com>
Ken Kli en ein

Noelle Llama
FL ec d e e 2. df
55K

To: RSIX@fdle. a e.fl.
Ken Kli en ein

Noelle Llama
FL ec d e e 2. df
55K
S hea Fl ida F i n Cen e < effc@md d.com> S n, A g 23, 2020 a 6:19 PM

To: Ken Kli en ein <kenjkli en ein@gmail.com>, "f ion@ b o.o g" <f ion@ b o.o g>
Hello,
Plea e end o e e o:
Miami-Dade Police De a men

P blic Info ma ion & Ed ca ion B ea
9105 NW 25 h S ee
Do al, FL 33172
iebinfo@md d.com
So hea Flo ida F ion Cen e

effc@md d.com
office: 305 470-3880
fa : 305 470-3895
CONFIDENTIALITY NOTICE: The info ma ion con ained in hi comm nica ion f om he So hea Flo ida Cen e
(SEFFC) ma con ain en i i e, legall i ileged, and/o confiden ial info ma ion and i no in ended fo hi d a
di ib ion i ho he e e a o al of he SEFFC. No o ion of hi doc men ho ld be elea ed o he media,
gene al blic o o he e onnel ho do no ha e a alid "need- o-kno ." Plea e add e e e fo f he
di ib ion, e ion , o commen o he SEFFC In elligence O e a ion Cen e (305-470-3880) o email a
effc@md d.com. If o a e no an in ended eci ien of hi an mi ion, he di emina ion, di ib ion, co ing o e
of he info ma ion i ic l ohibi ed. Pe on o o gani a ion iola ing di ib ion e ic ion ill be ohibi ed f om
ecei ing f e doc men and emo ed f om di ib ion li .
-----O iginal Me age-----

F om: Ken Kli en ein [mail o:kenjkli en ein@gmail.com]
Sen : Sa da , A g 22, 2020 2:23 AM
To: f ion@ b o.o g; So hea Flo ida F ion Cen e < effc@md d.com>
S bjec : flo ida n hine la e e
Ken Kli en ein

Noelle Llama
Ken Kli en ein <kenjkli en ein@gmail.com> S n, A g 23, 2020 a 6:19 PM

To: Eli abe h Bo don <bbo don@me.com>
---------- Fo a ded me age ---------

F om: S hea Fl ida F i n Cen e < effc@md d.com>
Da e: S n, A g 23, 2020 a 5:19 PM
S bjec : RE: flo ida n hine la e e
To: Ken Kli en ein <kenjkli en ein@gmail.com>, f ion@ b o.o g <f ion@ b o.o g>
CC: Noelle Llama <noelle aellama @gmail.com>
Hello,
Plea e end o e e o:
Miami-Dade Police De a men
P blic Info ma ion & Ed ca ion B ea

9105 NW 25 h S ee
Do al, FL 33172
iebinfo@md d.com
So hea Flo ida F ion Cen e
effc@md d.com
office: 305 470-3880
fa : 305 470-3895
CONFIDENTIALITY NOTICE: The info ma ion con ained in hi comm nica ion f om he So hea Flo ida Cen e
(SEFFC) ma con ain en i i e, legall i ileged, and/o confiden ial info ma ion and i no in ended fo hi d a
di ib ion i ho he e e a o al of he SEFFC. No o ion of hi doc men ho ld be elea ed o he media,
gene al blic o o he e onnel ho do no ha e a alid "need- o-kno ." Plea e add e e e fo f he
di ib ion, e ion , o commen o he SEFFC In elligence O e a ion Cen e (305-470-3880) o email a
effc@md d.com. If o a e no an in ended eci ien of hi an mi ion, he di emina ion, di ib ion, co ing o e
of he info ma ion i ic l ohibi ed. Pe on o o gani a ion iola ing di ib ion e ic ion ill be ohibi ed f om
ecei ing f e doc men and emo ed f om di ib ion li .
-----O iginal Me age-----
F om: Ken Kli en ein [mail o:kenjkli en ein@gmail.com]
Sen : Sa da , A g 22, 2020 2:23 AM
To: f ion@ b o.o g; So hea Flo ida F ion Cen e < effc@md d.com>
S bjec : flo ida n hine la e e
Ken Kli en ein
Noelle Llama
Ken Kli en ein <kenjkli en ein@gmail.com> Mon, A g 24, 2020 a 12:20 AM

To: iebinfo@md d.com
Cc: Noelle Llama <noelle aellama @gmail.com>, Be h Bo don <bbo don@me.com>
Plea e ee he e e belo .
Begin fo a ded me age:
kenjkli en ein@gmail.com
f ion@ b o.o g effc@md d.com

noelle aellama @gmail.com
Ken Kli en ein

Noelle Llama
2 a achmen
FL ec d e e 2-1. df
55K
FL ec d e e 2. df
55K
P blic Rec d Re e - Cen al Rec d < blic eco d e e @ b o.o g> Mon, A g 24, 2020 a 7:53 AM
To: "kenjkli en ein@gmail.com" <kenjkli en ein@gmail.com>
Cc: "noelle aellama @gmail.com" <noelle aellama @gmail.com>

Tracking Number:20-08-2730
Good day,
Your request for records has been received by the Palm Beach County Sheriff’s Of ce and a tracking
number has been assigned as noted above. This has been forwarded to the appropriate department for
processing. Someone from that department may be in contact with you to clarify any questions related to
your request, advise of possible associated costs, and review pickup/delivery options.
If you should have any questions or would like to check the status of your request, please feel free to
contact our Central Records Division by phone at (561) 688-3140, by email at
e ai ce a ec d @ b . g, or in person at one of our district of ces. The hours for our Central Records
Division at the Airport Center are Monday – Friday, 7:30am to 6:00pm.
Please be advised that given the current situation related to COVID-19, should a mandated quarantine or
any other mandate occur that will affect staf ng, there may be a delay in our response to your request.
** Please do not reply to this email. This inbox is not monitored and all messages to this address are
deleted. Please see above for our contact information. **
Thank you,
Records Production Division

Palm Beach County Sheriff’s Of ce
3228 G C b R ad
West Palm Beach, FL 33406

Begin fo a ded me age:
F m: Ken Kli en ein <kenjkli en ein@gmail.com>

Da e: A g 22, 2020 a 2:22:49 AM EDT
T : F ion <F ion@ b o.o g>, " effc@md d.com" < effc@md d.com>
S bjec : fl ida n hine la e e
**Thi email a en f om an e e nal (non-PBSO) o ce.**.
Ken Kli en ein

Noelle Llama
Re lie o hi me age a e o ed o an nmoni o ed mailbo . Sho ld o need o comm nica e i h he Reco d

de a men lea e i i h :// . b o.o g/inde .cfm?fa=cen al eco d fo addi ional con ac info ma ion.
Telephone: (850) 410-7645
Central Florida Intelligence eXchange (CFIX)

Email: CFIX@ocfl.net
Telephone: (407) 858-3950
Website: https://cfix.ocso.com/
Southeast Florida Fusion Center (SEFFC)

Email: seffc@mdpd.com & fusion@pbso.org
Telephone: (305) 470-3880
Website: http://www.miamidade.gov/Police/

Email: nwfloridafusion@fdle.state.fl.us Telephone: (850) 595-2082

Northeast Florida Fusion Center (NEFFC)

Email: contact@northeastfloridafusion.org
Telephone: (904) 256-5950
Tampa Bay Regional Intelligence Center (TBRIC)

Email: TBRIC@fdle.state.fl.us
Telephone: (813) 318-5600
Website: http://www.fdle.state.fl.us/ffc/TBRIC
Southwest Florida Fusion Center (RSIX)

Email: RSIX@fdle.state.fl.us
This is a request under the Florida Sunshine Law, Fla. Stat. § 119.011(12)
Address: 110 D St SE Apt 407, Washington, DC 20003
Phone: (202)510-1268
Name: Noelle Llamas

Phone: (407) 454-4984
RECORDS SOUGHT
I respectfully request copies of all fusion center intelligence products about or
concerning the George Floyd protests and subsequent civil unrest, including but
not limited to all intelligence products that contain any of the following keywords:
“George Floyd”, “protest”/“protester”, “demonstration”/“demonstrator”. “Antifa”,
“anarchist”, “activist”, “civil unrest”, “violent extremist”, “extremists”,
“looting”/“looters”, “black lives matter”, “monument”, “Covid”/“Covid-19”,
“coronavirus,” “Operation Legend”, “National Guard”, “pandemic”, and
“riot”/“rioter”.
You may limit your search to intelligence products dated between May 25, 2020
and August 22, 2020.
BACKGROUND
Please include intelligence products generated by the fusion center but also those
received, acquired or transmitted by them from other agencies, including state and
federal partners (e.g., the Federal Bureau of Investigation, the Department of
Homeland Security, etc.)
My request includes but is not limited to Suspicious Activity Reports, Joint
Intelligence Bulletins or any other intelligence bulletins, Situational Awareness
Reports or any other situation reports, and threat assessments.
Please preserve all records related to this request that may be subject to deletion.
As a reporter and DC correspondent for The Nation magazine, I am a
representative of the news media. Disclosure of the requested information to me is
in the public interest because it is likely to contribute significantly to public
understanding of the operations or activities of the government and is not primarily
in my commercial interest. Intelligence product catalogues would provide the
general public with information about what kinds of intelligence the government is
using their tax dollars to generate or access. It would also provide the general
public with document titles and control codes that they can use to subsequently
request any of the documents they may wish to learn more about. I have written
extensively about national security matters and will do the same here. My work has
been referenced by The New York Times, The Washington Post, The Los Angeles
Times, The Atlantic, and other major media outlets.

If any responsive record or portion thereof is claimed to be exempt from
production, the Florida Sunshine Law provides that even if some of the requested
material is properly exempt from mandatory disclosure, all segregable portions
must be released.
“(d) A person who has custody of a public record who asserts that an exemption
applies to a part of such record shall redact that portion of the record to which an
exemption has been asserted and validly applies, and such person shall produce the
remainder of such record for inspection and copying. (e) If the person who has
custody of a public record contends that all or part of the record is exempt from
inspection and copying, he or she shall state the basis of the exemption that he or
she contends is applicable to the record, including the statutory citation to an
exemption created or afforded by statute.” Fla. Stat. § 119.07(d)
If documents are denied in part or in whole, please specify which exemption(s) is

(are) claimed for each passage or whole document denied. Please provide a
complete itemized inventory and a detailed factual justification of total or partial
denial of documents. Specify the number of pages in each document and the total
number of pages pertaining to this request. In excising material, please “black out”
the material rather than “white out” or “cut out.” I expect, as provided by the
Florida Sunshine Law, that the remaining non-exempt portions of documents will
be released.
Please release all pages regardless of the extent of excising, even if all that remains
are stationary headings or administrative markings. In addition, I ask that your
agency exercise its discretion to release records which may be technically exempt,
but where withholding serves no important public interest.

Ken Klippenstein
Noelle Llamas
11/29/2020 G a -P b cR c d R I c P d c M ada a, Oc b 2020; M d a
Ken Klippenstein <kenjklippenstein@gmail.com>
P b c Rec d Re e f I e e ce P d c Me ada a, Oc be 2020; Med a

e e
1 me age
Ken Klippenstein <kenjkli en ein@gmail.c m> S n, Oc 11, 2020 a 9:07 PM

T : Fl idaF i nCen e @fdle. a e.fl. , inf @fdle. a e.fl.
D a S Ma a :
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a O b 11, 2020, aa I P Ja a 1, 2019,
O b 7, 2020.
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FFC Records Req est October 2020 req est 1.pdf

117K
:// a . .c / a / /2? = 9 cbc 8& = & a c =a & d= ad-a%3A 2837578955485136979& = -a%3A -4181356545915121568 1/1
Florida Department of Law Enforcement
2331 Phillips Road
Tallahassee, FL 32308
info@fdle.state.fl.us
Telephone: (850) 410-7645
October 11, 2020
This is a public records request under Chapter 119 of the Florida Statutes, otherwise known as
the Florida Sunshine Law.

Address: 360 W. Washington Ave, Unit #1114, Madison, WI
Phone: (202) 510-1268
Name: Noelle Llamas

Address: 4420 Leola Lane, Orlando, FL 32812 Email:
noelleraellamas@gmail.com
Phone: (407) 454-4984
RECORDS SOUGHT
I respectfully request a document log, alerts log, and/or product log of all Intelligence Products
produced or possessed by the Florida Fusion Center (FFC) from January 1, 2019, through
October 7, 2020. The document log, alerts log, and/or product log should include the
Intelligence Product metadata, such as the document number, the date of the document, the
document type, and the document topic or title, along with any additional metadata kept by FFC.
BACKGROUND
Please include intelligence products generated by the fusion center as well as those received,
acquired or transmitted by it from other agencies, including state and federal partners (e.g., the
Federal Bureau of Investigation, the Department of Homeland Security, etc.).
My request includes but is not limited to Suspicious Activity Reports, Threat Assessment,
Spotlight, Joint Intelligence Bulletins or any other intelligence bulletins, Situational Awareness
Reports or any other assessments, briefs, bulletins or reports.
It is believed the Intelligence Product metadata may be catalogued as a document log, alerts log
and/or product log, and would include all of those logs or any manner in which the metadata is
catalogued.

public with document titles and codes that they can use to subsequently request any of the
documents they may wish to learn more about. I have written extensively about national security
matters and will do the same here. My work has been referenced by The New York Times, The
Washington Post, The Los Angeles Times, The Atlantic, and other major media outlets.

If any responsive record or portion thereof is claimed to be exempt from production, the
Florida Sunshine Law provides that even if some of the requested material is properly exempt
from mandatory disclosure, all segregable portions must be released.
(d) A e h ha c d f a blic ec d h a e ha
an exemption applies to a part of such record shall redact that
portion of the record to which an exemption has been asserted and
validly applies, and such person shall produce the remainder of
such record for inspection and copying. (e) If the person who has
custody of a public record contends that all or part of the record is
exempt from inspection and copying, he or she shall state the basis
of the exemption that he or she contends is applicable to the
record, including the statutory citation to an exemption created or
aff ded b a e. Fla. S a . 119.07(d)
for each passage or whole document denied. Please provide a complete itemized inventory and
a detailed factual justification of total or partial denial of documents. Specify the number of
pages in each document and the total number of pages pertaining to this request. In excising
ma e ial, plea e black o he ma e ial a he han hi e o o c o . I e pec , a
provided by the Florida Sunshine Law, that the remaining non-exempt portions of documents
will be released.
Please release all pages regardless of the extent of excising, even if all that remains are
stationary headings or administrative markings. In addition, I ask that your agency exercise its
discretion to release records which may be technically exempt, but where withholding serves
no important public interest.
Ken Klippenstein
Noelle Llamas
11/29/2020 G ai - b ic ec d e e Oc be 21, 2020
p blic record req e Oc ober 21, 2020

1 a
Ken Klippenstein < @ a . > W ,O 21, 2020 a 6:06 PM

T :F aF C @ . a . . , @ . a . .
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A a a a , a O 21, 2020. P a a
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T a a a a .
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(202) 510-1268
FFC Records Request October 2020 request 2.pdf

119K
h :// ai .g g e.c / ai / /2?i =f9fcbcffe8& ie = & ea ch=a & e hid= h ead-a%3A -3432028403086216529& i = g-a%3A 5719986334840316827 1/1
2331 Phillips Road
Telephone: (850) 410-7645
October 21, 2020

Phone: (202) 510-1268
Name: Noelle Llamas

Phone: (407) 454-4984
RECORDS SOUGHT
I respectfully request the titles of all intelligence products generated by or for your agency.
Please pro ide copies of each in elligence prod c s i le as i firs appears in he doc men .
You may limit your search to titles for all intelligence products dated from January 1, 2019
through October 21, 2020.
BACKGROUND
Please include in your search titles of all intelligence products transmitted to your agency,
acquired by your agency from other agencies, or otherwise in the possession of your agency,
regardless of he her o r agenc s possession as emporar or o r agenc as merely
used as a pass-through of intelligence products from one agency to another.
Please note that in an effort to facilitate the timely production of records, this request does not
seek raw or otherwise unfinished intelligence, nor even the general contents of intelligence
prod c s. Ra her, his req es seeks onl each in elligence prod c s i le as i firs appears in
the document. In the unlikely event that no such title exists or if the title is not descriptive
(e.g. 20-FFC-418 ), please incl de a cop of he in elligence prod c s descrip i e s mmar .
Intelligence products include, but are not limited to, intelligence enterprise products, threat
assessments, significant incident reports, joint reports, intelligence notes, intelligence
bulletins, spotlights, situation reports, Guardian reports, situational awareness reports,
situational awareness bulletins, tactical intelligence reports, briefs, after action reports,
reports, summaries, etc.
As part of the intelligence cycle, intelligence agencies routinely collect information or data
that form the basis of what is commonly called intelligence products. Information is gathered
from various sources, which include human intelligence (HUMINT), signals intelligence
(SIGINT), imagery intelligence (IMINT), measurement and signatures intelligence
(MASINT), geospatial intelligence (GEOINT), and open source intelligence (OSINT),
etc. The collected intelligence is processed by analysts into a manner suitable for production
into finished intelligence products that are then disseminated within an agency or to other
agencies. Intelligence products might be a bulletin, a situational awareness report, a tactical
intelligence report, a joint report, a threat assessment, or some other similar document
type. These in elligence prod c s picall ha e a i le or shor descrip i e s a emen ha
summarizes the nature and content of the finished intelligence product.


aff ded b a e. Fla. Stat. § 119.07(d)
ma erial, please black o he ma erial ra her han hi e o or c o . I e pec , as
will be released.
Ken Klippenstein
Noelle Llamas
11/29/2020 G a - P b c Rec d Re e eF da F Ce e da ed Oc be 27, 2020
P b c Rec d Re e he F da F Ce e da ed Oc be 27, 2020

1
Ken Klippenstein < @ . > ,O 27, 2020 7:34 PM

:F F C @ . . . , @ . . . , @ . . .
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FFC Records Req est October 2020 req est 3.pdf

194K
:// a . e.c / a / /2? = 9 cbc e8& e = & ea c =a & e d= ead-a%3A 3465584065064232221& = -a%3A -1867512344978735296 1/1
2331 Phillips Road
publicrecords@fdle.state.fl.us
Telephone: (850) 410-7645
October 27, 2020

Address: 360 W. Washington Ave, Unit #1114, Madison, WI 53703
Phone: (202) 510-1268
Name: Noelle Llamas

Phone: (407) 454-4984
RECORDS SOUGHT
I respectfully request records sufficient to show the titles of intelligence products and all
corresponding metadata (e.g. a document number, document type, document date), which may be
in the form of a document log, alerts log, and/or product log, for all finished intelligence products
produced or possessed by the Florida Fusion Center from January 1, 2019, through October 27,
2020. An example of the records I am seeking is attached hereto as Appendix 1.
If no such record exists as detailed above and shown by example in Appendix 1, I then
alternatively respectfully request records sufficient to show the titles of all finished intelligence
products generated by or for your agency. Please provide copies of each intelligence product’s
title as it first appears in the document; should the title first appear on the document on a page
that contains information beyond the title, the additional information may be redacted so as to
provide only the title of the finished intelligence product.
BACKGROUND
catalogued.
seek raw or otherwise unfinished intelligence, nor even the general contents of finished
intelligence products.
Alternatively, this request seeks only each finished intelligence product’s title as it first appears
in the document. In the unlikely event that no such title exists or if the title is not descriptive (e.g.
“20-DHS-418”), please include a copy of the intelligence product’s descriptive summary,
redacting any information that is unrelated to the descriptive summary.
As part of the intelligence cycle, intelligence agencies routinely collect information or data that
form the basis of what is commonly called intelligence products. Information is gathered from
various sources, which include human intelligence (HUMINT), signals intelligence (SIGINT),
imagery intelligence (IMINT), measurement and signatures intelligence (MASINT), geospatial
intelligence (GEOINT), and open source intelligence (OSINT), etc. The collected intelligence is
processed by analysts into a manner suitable for production into finished intelligence products
that are then disseminated within an agency or to other agencies. Intelligence products might be
a bulletin, a situational awareness report, a tactical intelligence report, a joint report, a threat
assessment, or some other similar document type. These intelligence products typically have a
“title” or short descriptive statement that summarizes the nature and content of the finished
intelligence product


“(d) A person who has custody of a public record who asserts that
afforded by statute.” Fla. Stat. § 119.07(d)
material, please “black out” the material rather than “white out” or “cut out.” I expect, as
will be released.
Ken Klippenstein
Noelle Llamas
11/29/2020 G a - 10-29-20 RE: P b c Rec d Re e eF da F Ce e da ed Oc be 27, 2020
Ken Klippen ein <kenjklippen ein@gmail.com>
10-29-20 RE: P R R F aF C a O 27,

2020
1 message
P blic Reco d <PublicRecords@fdle.state.fl.us> Thu, Oct 29, 2020 at 9:21 AM

To: Ken Klippenstein <kenjklippenstein@gmail.com>
Cc: Public Information Office <Info@fdle.state.fl.us>
Good morning Mr. Klippenstein. This request was submitted to our office was previously received October 21, 2020 and
was docketed as PRR-2020-2811 and PRR-2020-2817. PRR-2020-2811 you sent the request to FDLE s Public
Information Office info@fdle.state.fl.us and PRR-2020-2817 you sent to the North Florida Fusion center nffx@flcjn.net.
If you have questions concerning your request, please contact us at (850) 410-7676 or publicrecords@fdle.state.fl.us, and
please include your PRR docket numbers we ve provided above.
Sincerely,
Office of General Counsel
Post Office Box 1489
Tallahassee, FL 32302-1489
(850) 410-7676
PublicRecords@fdle.state.fl.us
CONFIDENTIALITY NOTICE - The f a c a ed h e- a a f he F da De a e f La

E f ce e PRIVILEGED a d CONFIDENTIAL. I e ded f he e e f he e ( ) e a ed. If
ae he e ded ec e f h a , he d e a ,d b ,c g, he e f h
f a a c ea a f 119, F. S. a d c h b ed. If ha e ece ed h e a e ,
ea e c ac he e de ed a e .
F om: Ken Klippenstein <kenjklippenstein@gmail.com>

Sen : Tuesday, October 27, 2020 7:34 PM
To: Florida Fusion Center <FFCenter@fdle.state.fl.us>; Public Information Office <Info@fdle.state.fl.us>; Public Records
<PublicRecords@fdle.state.fl.us>
S bjec : Public Records Request to the Florida Fusion Center dated October 27, 2020
Greetings:
:// a . e.c / a / /2? = 9 cbc e8& e = & ea c =a & e d= ead- %3A1681892488036382043& = - %3A1681892488036382043 1/2
11/29/2020 G a - 10-29-20 RE: P b c Rec d Re e eF da F Ce e da ed Oc be 27, 2020
Attached please find my public records request to the Florida Fusion Center dated October 27, 2020. I have previously
submitted two requests this month to your agency and have received no response acknowledging receipt or processing of
my request.
I am a member of the media and have included the email address for media requests per instructions on the website, and
have now included the public records email request with the hope that it will result in acknowledgment of this receipt by
someone at their earliest convenience.
Thank you for your assistance in this matter.
Sincerely,
Ken Klippenstein
DC Correspondent/The Nation
(202) 510-1268
FFC Reco d Re e Oc obe 2020 e e 3.pdf

194K
11/29/2020 G a - 10-29-20 RE: P b c R c d R F da F C da d Oc b 27, 2020
10-29-20 RE: P R R F aF C a O 27,

2020
1 message
P blic Reco d <PublicRecords@fdle.state.fl.us> Thu, Oct 29, 2020 at 9:40 AM

To: Ken Klippenstein <kenjklippenstein@gmail.com>
Cc: Public Information Office <Info@fdle.state.fl.us>
Good morning Mr. Klippenstein. This request was submitted to our office was previously received October 21, 2020 and
was docketed as PRR-2020-2811 you sent the request to FDLE s Public Information Office info@fdle.state.fl.us.
If you have questions concerning your request, please contact us at (850) 410-7676 or publicrecords@fdle.state.fl.us, and
please include your PRR docket numbers we ve provided above.
Sincerely,
Office of General Counsel
Post Office Box 1489
Tallahassee, FL 32302-1489
(850) 410-7676
PublicRecords@fdle.state.fl.us
CONFIDENTIALITY NOTICE - The f a c a ed h e- a a f he F da De a e f La

E f ce e PRIVILEGED a d CONFIDENTIAL. I e ded f he e e f he e ( ) e a ed. If
ae he e ded ec e f h a , he d e a ,d b ,c g, he e f h
f a a c ea a f 119, F. S. a d c h b ed. If ha e ece ed h e a e ,
ea e c ac he e de ed a e .
F om: Ken Klippenstein <kenjklippenstein@gmail.com>

Sen : Tuesday, October 27, 2020 7:34 PM
To: Florida Fusion Center <FFCenter@fdle.state.fl.us>; Public Information Office <Info@fdle.state.fl.us>; Public Records
<PublicRecords@fdle.state.fl.us>
S bjec : Public Records Request to the Florida Fusion Center dated October 27, 2020
Greetings:
:// a . .c / a / /2? = 9 cbc 8& = & a c =a & d= ad- %3A1681893693362358495& = - %3A1681893693362358495 1/2
11/29/2020 G a - 10-29-20 RE: P b c R c d R F da F C da d Oc b 27, 2020
Attached please find my public records request to the Florida Fusion Center dated October 27, 2020. I have previously
submitted two requests this month to your agency and have received no response acknowledging receipt or processing of
my request.
I am a member of the media and have included the email address for media requests per instructions on the website, and
have now included the public records email request with the hope that it will result in acknowledgment of this receipt by
someone at their earliest convenience.
Thank you for your assistance in this matter.
Sincerely,
Ken Klippenstein
DC Correspondent/The Nation
(202) 510-1268
FFC Reco d Re e Oc obe 2020 e e 3.pdf

194K
:// a . .c / a / /2? = 9 cbc 8& = & a c =a & d= ad- %3A1681893693362358495& = - %3A1681893693362358495 2/2
Ken Klippens ein <kenjklippens ein@gmail.com>

e e
1
Ken Klippens ein < @ . > S ,O 11, 2020 9:10 PM

T : @ .
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A C 119 F S , O 11, 2020,

I P J 1, 2019, O 7, 2020.
( )
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DC C /T N
(202) 510-1268
NFFX Records Req es Oc ober 2020 req es 1.pdf

116K
:// a . .c / a / /2? = 9 cbc 8& = & a c =a & d= ad-a%3A -7071806189594824125& = -a%3A 3729600925819470116 1/1
P.O. Box 1489
Phone: (850) 410-8889
October 11, 2020

Phone: (202) 510-1268
Name: Noelle Llamas

Phone: (407) 454-4984
RECORDS SOUGHT
I respectfully request a document log, alerts log, or product log of all Intelligence Products
produced or possessed by the North Florida Fusion eXchange (NFFX) from January 1, 2019,
through October 7, 2020. The document log, alerts log, or product log should include the
document type, and the document topic or title, along with any additional metadata kept by
NFFX.
BACKGROUND
catalogued.

ma e ial, plea e black o he ma e ial a he han hi e o o c o . I e pect, as
will be released.
Ken Klippenstein
Noelle Llamas
11/29/2020 G a - P b c Rec d Re e I e e ce P d c Me ada a, Oc be 2020; Med a e e
Ke K i e ei < e i e ei @g ai .c >

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N h F ida F i eXcha ge < ff @flcj . e > M , Oc 12, 2020 a 11:21 AM

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S bjec : P b ic Rec d Re e f I e ige ce P d c Me ada a, Oc be 2020; Media e e
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11/30/2020 Public Records
Of ce f he Ge e al C el
P blic Rec d / Rec d C dia
http://www.fdle.state. .us/Criminal-Histor -Records/Obtaining-Criminal-Histor -Information (http://www.fdle.state. .us/Criminal-Histor -

Records/Obtaining-Criminal-Histor -Information.aspx)
Section 119.011(12), F.S.
Vie a more detailed g ide regarding FDLE s P blic Record Req ests
https://www.fdle.state. .us/OGC/Public-Records.aspx 1/4

Req est
Pro le




1 a
Ken Klippenstein < @ a . > W ,O 21, 2020 a 6:04 PM

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(202) 510-1268
NFFX Records Req est October 2020 req est 2.pdf

118K
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P.O. Box 1489
Phone: (850) 410-8889
October 21, 2020

Phone: (202) 510-1268
Name: Noelle Llamas

Phone: (407) 454-4984
RECORDS SOUGHT
BACKGROUND
regardless of he her o r agenc s possession as emporar or o r agenc as merel
type. These intelligence prod c s picall ha e a i le or shor descrip i e s a emen ha


ma erial, please black o he ma erial ra her han hi e o or c o . I e pect, as
will be released.
Ken Klippenstein
Noelle Llamas
11/29/2020 G a - P b c Rec d Re e Oc be 21, 2020
P blic Reco d Req e Oc obe 21, 2020

1 me age
N h F ida F i eXcha ge <nff @flcjn.ne > Th , Oc 22, 2020 a 10:28 AM

Repl -To: nff @flcjn.ne
To: "kenjklippen ein@gmail.com" <kenjklippen ein@gmail.com>
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11/29/2020 G a -P b cR c d R da d Oc b 27, 2020, NFFX
P b c Rec d Re e da ed Oc be 27, 2020, NFFX

1
Ken Klippens ein < @ . > ,O 27, 2020 7:54 PM

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193K
P.O. Box 1489
Phone: (850) 410-8889
October 27, 2020

Phone: (202) 510-1268
Name: Noelle Llamas

Phone: (407) 454-4984
RECORDS SOUGHT
produced or possessed by the North Florida Fusion eXchange (NFFX) from January 1, 2019,
through October 27, 2020. An example of the records I am seeking is attached hereto as
Appendix 1.
BACKGROUND
catalogued.


will be released.
Ken Klippenstein
Noelle Llamas
11/29/2020 G a -P b cR c d R da d Oc b 27, 2020, NFFX
P b c Rec d Re e da ed Oc be 27, 2020, NFFX

1 me age
N h F ida F i eXcha ge <nff @flcjn.ne > Wed, Oc 28, 2020 a 11:11 AM

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1301 North Palafox Street
Pensacola, FL 32501
Telephone: (850) 595-2082
October 11, 2020

Phone: (202) 510-1268
Name: Noelle Llamas

Phone: (407) 454-4984
RECORDS SOUGHT
I respectfully request a document log, alerts log, or product log of all Intelligence Products
produced or possessed by the Northwest Florida Fusion Center (NWFFC) from January 1, 2019,
through October 7, 2020. The document log, alerts log, or product log should include the
document type, and the document topic or title, along with any additional metadata kept by
NWFFC.
BACKGROUND
catalogued.

ma e ial, plea e black o he ma e ial a he han hi e o o c o . I e pec , a
will be released.
Ken Klippenstein
Noelle Llamas

Ken Klippens ein < @ a . > W ,O 21, 2020 a 6:03 PM
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NWFFC Records Req es Oc ober 2020 req es 2.pdf

118K
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Pensacola, FL 32501
Telephone: (850) 595-2082
October 21, 2020

Phone: (202) 510-1268
Name: Noelle Llamas

Phone: (407) 454-4984
RECORDS SOUGHT
BACKGROUND
regardless of he her o r agenc s possession as emporar or o r agenc as merel
type. These intelligence prod c s picall ha e a i le or shor descrip i e s a emen ha


ma erial, please black o he ma erial ra her han hi e o or c o . I e pect, as
will be released.
Ken Klippenstein
Noelle Llamas
11/30/2020 G ail - blic ec d e e Oc be 21, 2020
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11/29/2020 G a -P b cR c R a Oc b 27, 2020 NWFFC
P b cR c d R da d Oc b 27, 2020 NWFFC

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Pensacola, FL 32501
Email: nwfloridafusion@fdle.state.fl.us; info@fdle.state.fl.us
Telephone: (850) 595-2082
October 27, 2020

Phone: (202) 510-1268
Name: Noelle Llamas

Phone: (407) 454-4984
RECORDS SOUGHT
produced or possessed by the Northwest Florida Fusion Center (NWFFC) from January 1, 2019,
through October 27, 2020. An example of the records I am seeking is attached hereto as
Appendix 1.
BACKGROUND
catalogued.


will be released.
Ken Klippenstein
Noelle Llamas
Ke K e e < e e e @g a .c >

e e
M c e e Ba e - 3314 <Michelle.Ba en@c llie he iff. g> T e, Oc 27, 2020 a 10:23 AM
T : Ken Kli en ein <kenjkli en ein@gmail.c m>
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Cell: 239.253.6052
From: K K <kenjklippens ein@gmail.com>

Sen : F a , O 16, 2020 1:29 PM
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11/29/2020 G - HILLSBOROUGHSHERIFF S R U :: P043593-102720
HILLSBOROUGHSHERIFF Ser ice Req es Upda ed :: P043593-102720

2 me age
HILLSBOROUGHSHERIFF S pport <hill boro gh heriff@m c help.ne > Wed, Oc 28, 2020 a 2:18 PM
To: "kenjklippen ein@gmail.com" <kenjklippen ein@gmail.com>
--- Plea e re pond abo e hi line ---
RE: PUBLIC RECORDS REQUEST of Oc ober 27, 2020., Reference # P043593-102720.

Dear Ken Klippen ein,
The Hill boro gh Co n Sheriff' Office recei ed a p blic informa ion req e from o on Oc ober 27, 2020. Yo r
req e men ioned:
"RECORDS SOUGHT
I respectfully request records sufficient to show the titles of intelligence products and all corresponding metadata (e.g. a
document number, document type, document date), which may be in the form of a document log, alerts log, and/or product
log, for all finished intelligence products produced or possessed by the Tampa Bay Regional Intelligence Center (TBRIC)
from January 1, 2019, through October 27, 2020. An example of the records I am seeking is attached as Appendix 1to the
PDF document uploaded with this request.
If no such record exists as detailed above and shown by example in Appendix 1 of the uploaded PDF, I then alternatively
respectfully request records sufficient to show the titles of all finished intelligence products generated by or for your agency.
Please provide copies of each intelligence product’s title as it first appears in the document; should the title first appear on
the document on a page that contains information beyond the title, the additional information may be redacted so as to
BACKGROUND
Please include intelligence products generated by the fusion center as well as those received, acquired or transmitted by it
from other agencies, including state and federal partners (e.g., the Federal Bureau of Investigation, the Department of
My request includes but is not limited to Suspicious Activity Reports, Threat Assessment, Spotlight, Joint Intelligence
Bulletins or any other intelligence bulletins, Situational Awareness Reports or any other assessments, briefs, bulletins or
reports.
It is believed the Intelligence Product metadata may be catalogued as a document log, alerts log and/or product log, and
would include all of those logs or any manner in which the metadata is catalogued.
Please note that in an effort to facilitate the timely production of records, this request does not seek raw or otherwise
unfinished intelligence, nor even the general contents of finished intelligence products.
Alternatively, this request seeks only each finished intelligence product’s title as it first appears in the document. In the
unlikely event that no such title exists or if the title is not descriptive (e.g. “20-DHS-418”), please include a copy of the
intelligence product’s descriptive summary, redacting any information that is unrelated to the descriptive summary.
As part of the intelligence cycle, intelligence agencies routinely collect information or data that form the basis of what is
commonly called intelligence products. Information is gathered from various sources, which include human intelligence
(HUMINT), signals intelligence (SIGINT), imagery intelligence (IMINT), measurement and signatures intelligence (MASINT),
geospatial intelligence (GEOINT), and open source intelligence (OSINT), etc. The collected intelligence is processed by
analysts into a manner suitable for production into finished intelligence products that are then disseminated within an agency
or to other agencies. Intelligence products might be a bulletin, a situational awareness report, a tactical intelligence report, a
joint report, a threat assessment, or some other similar document type. These intelligence products typically have a “title” or
short descriptive statement that summarizes the nature and content of the finished intelligence product
Please preserve all records related to this request that may be subject to deletion."
:// . . / / /2? = 9 8& = & = & = - %3A1681820586077813781& =1& = - %3A168182058607781 1/3

11/29/2020 G - HILLSBOROUGHSHERIFF S R U :: P043593-102720
No record re pon i e. Refer o FDLE Florida F ion Cen er. If o ha e an q e ion in regard o hi req e , plea e
feel free o con ac m office a (813) 247-8060.
Sincerel ,
I abel Ca illo
Hill boro gh Co n Sheriff' Office
P blic Affair Office
Ken Klippenstein <kenjklippen ein@gmail.com> Wed, Oc 28, 2020 a 6:35 PM

To: HILLSBOROUGHSHERIFF S ppor <hill boro gh heriff@m c help.ne >
TBRIC doe n' prod ce and a e fini hed in elligence prod c ?
On Wed, Oc 28, 2020 a 2:18 PM HILLSBOROUGHSHERIFF S ppor <hill boro gh heriff@m c help.ne > ro e:
--- Plea e re pond abo e hi line ---
RE: PUBLIC RECORDS REQUEST of Oc ober 27, 2020., Reference # P043593-102720.

Dear Ken Klippen ein,
The Hill boro gh Co n Sheriff' Office recei ed a p blic informa ion req e from o on Oc ober 27, 2020. Yo r
req e men ioned:
"RECORDS SOUGHT
I respectfully request records sufficient to show the titles of intelligence products and all corresponding metadata (e.g. a
document number, document type, document date), which may be in the form of a document log, alerts log, and/or
product log, for all finished intelligence products produced or possessed by the Tampa Bay Regional Intelligence Center
(TBRIC) from January 1, 2019, through October 27, 2020. An example of the records I am seeking is attached as
Appendix 1to the PDF document uploaded with this request.
If no such record exists as detailed above and shown by example in Appendix 1 of the uploaded PDF, I then alternatively
respectfully request records sufficient to show the titles of all finished intelligence products generated by or for your
agency. Please provide copies of each intelligence product’s title as it first appears in the document; should the title first
appear on the document on a page that contains information beyond the title, the additional information may be redacted
so as to provide only the title of the finished intelligence product.
BACKGROUND
Please include intelligence products generated by the fusion center as well as those received, acquired or transmitted by it
from other agencies, including state and federal partners (e.g., the Federal Bureau of Investigation, the Department of
My request includes but is not limited to Suspicious Activity Reports, Threat Assessment, Spotlight, Joint Intelligence
Bulletins or any other intelligence bulletins, Situational Awareness Reports or any other assessments, briefs, bulletins or
reports.
It is believed the Intelligence Product metadata may be catalogued as a document log, alerts log and/or product log, and
would include all of those logs or any manner in which the metadata is catalogued.
Please note that in an effort to facilitate the timely production of records, this request does not seek raw or otherwise
unfinished intelligence, nor even the general contents of finished intelligence products.
Alternatively, this request seeks only each finished intelligence product’s title as it first appears in the document. In the
unlikely event that no such title exists or if the title is not descriptive (e.g. “20-DHS-418”), please include a copy of the
intelligence product’s descriptive summary, redacting any information that is unrelated to the descriptive summary.
As part of the intelligence cycle, intelligence agencies routinely collect information or data that form the basis of what is
commonly called intelligence products. Information is gathered from various sources, which include human intelligence
(HUMINT), signals intelligence (SIGINT), imagery intelligence (IMINT), measurement and signatures intelligence
(MASINT), geospatial intelligence (GEOINT), and open source intelligence (OSINT), etc. The collected intelligence is
processed by analysts into a manner suitable for production into finished intelligence products that are then disseminated
within an agency or to other agencies. Intelligence products might be a bulletin, a situational awareness report, a tactical
:// . . / / /2? = 9 8& = & = & = - %3A1681820586077813781& =1& = - %3A168182058607781 2/3

11/30/2020 G a - [Rec d Ce e ] Med a Re e :: P586688-102920
Ke K i e ei <ke jk i e ei @g ai .c >
[R C ]M R :: P586688-102920
Mia i-Dade P ice De a e < @ . > ,N 25, 2020 6:26 PM
:" @ . "< @ . >
--- P ---
Re: Media Re e f Oc be 29, 2020. Refe e ce #: P586688-102920
D C K K :
M -D P D ("MDPD") O 29, 2020.
S F F C ,R C :
"P rs ant to the req est, the So theast Florida F sion Center(SEFFC) does not keep logs or a master list of an of its prod cts; no
s ch loge ists. In an effort to pro ide o ith the information o are seeking, eha e attached a screenshot of o r SharePoint, that
sho s o the titles of theintelligence prod cts that ere prod ced b the SEFFC. P rs ant to the req est,the SEFFC does not ha e
the a thorit to release third part prod cts itho tconsent from the originating agenc ; moreo er, copies of third part prod cts
arenot retained b the SEFFC."
P P R R .
S , 305-471-2085.
S ,
L C
P O
M
, , , P R C .
:// a . e.c / a / /2? = 9 cbc e8& e = & ea c =a & e d= - %3A1684376673441534045& = - %3A1684376673441534045 1/1

Ken Klippenstein FOIA Lawsuit

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Filing # 117323728 E-Filed 11/30/2020 04:26:22 AM

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT

FLORIDA DEPARTMENT OF LAW ENFORCEMENT,

COMPLAINT FOR WRIT OF MANDAMUS

Plaintiff, Ken Klippenstein, through undersigned counsel and pursuant to

Mandamus directing the Defendant to produce public records requested by

Plaintiff. In support hereof, Plaintiff states:

FACTS ON WHICH PLAINTIFF RELIES FOR RELIEF

1. Plaintiff, Ken Klippenstein, is a journalist and is the DC Correspondent

2. Defendant, Florida Department of Law Enforcement (FDLE), oversees

According to the Department of Homeland Security, a primary fusion center

3. The Central Florida Intelligence Exchange (CFIX) and the Southeast

4. The Tampa Bay Regional Intelligence Center (TBRIC) is a regional node

(Composite Exhibit C); it is unknown which of these may be a certified node of

FFC, though RSIX stated it is a node via email. Exhibit D.

request attached to the email as a PDF document, seeking “copies of catalogues,

Intelligence Bulletins, Situational Awareness Reports, and threat assessments.

seeking the status of Plaintiff’s request as well as an estimated date of completion.

the July emailed records request.

records request attached as a PDF document seeking all intelligence products

related to George Floyd protests, including a list of keywords. Composite Exhibit

responsive records to Plaintiff’s July 11, 2020 request. Composite Exhibit G. No

fusion center produced responsive documents to Plaintiff’s August 22, 2020

request; as a result of the responsive documents by CFIX, Plaintiff decided to

The October Florida Fusion Center (FFC) Requests

product log of all Intelligence Products produced or possessed by the Florida

response to this email.

9. Based upon a response from a fusion center (RSIX), on October 21,

FFC as a PDF attachment, which combined the October 11 and October 21

requests into one request, seeking the following:

I respectfully request records sufficient to show the titles of intelligence

If no such record exists as detailed above and shown by example in

Additionally, Plaintiff’s email noted he had not received an acknowledgment of his

October 21, 2020 and docketed as PRR-2020-2811 and PRR-2020-2817, noting

and it was docketed as PRR-2020-2811 and was sent to FDLE’s Public

Information Office (info@fdle.state.fl.us). Composite Exhibit K contains both

email replies from October 29, 2020.

12. To date Plaintiff has received no responsive documents from FDLE

a clearer request for the same records.

13. Defendant’s unjustified delay in producing the records sought

constitutes an unlawful refusal to provide access to public records under Chapter

The October North Florida Fusion eXchange (NFFX) Requests

Intelligence Products produced or possessed by the North Florida Fusion eXchange

Exhibit L is the email and its PDF attachment.

15. On October 12, 2020, NFFX emailed acknowledging receipt of

of the General Counsel Public Records/Records Custodian web page. Composite

prior records request. Composite Exhibit N.

request in the same manner it responded on October 12, 2020. Exhibit O.

NFFX as a PDF attachment, which combined the October 11 and October 21

requests into one request, seeking the following:

I respectfully request records sufficient to show the titles of intelligence

If no such record exists as detailed above and shown by example in

Composite Exhibit P is a copy of the email and its PDF attachment.

19. On October 28, 2020, NFFX emailed a response acknowledging receipt

and October 22, 2020. Exhibit Q.

20. To date Plaintiff has received no responsive documents from NFFX or

a clearer request for the same records.

21. Defendant’s unjustified delay in producing the records sought

constitutes an unlawful refusal to provide access to public records under Chapter

The October Northwest Florida Fusion Center (NWFFC) Requests

Intelligence Products produced or possessed by the Northwest Florida Fusion

prior records request. Composite Exhibit S.

24. On October 22, 2020, NWFFC responded to Plaintiff’s October 21,