NYPD Drones - 2014.11.20 Notice of Petition

8/10/2019 NYPD Drones - 2014.11.20 Notice of Petition

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

--------------------------------------------------------------------)

SHAWN

MUSGRAVE,

Petitioner,

-against-

NEW YORK CITY POLICE DEPARTMENT, and

THE CITY OF NEW YORK,

Respondents.

--------------------------------------------------------------------)

NOTICE OF

PETITION

PLEASE

T KE

NOTICE that upon the affirmation

of

Gillian Cassell-Stiga

of

Rankin Taylor, PLLC, sworn to on November

lJ_

2014, and the attached exhibits, the

undersigned petitioner will request this Court, at 9:30 in the forenoon on the

day

of

located at 60 Centre Street, New York, New York, in the Motion Support Courtroom, IAS Part

Room 130, for an Order and Judgment grariting the following relief

to

the undersigned

petitioner:

2 Ordering the respondents pay the reasonable litigation costs

I D 1 < : t l 8 1 1 1 8 f . t ~ M r i ~ i ~

fees pursuant to Public Officers Law Article 6 89 4)c; and

3 Other such relief as the Court finds just and proper

. Dated: New York, New York

J


2/30

November 2014

To:

New

York City Police Department

One Police Plaza, Room 1406

New

York, New York 10038

The City ofNew York

100 Church Street

New York,

New

York 10007

Supreme Court, State ofNew York

County ofNew York

Motion Submission Term, Room 130

60 Centre Street

New York, New York 10007

Respectfully submitted,

illian Cassell-Stiga

Rankin Taylor, PLLC

Park Place, Suite 914


t

212-226-4507

f

212-658-9480

e:

[email protected]


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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - {

SHAWN MUSGRAVE,

Petitioner,

-against-

NEW YORK CITY POLICE DEPARTMENT, and

THE CITY OF NEW YORK,

Respondents.

--------------------------------------------------------------------){

VERIFIED PETITION PURSUANT

TO RTICLE 78 OF THE NEW

YORK PR CTICE L W

AND

RULES

'

IndexNo.

f

I, GILLIAN CASSELL-STIGA, an attorney duly licensed to practice law in the Courts

of

the State

of

New York, does hereby verify and affirm, under the penalties of perjury, that the

following is true and accurate:

PRELIMIN RY

STATEMENT

1

Pursuant to the Freedom of Information Law ( FOIL ) and Article 78 of he New

York Civil Law and Rules, the undersigned, petitioner Shawn Musgrave

( Mr.

Musgrave ),

seeks an order directing respondents New York City Police Department ( NYPD ) and The City

of New York ( CITY ) to disclose all NYPD documents and correspondence concerning

remotely piloted aircraft, unmanned aerials, unmanned aerial vehicles, and/or unmanned aerial

systems.

2. Since respondent NYPD has steadfastly refused to respond to the Mr. Musgrave's

FOIL request, and since Mr. Musgrave has exhausted all available administrative remedies, the

Mr. Musgrave respectfully requests the Court order respondents to produce the documents

sought in the Request.


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BACKGROUND

3. On June 9, 2014,

Mr.

Musgrave sent a FOIL request to the FOIL Unit within the

NYPD. See Request from Shawn Musgrave dated June 9, 2014 to the NYPD FOIL Unit,

attached hereto as Exhibit A.

4. The Request sought disclosure o memorandum, e-mails, correspondence, and

other documents or records related to agency use o aerial drones, remotely piloted vehicles

(RPVs), remotely piloted aircraft (RPAs), unmanned aerials (UAs), unmanned aerial vehicles

(UAVs), and/or unmanned aerial systems (UASs) (hereinafter drones ) from January, 2005

unto the present. This Request includes, but is not limited to, documents concerning or related to

the policy, acquisition, use, and training

o

personnel. See Request, Exhibit A, at 1-5.

5. June 24th, 2014, Mr. Musgrave received a letter from the NYPD Records Access

Officer Lieutenant Richard Mantellino ( Office Mantellino ) acknowledging the receipt o his

request, assigning

it

file nun1ber LBF #14PL105084, and informing him further review would be

required and a response estimated in the next 20 days. See Acknowledgment from Officer

Mantellino dated June 24th 2014, attached hereto as Exhibit B.

6. July 18, 2014, Mr. Musgrave then received a letter from Officer Mantellino

informing him the request was denied. See Letter Denial from Officer Mantellino dated July 18,

2014, attached hereto as Exhibit C. The letter stated that Mr. Musgrave could appeal the

decision in writing within 30 days o he date o he letter. See Letter Denial, Exhibit C.

7.

August 5, 2014,

n

compliance with the NYPD's internal procedures, Mr.

Musgrave sent a letter to Jonathan David, Records Access Appeals Officer for NYPD,


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administratively appealing the denial and requesting the production of the documents sought. See

Administrative Appeal to respondent NYPD dated August 5 2014, attached hereto as Exhibit D.

8. August 22, 2014,

Mr.

Musgrave received a letter from Officer David stating that

his appeal was denied. See Appeal Denial from Officer David dated September

19

2014,

attached hereto as Exhibit

E.

9.

Respondent NYPD should have made a determination regarding the

Administrative Appeal within

10

business days

of

receipt by the agency. See 34 R.C.N.Y. 1-

06(d). Further, the NYPD s blanket denial

of Mr.

Musgrave s request sweepingly

claims

the

applicability

of

exemptions without providing a justification

of

the required specificity.

10.

The NYPD has failed

to

provide a single document in response to

Mr.

Musgrave s

request.

JURISDICTION AND VENUE

11. This proceeding pursuant to Article 78

of

the Civil Practice Law and Rules

is

the

proper mechanism for seeking judicial review

of

a state agency s determination with respect to a

FOIL request. N.Y. Pub. Off 89(4)(b).

12. Respondent NYPD is a state agency subject to the FOIL.

t

is also an agency

of

respondent CITY.

13. The undersigned has exhausted respondent NYPD s internal appeals process, and

the instant petition

has

been filed within the four-month period thereafter specified in

C.P

.L.R.

217(1). See

su:gra i i

3-10.

14. Both respondents NYPD and CITY have their central offices located in the

County ofNew York. Venue therefore is proper in this Court. C.P.L.R. 7804(a), 506(b).


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BASIS FOR RELIEF

15. When a State or municipal agency makes a determination which is arbitrary and

capricious, the aggrieved party may challenge that determination in

n

Article

78

petition.

C.P.L.R.

7803(3).

16. In rejecting both the original request and

Mr.

Musgrave's appeal, the

NYPD

has

failed to provide an articulation of a particularized and specific justification for denying access

as required to establish the applicability

of

an exemption, instead merely reciting the statutory

phrasing

of

the exemption.

Capital Newspapers

Div of

Hearst Corp.

v

Burns,

67 N.Y.2d 562

(N.Y. 1986);

DJL Restaurant Corp. v Department ofBldgs., 273

A.D.2d 167 (N.Y.

App.

Div.

1st Dep't 2000) ( affidavits merely repeating the statutory phrasing

of

an exemption are

insufficient to establish the requirement ofparticularity ).

17. Where the good faith invocation

of

the statue is called into question,

the

court

should make an in camera inspection

of

the requested documents.

City ofNewarkv. Law Dep t of

NY.

305 A.D.2d 28

N.Y.

App. Div. 1st Dep't 2003).

REQUEST OR RELIEF

WHEREFORE, the undersigned petitioner respectfully requests this Court enter

an Order either directing respondent NYPD to disclose all documents within the scope

of

the

Request or directing respondent NYPD to submit for in camera inspection copies of all

documents within the scope

of

the Request, for determination by the Court as to the propriety

of

exempting or disclosing saine under the FOIL; awarding the undersigned his legal fees and


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expenses incurred in making the instant petition for relief; and awarding such other and further

relief as the Court may deem

just

and proper.

Dated:

To:

New York, 1 - f ~ Y York

November

J..j

2014

New York City Police Department

One Police Plaza, Room 1406

New

York,

New

York 10038

The City ofNew York

100 Church Street


Supreme Court, State

of

New York

County

of

New York

Motion Submission Term, Room 130

60 Centre Street


Respectfully submitted,

Giiran Cassell-Stiga

Rankin Taylor, PLLC

11 Park Place, Suite 914


t 212-226-4507

f: 212-658-9480

e: [email protected]


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ATTORNEY S VERIFICATION

I, Gillian Cassell-Stiga, an attorney duly admitted to practice before the Courts of he

State of

New

York, affirm the following to be true under the penalties

of

perjury:

I

am

the attorney

of

record for the Petitioner.

I have read the annexed Petition and know the contents thereof, and the same are true to

my

knowledge, except those matters therein which are stated to be alleged upon information nd

belief, and as to those matters I believe them to be true. y beliefs, as to those matters therein

not stated upon knowledge, are based upon facts, records, and other pertinent information

contained in my files.

This verification is made by

me

because Petitioner does

not

reside

in

the county where I

maintain

my

offices.

Dated:

New

York,

New

York

November / q 201.4


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Records Access Officer

NYC Police Department

F 0 1 L Unit - Legal Bureau

One Police Plaza, Room 110-C

New York, New York I 0038

June 9, 2014

To Whom

t

May Concern:

Pursuant to the New York State Freedom o lnfonnation Law ( 1977 N. Y. Laws ch. 933), J hereby request the

following records:

All documents created from January 2005 to the date this request is processed related to the agency's use

o

aerial

drones, remotely piloted vehicles (RPVs), remotely piloted aircraft (RPAs), unmanned aerials (UAs), unmanned

aerial vehicles (UAVs), and/or unmanned aerial systems (UASs)(hereinafter drones ).

Please note that this

is

the third time we have submitted a FOIL request for this type

o

documentation (see 20 I3-

PL-100448 and 20 I 3-PL-7978). Previously, the NYPD FOIL Unit has invoked personal privacy as well as

disclosure o law enforcement techniques to justify rejections. However, the NYPD's recent statements to the City

Council's Public Safety Committee eliminate both considerations: the Commissioner very publicly confirmed that

the department

is

researching drones, and Deputy Commissioner Miller

indicaK


11/30


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Filed via MuekRock.eom

E-mail (Preferred): 11991

For mailed responses, please address (see note):

MuckRock News

DEPT MR 99

PO Box 55819

Boston,

MA

02205-5819

PLEASE NOTE the new address as well as the fact that improperly addressed (i.e., with the requester s name rather

than MuckRock News) requests might be returned by the USPS as undelivernble.


13/30


14/30

E

.O.Ll .. l

111

1

nc

Box l ()

t5ostnn \

t i R

1 t

l L.

letter

this n

Oll ) J 6

14

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~ ~ X-l S


15/30


16/30

Room

I IOC

One Polin:

Plaza

New

Julv

8. 2014

RE: FIN

i\

F#14PL 05084

letter is in further response to your letter

June t . O

pursuant to the Freedom In format iun Law ( FO l L

time frame from

i

to

uest is duplicati' e f your prior requc:-:ts

J

JPL l 07978

addition,

your

request

is

the

reasons

final

L Scciion

n

that

may

he

in

..:xistcncc.

In addition,

the requc:sl

is

denied

umkr

POL

seek could endanger

t l K ~

life or

ng

to unmanned

in the

for

disclosure you

Moreover. the request

is

to the extent rcspons11e ir n existence.

would constitute intra-agency materi comprised of preliminary infurmatinn

assessments arc deliberative and pre-decisional

in

nature. :\econlingly. disclosure is not

required pursuant to POL Section S ) g).


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18/30


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Jonathan David

Records Access Appeals Officer


One Police Plaza - Room 1406

New York. NY I 0038-1497

August 5, 2014

Mr. David,

This is an appeal for the blanket rejection ofFOIL l4PLl05084.

Despite the NYPD FOIL Unit's now third assertion, at bare minimum a portion of he requested documents are

squarely within the public domain. The remaining justifications for denying the request are irrelevant, lack factual

grounding and are asserted without substantiation.

Foremost, that I have submitted related FOIL requests in the past has no bearing on the present request for material,

particularly given that the current request incorporates additional information regarding the department's research

into unmanned aerial vehicles. In particular, I cited the Commissioner's recent statements before the City Council's

Public Safety Committee, with which the Commissioner confirmed that the NYPD is investigating UAVs for

department use. This additional guiding information clearly sets this request as distinct from previous requests.

Furthermore, the NYPD's justification for rejecting my request has evolved substantially with each subsequent

request. Beginning with a puzzling determination that personal privacy barred releasing documents in response to

my first request, the NYPD has rejected my previous two requests on highly suspect grounds, and does so again

in

response to my latest request. The appeal determination for my second appeal was grounded foremost in my failure

to file a timely appeal for the first request, rather than on substantive issues. The NYPD FOIL Unit cannot invoke

irrelevant justifications for denying requests.

Similar logical inconsistencies and assertions without justification are at play in this latest request. The foremost

justification for appeal is that this request

is

duplicative

of

my previous two requests. Given the additional

information, passage

of

ime and procedural issues

in

filing my first request, this foremost grounds for denial

is

utterly irrelevant

in

the present FOIL request.

Next, Lt. Mantellino relies on the appeal determination for l3PL107978, which again was errantly grounded

primarily

in

the denial ofmy first appeal, which was due to procedural rather than substantive concerns.

Next, the request denial indicates that releasing documents would reveal non-routine techniques. As asserted

previously, Mayor Bloomberg and now two NYPD Commissioners have publicly disclosed details

of

the

department's investigation into unmanned aerial vehicle technology. There is thus very thin justification to assert that

all documents must

e

withheld

in

the interest ofprotecting non-routine information.

Lt. Mantellino asserts without support that disclosing these records might endanger the life or safety

of

persons in

New York City. Dozens

of

other law enforcement agencies across the country have released documents related to

their use

of

or research into UAVs. This includes federal agencies such as the Bureau ofCustoms and Border

Protection and the FBI that have already deployed UAVs

in

operations. The assertion that releasing documents

might endanger safety or lives requires substantial backing and evidence that Lt. Mantellino has utterly failed to

provide.


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Finally, the rejection letter indicates that some of he documents constitute intra-agency materials comprised of

preliminary information and/or assessments that are deliberative and pre-decisional in nature. While this may e

true for portions of he documents, the Mayor and two NYP Commissioners have publicly stated the department's

intention to pursue

U V

technology. This decision has squarely been taken. While some documents may comprise

pre-decisional materials, there is much that would feasibly not fall within this category.

In light of the above, I respectfully insist

that

this FOIL request be remanded back to the NYPD FOIL Unit for

substantive response and release of responsive documents.

Best,

Shawn Musgrave

MuckRock


21/30

Shawn Musgrave

MuckRock News

DEPT MR 7109

P.O.

Box 55819

Boston.

MA 0220 5

Dear

Mr

Musgrave:

POLICE DEPARTMENT

LEGAL

BUREAU

F.0.1.L. Unit, Room 11

OC

One Police Plaza

New

York,

New

York

10038

July 18, 2014

RE:

FREEDOM

OF

INFORMATION

LA\V

REQUEST:

LSF

14PLl05084

This letter is in further

response

to your letter dated June 9, 2014, requesting disclosure,

pursuant to the Freedom of Information Law ("FOIL"), of various records related to unmanned

aerial vehicles.

That part

of

your request covering the time frame from January,

2005

to October

22,

2013 is denied

because your

instant request is duplicative

of

your prior requests that were

assigned

file

numbers 13PL100448 and 13PLI07978.

In

addition, your request is denied in its entirety for the reasons that were set forth

in

the

February 7,

2014

final

determination of

your appeal under file number 13PL107978, and for the

reasons stated hclow.

Your request

is

denied under

Puhlic Officers I.aw

(POL)

Section 87(2)(e)(iv), which

exempts from disclosure law cnfon.:erncnt records that

re\eal

non-routine investigati\c

tcclrniqw.:s or procedures.

This

exemption applies

to lav

enforcement records that descrihc the

workings

of noYcl

systems that could be used

to

address public saJcty emergencies. inciuding

possible terrorist attacks

and

criminal

ads.

Accordingly. the

disclosure

you seek. were

it to

be

made.

would enahlc miscreants to tailor their conduct

in

anticipation of law enforn;ment efforts

to prc\ent criminal activities. and would therefore not be required under

FOIL

as to any records

that may be

in cxistem:e.

In

addition. the request

is

denied under

POL

Section

X7 2) f)

because

the

disclosure

you

seek

could endanger thc

lit\:

or sakty of

pt.:rsons

in

New York ( 'ity.

\1oremer.

the request is denied to

the

extent that responsive records.

ir n

existence.

would constitute intra-agency materials comprised of preliminary information andior

assessments that are dcliberatin: and pn.:-decisiona in nature. Accordingly. disc losure is not .

requin..:d pursuant lo POL Section S7{2) g).


22/30

You may appeal this decision in writing, within thirty 30) days of the date of this

letter. Any appeal should he addressed to Mr. Jonathan David, Records Access Appeals

Officer, NYPD, ne Police Plaza, Room 1406, New York, NY 10038-1497.

\

m

i } f _ : r e l ~

)

d t )

~

if

-f/

/U v

)

J

i

R i c h a r ~ n t c l l i n o

Lieutenant

Records Access Officer


23/30

On July 22, 2014:

Lt Mantellino -

I hereby

once

again assert

my

right to receive

FOIL

responses

by

electronic mail, rather than

by

postal mail.

Per

89(3)(b), which states

that All

entities shall, provided such entity has reasonable means available, accept

requests

for

records submitted in the form

ofclectronic

mail and shall respond

to

such requests by electronic mail...

to the extent practicable

..

''. this is a legal obligation or

NYPD to

comply with my request.

Please confirm that responses for this request will be sent by electronic mail.

Shawn

On

July 22, 2014:

Lt. Mantellino -

Per the

attached, NYPD was slated

to

respond to issue a determination for this request by July 18, 2014. To date, no

such response has been received. Please advise.

Best,

Shawn

On July

19, 2014:

The

request has been rejected, with

the

agency stating that the information

or

document(s) requested are exempt

from disclosure.

On July 15, 2014:

A letter stating that the request appeal has been rejected.

On

July 3, 2014:

Jonathan David

Records Access Appeals Officer


One

Police

Plaza

- Room 1406

New York,

NY

10038-1497

July 3, 2014

Mr. David:

Under the provisions

of

he New York Freedom oflnformation Law, Article 6 89(4)(a)

of

he Public Officers Law, I

hereby request an internal appeal

of

your failure to respond to my FOIL request dated June 9, 2014. A copy of my


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request is attached, along with a letter showing your office received the attached request on June l

6,

2014. The

FOIL Unit did not respond

or

acknowledge the attached request within the five (5) business days as required by

statute, therefore,

the

request has been constructively denied and an internal appeal is appropriate.

Please notify

me

of

he results

of

the appeal without delay.

If

for

any

reason

any

portion

of

my request is again denied, please inform me

of

he reasons for

the

denial in writing

within

the

ten

(10)

days as required by statute.

Sincerely,

Shawn Musgrave

MuckRock

Attachments

On June 24, 2014:

To Whom It May Concern:

I wanted to follow up on the following Freedom

of

Information request, copied below, and originally submitted on

June 9, 2014. Please let

me

know when 1 c n expect to receive a response, or

if

further clarification is needed.

Thank you for

your

help.

On

June 24, 2014:

An

acknowledgement letter, stating the request

is

being processed.

On

June 9, 2014:

To Whom

t

May Concern:

Pursuant to the

New

York State Freedom

of

Information Law (l 977 N.Y. Laws ch. 933), I hereby request the

following records:

All documents created from January 2005 to the date this request is processed related to the agency's use

of

aerial

drones, remotely piloted vehicles (RPVs), remotely piloted aircraft (RPAs), unmanned aerials (UAs), unmanned

aerial vehicles (UAVs), and/or unmanned aerial systems (UASs)(hereinafter drones ).

Please note that this is the third time we have submitted a FOIL request for this type

of

documentation (see 2013-

PL-l

00448 and 20 I 3-PL-7978). Previously, the

NYPD

FOIL Unit has invoked personal privacy as well as

disclosure

of

law enforcement technjques

to

justify rejections. However, the NYPD's recent statements to the City

Council' s Public Safety Committee eliminate both considerations: the Commissioner very publicly confirmed that

the department

is

researching drones, and Deputy Commissioner Miller indicated that

NYPD

officers were looking

into

what's

on the market,

what's

available.

A December 2010 email from a detective in the Counterterrorism Division to

the

FAA (first reported in August

2011: ) indicated that as

of

hat time, the department

was in the basic stages of investigating the possible use

ofUAV's

as a law enforcement tool.


25/30

Please search specifically for the below document categories, and respond to each of he categories and items:

I Acquisition documents:

i

requests for proposals RFPs), proposals/quotes submitted by vendors, contracts, leases, budget requests, project/

equipment budgets, cost allocations or reimbursements for the purchase

of

drone equipment;

ii) Grant applications and award letters for drone equipment purchases;

iii) Insurance contracts for all drone equipment;

iv) Communications including electronic communications) between the agency head or agency quartermaster or

individual responsible for equipment purchases and maintenance) and drone vendors, manufacturers or retailers;

v) Communications including electronic communications) between the agency head and agency quartermaster or

individual responsible for equipment purchases and maintenance) regarding acquisition, lease or use ofdrone

equipment;

vi) Communications including electronic communications) between the agency head and the governor, mayor and

city/town manager regarding the acquisition

of

drones;

vii) Applications including all components and support documentation) for Certificates of Waiver/Authorization

COA) from the Federal Aviation Administration, as well as COA grant notifications and final agreement;

viii) Contracts for services related to drones, such as data storage, data analysis, image storage, image analysis,

video storage, video analysis, operation, maintenance;

2) Equipment logs:

i

Inventories/logs/lists/databases

of

all drones owned, leased or operated by

or

for the agency;

ii) Maintenance logs for all drones owned, leased or otherwise operated by or for the agency;

3) Policy documents:

i

Policies, guidelines, protocols, manuals and/or instructions on the use/operation

of

drones and usage

of

data,

images and video obtained from drone flights;

ii) Communications from the agency head, quartermaster or individual responsible for overseeing equipment

purchases and maintenance) on approved uses for drones;

iii

Memorandums

of

understanding {MOUs), memorandums

of

agreement MOAs) or any other agreements or

contracts with other government agencies, private corporations, organizations

or

individuals to share drone

equipment, data, images

or

video

or

to operate drones on behalfof he agency;

4) Training documents:

i

Curriculum used to train drone operators and observers;

ii

Training log for all drone operators and observers;

iii

Certifications

of

training completion for all drone operators and observers;

iv) Contracts, purchase orders, budget requests or reimbursement orders for training sessions for all drone operators

and observers;

5) Usage documents:

i

Flight logs for all drone flights, including training flights;


26/30

ii

Flight logs transmitted to the Federal Aviation Administration pursuant to Certificate

of

Waiver/Authorization

(COA) requirements;

iii) Reprimands relating to drones, including misuse

of

equipment and failure

to

properly maintain

equipment

also request that,

if

appropriate , fees be waived as believe this request is in the public interest.

The

requested

documents will be made available to the general public free

of

charge as part

of he

public information service at

MuckRock.com, processed by a representative

of

he news media/press and is made in the process

of

news gathering

and not for commercial usage.

In the event that fees cannot be waived, would be grateful if you would inform me

of

he total charges in advance

of

fulfilling my request. I would prefer

the

request filled electronically,

by

e-mail attachment

if

available

or

D-

ROM

if

not.

Thank you

in

advance for your anticipated cooperat ion in this matter. look forward to receiving your response to

this request within 5 business days, as the statute requires.

Sincerely,

Shawn Musgrave

Filed via MuckRock.com

E-mail (Preferred):

99

For mailed responses, please address (see note):

MuckRock

News

EPTMR

11991

PO Box 55819

Boston, MA 02205-5819

PLEASE

NOTE

the new address as well

as

the fact that improperly addressed (i.e., with the requester s name rather

than MuckRock News) requests might be returned by the USPS as undeliverable.


27/30

HI ITE


28/30

is in response to

: , :2014 appeal or

request

for

records

RE: EDO:\ OF INFORf\IATIO '\

R lEST: .BF#l4PLIOS084

dated September 17.

Access 0

to the

l .

l-r

ring l the status of

ili:1tiun

the

tin La\\ .

Please be adYised a inati 1i1 or your

\Vil:\

mailed

011

1 1

1-r .

Another cupy of 1hc

August

.2:2. 20

i

4 appeal dctcrrni11ation is l'nc oscd.

Si

Appeals Officer

011

Open


29/30

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Documents

NYPD Drones - 2014.11.20 Notice of Petition