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Comment on Proposed Rule for Federal Financial Assistance

6/8/2026

5 Comments

 
This proposed rule is a 100+ page proposed regulation that does several things simultaneously, and the DEI rollback is one of many disturbing aspects. The public comment page is here, scroll down for a template you can modify and copy/paste as desired. 

Summary
This regulation essentially rewrites the government-wide framework for managing federal financial assistance including grants, cooperative agreements, and related forms of federal funding.

What it does structurally
The rule consolidates power for grantmaking under OMB instead of the federal agencies related to the grant function.

Since 2013, the OMB rules governing federal grants (called "Uniform Guidance") were exactly that — guidance. Agencies had flexibility in how they implemented them. This rule converts guidance into binding OMB regulation. That means OMB, a White House office controlled by the president, now has direct regulatory authority over every federal grant across every agency. Future amendments to grant rules would go through OMB alone, not through individual agencies. One office, controlled by political appointees, governing all federal financial assistance.

The most dangerous provision is the "pre-issuance review" — every discretionary grant must now be reviewed by senior political appointees before it can be awarded. Peer review by scientific experts becomes purely "advisory." A political appointee can overrule the scientists and deny funding for any reason that doesn't align with "the President's policy priorities."

That means research on climate change, environmental health, public health disparities, gun violence, reproductive health — anything that contradicts the administration's political agenda — can be defunded not through Congress but through a political appointee's veto at the grant review stage. The research never happens. The data never gets collected. The knowledge never exists.

The DEI and gender ideology provisions:
The rule explicitly prohibits federal funds from being used for anything the administration defines as DEI activities, "gender ideology," or what it calls "child sex mutilation",  their term for gender-affirming care for minors. 

Gender-affirming healthcare is funded through multiple federal channels — NIH research grants studying gender dysphoria treatment, Medicaid covering transition-related care, HRSA community health centers providing services. This rule gives the administration a mechanism to defund all of it simultaneously across every agency without needing to pass a law or win a court case. Just deny the grants at the pre-issuance review stage.

For trans people who depend on federally funded healthcare for hormones, mental health services, and medical care, this could mean clinics lose funding and close. Providers stop offering services. Research into best practices stops. The infrastructure of care disappears not through a ban but through the quieter mechanism of defunding.

The rule also prohibits grants to organizations that promote "gender ideology", a term deliberately left vague enough to encompass virtually any organization that acknowledges trans people exist. Homeless shelters that house trans people according to their gender identity. Domestic violence organizations that serve trans women. Mental health providers who offer gender-affirming therapy. All of these receive federal grants. All of them could lose funding.

The broader issue:
The rule also allows agencies to terminate existing grants mid-stream if funding "no longer aligns with program goals, agency priorities, or the national interest." That language is broad enough to cancel virtually any grant for any political reason. Combined with the pre-issuance political review, it creates a system where new grants require political approval and existing grants can be terminated at political will.

Active grants — research in progress, clinical trials, public health programs — can be killed without cause. The scientists running them have already spent years and millions on the work. It all stops because a political appointee decides it doesn't serve the president's priorities.

Notably this proposed rule also prohibits grants supporting disparate impact theory, voter registration campaigns, and issue advocacy.

Comment Template

Below is a template you can modify and copy/paste sections you want to highlight in your comment. (Link to public comment page is here)
While the stated objectives of transparency, accountability, and oversight are laudable, the proposed rule as written would achieve the opposite — concentrating grant-making authority in political appointees, undermining scientific independence, threatening the lives of vulnerable populations, and fundamentally altering the relationship between federal agencies and the communities they serve.

[§ 200.205] Pre-Issuance Review 
This provision reduces expert peer review to a purely advisory role, requiring political appointee approval for all discretionary grants. For decades, peer review has ensured funding is awarded on scientific merit, not political alignment. A system requiring political approval before funding is awarded will produce only politically acceptable knowledge.

Climate science, public health research, epidemiology, environmental monitoring, and social science research all depend on the ability to follow evidence wherever it leads. A system that requires political approval before funding is awarded is a system that will produce only politically acceptable knowledge. This is not transparency. It is censorship at the point of origin, ensuring that inconvenient data is never collected in the first place.

I urge OMB to withdraw this provision and preserve the independence of merit-based peer review as the primary mechanism for grant award decisions.

[§ 200.300]  DEI, Gender Identity and Disparate Impact Prohibitions
Prohibiting funds related to "gender ideology" — a term left deliberately broad — threatens to defund healthcare infrastructure that transgender Americans depend on for basic medical care, mental health services, and suicide prevention. LGBTQ+ youth who lack access to affirming care are at significantly elevated risk of suicide. Defunding these services will cost lives.

Prohibiting research based on disparate impact theory would end the study of health disparities and environmental justice. These are empirically validated methodologies, not ideological frameworks. Banning them does not eliminate disparities. It eliminates our ability to understand and address them. 

I urge OMB to remove these prohibitions in their entirety.

[§ 200.340-344] Expanded Termination Authority
Expanded Termination Authority Allowing termination when an award "no longer aligns with the national interest" — a term undefined and subject to political interpretation — is functionally unlimited. Since January 2025, the administration has terminated thousands of grants and faced legal challenges. This provision appears designed to provide post-hoc legal authority for actions courts have questioned.

I urge OMB to maintain existing termination procedures that require documented cause, adequate notice, and meaningful opportunity for appeal.

[§ 200.206] Risk-Based Applicant Review and FEMA Implications
Embedding immigration enforcement into the grant framework raises life-and-death concerns. A flood does not check immigration papers. A wildfire does not ask for documentation. A hurricane does not distinguish between citizens and non-citizens. Relief organizations should not be forced to either. Research confirms that immigration enforcement produces declines in communities' willingness to seek emergency services.

I urge OMB to explicitly exempt emergency management, disaster relief, and public health emergency programs from immigration enforcement provisions in the proposed rule.

[2 CFR Subtitle A] Conversion from Guidance to Binding Regulation 
Converting the Uniform Guidance into a binding OMB regulation centralizes authority in a single White House office, removing individual agencies' ability to tailor requirements to their programs. This unprecedented consolidation of executive power over federal spending cannot account for the diverse needs of scientific research, public health, education, and environmental protection.

I urge OMB to maintain the existing framework in which agencies retain flexibility to implement guidance in ways appropriate to their specific programs, rather than centralizing regulatory authority in a single office.

[§ 200.450] Prohibition on Voter Registration and Issue Advocacy  
Voter Registration Prohibition Voter registration is a nonpartisan civic activity protected by the National Voter Registration Act. Prohibiting federally funded organizations from conducting voter registration suppresses civic participation among low-income, minority, and underserved communities.

I urge OMB to distinguish between partisan activity and nonpartisan voter registration.

Conclusion:
This proposed rule not an incremental adjustment. It is a structural transformation of federal grant-making into a tool of political control. I urge OMB to withdraw it in its entirety.

Respectfully submitted,

Additional summaries of the proposed regulations that go into greater depth and breadth:
  • OMB Proposes Major Overhaul of Federal Grant Rules: What Grant Recipients Need to Know (JD Supra, 6/5/26)
  • OMB Unveils Proposed Rule to Restructure Federal Financial Assistance Oversight (JD Supra, 6/2/26)
  • Breakdown of OMB Proposed Rule: Regulation for Federal Financial Assistance (American Astronomical Society, 6/4/26)
  • Office of Management and Budget Government-Wide
    Regulations for Federal Financial Assistance
    (American Council on Education, 6/2/26)
  • OMB Proposed Uniform Grants Regulation (AMPO, 6/2/26)
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5 Comments

International Worker's Day - May 1st

4/20/2026

0 Comments

 
There’s a clear next step that has been gaining traction - a one day General Strike on May 1st. This obviously is not going to topple authoritarianism, but it is an important step in getting Americans used to flexing their labor withdrawal muscle.

Led by labor groups like May Day Strong and Power in Numbers and backed by large coalitions like No Kings (50501, Indivisible, Women’s March, Greenpeace, Jewish Peace, Move On and more), there is potential for this to reverberate and gain media attention. The message needs to be clear: the American people are willing to make sacrifices for the greater good of humanity.

Check out this map for a local event near you, or create your own on Mobilize. Sign up with May Day Strong to learn more about organizing, or join your local DSA, 50501 or Indivisible chapter.
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Inspiring May Day Flyers Circulating Online:

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0 Comments

Script for City Council Meetings on NSPM-7

4/9/2026

0 Comments

 
The proposed budget for 2027 includes substantial funding for the Department of Justice training of city and state law enforcement to implement NSPM-7, the "Countering Domestic Terrorism and Organized Political Violence" memo issued in September 2025 that targets broadly left-wing ideologies as signs of potential domestic terrorism. 

Below is a script you can copy and adapt to read to your own city council meetings.

Template/Script

Hello, my name is [Name], and I’m here to ask this Council to take seriously the civil liberties implications of NSPM-7, a federal national security directive that appears to expand domestic counterterrorism frameworks in ways that could target lawful political dissent by people who hold traditionally left wing views.

I'm bringing it to your attention because I recently learned they are planning to operationalize it locally — through law enforcement partnerships, intelligence-sharing networks, fusion centers, and Joint Terrorism Task Forces, including the training of local and state law enforcement on the directive.

If federal agencies are encouraging local police to view broad political beliefs — including: anti-capitalism, antifascism, anti-war protesting, or criticism of state violence — as indicators of extremism, then we are looking at a serious threat to the First Amendment rights of people in this city.

That should concern everyone, regardless of political affiliation.

Criticizing government policy is not terrorism.

Protesting injustice is not extremism.

Wanting human dignity, economic fairness, or an end to authoritarianism is not a public safety threat.


And yet we are seeing a political climate in which dissent — particularly from the "left"-leaning ideologies — is increasingly framed as dangerous, while actual patterns of political violence in this country have long shown right wing extremism to be the dominant source of fatal domestic violence historically. This was documented in a study by the Department of Justice in 2024, a joint DHS-FBI study in 2023, and a number of other DOJ and FBI testimonies.

Federal threat assessments have long identified racially and ethnically motivated violent extremism as the biggest domestic terrorism threat, and hate-motivated violence has disproportionately impacted Muslim, Jewish, LGBTQ and racial minority communities.

So I am asking this Council to do three things:
  • First, publicly affirm that lawful protest, organizing, political speech, and criticism of government are protected activities in this city.
  • Second, require transparency from local law enforcement about any participation in NSPM-7-related trainings, intelligence-sharing, surveillance programs, fusion center coordination, or FBI/JTTF cooperation connected to political monitoring.
  • Third, explore policies that prohibit city resources from being used to assist in the surveillance, targeting, or criminalization of constitutionally protected political activity.

If this directive is allowed to quietly filter downward into local institutions, the damage will not begin with “terrorists.” It will begin with ordinary people who are speaking out, organizing, dissenting, and often times actually trying to protect the constitution and democracy. 

That is exactly when local government is supposed to draw a line.

Thank you.

Learn more:
  • NSPM-7 Memo text
  • ACLU Analysis of NSPM-7
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0 Comments

Script for City Council Comment on Flock Cameras

4/8/2026

0 Comments

 
I came upon a video of a Corona City Council meeting where a resident with an IT and cloud infrastructure background commented on Flock cameras. It was very insightful so I transcribed it, did some fact checking, and adapted it so that people can take the script for any city they live in. (For reference, the original transcript is here, and original video is here.)

Script:

Hi. My name is {Name}, and I'm a resident of {City}.

I’m here to speak about Flock Safety cameras and the broader implications for privacy and public oversight.

Flock advertises these as simple license plate readers. But in practice, they function as a much broader data collection and surveillance system — capturing detailed images of vehicles and their surroundings, along with time and location data, and then storing that information in a searchable database hosted on corporate cloud infrastructure.

While local agencies technically control their data, the system is designed for sharing across jurisdictions. That means data collected here can be accessed by other agencies, sometimes far beyond the local level, raising real privacy concerns.

There have already been documented cases in other cities where federal agencies accessed local camera data without clear public awareness. That raises serious questions about transparency and oversight.

It's also important to note that Flock Safety is backed by none other than Peter Thiel, founder of Palantir, the data fusion platform utilized across federal agencies including ICE. He is billionaire famous for stating he does not believe in democracy or that women should have ever gotten the right to vote.

But this isn’t just about one company or one person. It’s about patterns in the kind of infrastructure we are building and who is allowed to control them. When mass data on ordinary residents is collected and stored in systems like this, it creates a permanent record of people’s movements — regardless of whether they are suspected of any wrongdoing. That has real implications for civil liberties and privacy violations. 

So the questions we should be asking:
  • Who has access to this data?
  • How is it being used?
  • And what safeguards are in place to prevent misuse?

Given this information, I am asking the City Council
  • Conduct a full audit of how Flock data is being accessed and shared
  • Disclose any agreements with outside agencies
  • And reconsider whether this system aligns with our community’s values and expectations around privacy, and consider taking a vote to cancel the Flock safety contract.

Lastly, I want to emphasize this is not about being anti-security or anti-police. Public safety obviously matters. But mass surveillance of entire populations by companies with stated political agendas is a different question.

Thank you. 
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0 Comments

Post "No Kings III" Actions

4/7/2026

0 Comments

 

Workers Over Billionaires - General Strikes

Get ready for a series of national general strikes. The first one will be on Friday, May 1st, International Workers Day.
  • It’s being led by a coalition of serious labor groups — May Day Strong, Power in Numbers, Sunrise Movement, Women's March
  • There’s training leading up to it—facilitated by Strike Ready Corps and Grassroots Democracy
  • Backed by larger organizations like Indivisible and The 50501 Movement this year, which means this could gather a critical mass.
  • It’s part of a larger strategy. Another one on Labor Day, in prep for the likely need for mass mobilization in November.

Sign up for their Welcome & Training Prep: https://grassroots-democracy-initiative.solidarity.tech/welcome-to-strike-ready-corps

Roadmap Dates: https://grassroots-democracy-initiative.solidarity.tech/road-map-to-may-day

How We Build a General Strike: 
This video is 90 minutes. If you can check out at least the first 30-40 minutes to hear talks from:
  • South Korean labor leader, Wol-San Liem, speaking about South Korea’s experience holding a general strike in response to their president declaring martial law
  • Chicago Mayor Brandon Johnson also talks about general strike and collective action.
  • Daniel Hunter, Freedom Trainers - about the ingredients required for general strike, importance building the kindling wood so that when a catalytic event happens you can strike the match.
  • Aru Shiney-Ajay, Sunrise Movement
  • Tamika Middleton, Women’s March
  • Neidi Dominguez, Power in Numbers

Images to Share for May 1st

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Defund the Broligarchy

Independence from the Big Tech companies who have aligned themselves with authoritarianism is a key step in saving our democracy. Below is an easy reference guide for big tech to avoid and alternatives. 

More information:
  • PDF file to print copies: visit the Defund the Broligarchy blog post
  • Check out the Digital Exodus Guidebook for even more details.
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0 Comments

Send Governor Message to Protect Citizen Privacy

3/31/2026

0 Comments

 
ICE is using our DMV data to track protestors. And we need state governors to put a stop to it. They need to hear from you.

Very easy action item -- takes 30 seconds.
  1. Go to this link: https://democracyactioncenter.org/noicedata
  2. Copy/paste the message from the page.
  3. Select your state. It'll take you to your governor's contact page where you can select the category (it can be "other" if you can't find the right one.
  4. Paste the message. Edit it however you see fit. Click send.

And you're done. Takes 30 seconds. Please do it.
0 Comments

Transcript from Corona City Council Meetings re: Flock Cameras and Palantir

3/31/2026

0 Comments

 
This is the transcript of a resident of Corona, who spoke to his City Council about Flock cameras. I will be creating a more generic template that we can apply to any city, but wanted to share the transcript now in case people want to get started.

The original video is here.

Transcript:

My name is Brett, and I've been a Corona resident in District 4 for 15 years.

I'm here to introduce Deflock Corona, a community coalition asking this council to cancel the city's contract with Flock Safety and remove the cameras that have been deployed throughout our city.  Our website is deflock-corona.org.

I'm here because new Flock cameras were recently installed between my home and my daughter's school. So now every time I make that drive, my family is being photographed and logged into a giant corporate database.

I want to be clear what these cameras actually are, and I say that as somebody with 20 years of experience in IT. I've served as the chief network architect for Fortune 500 companies. I've designed data centers, and today I work on cloud infrastructure for one of the largest loan origination companies in the country. I'm not speculating on how this technology works. I've read their patents, and I know how it works.

Flock advertises these cameras as simple license plate readers. Their own patents tell a different story.

  • They're AI-powered surveillance machines that capture every passing vehicle and person and transmit that data to a private corporate cloud, making it queriable by a multitude of state and federal agencies.
  • The city of Corona does not control that database, and Corona residents have no public record rights against the private company's servers.
  • Our daily movements are being harvested by a $7.5 billion corporation that only answers to venture capital investors, not to us.
  • Flock did not reach that valuation on their per-camera subscription fees. That math doesn't add up.

The city council should also understand who they're doing business with. 
Flock's CEO was asked whether the company had any federal contracts. He said no. That was a lie. Public records reveal that Flock had been secretly running a pilot program giving the U.S. Border Patrol access to local police camera data without the knowledge of the cities that paid for the cameras.

Now consider who's behind the company and where your data flows. 
Flock integrates directly with Palantir, a data fusion platform with a $30 million contract with ICE. Peter Thiel, the founder of Palantir, is also one of Flock's primary investors.  These are not separate companies with separate agendas. They are connected actors that are building a connected infrastructure.

Palantir's own CEO stated publicly just this month that his technology is being used as a political instrument designed to reduce the political power of certain voters.  And that's the ecosystem that our Corona cameras are feeding into.

We're not anti-police at all. We're against mass surveillance of innocent residents by a company with a documented record of deception built by investors with a stated political agenda.

We're asking the city council: 

  1. to start auditing the queries made against Flock's database to disclose any data sharing agreements and
  2. to take a vote to cancel the Flock safety contract.

The Deflock Corona org will be at future meetings and we'll be filing public records requests.

And I'll close by saying Benjamin Franklin warned us that "those who would give up essential liberty to purchase a little temporary safety deserve neither liberty nor safety."
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Video of live speech
0 Comments

Script to Bring to City Council Meetings RE: Cybersecurity contracts and CISA De-Funding

3/24/2026

0 Comments

 
Over the past two decades, cyber security attacks have been increasing across the United States. In March 2026, Foster City, California was hit by a ransomware attack, which crippled the city's police and emergency services briefly and shut other services down for several consecutive days. (San Fransisco Chronicle). 

What's particularly concerning is that in 2025, the federal Cybersecurity and Infrastructure Security Agency (CISA) — the agency designed to help cities defend against such attacks — had its budget cut by almost $500 million. (Axios)  (Update: According to a Techcrunch article from April 7, 2026, the proposed 2027 budget includes an additional $700 million in cuts.)

As federal funding for cybersecurity declines, cities become more vulnerable to cyber threats, which drains financial resources from local communities. At the same time, private technology corporations can exploit these crises to sell costly “solutions,” a tactic describe in detail in Naomi Klein’s Shock Doctrine.

We must encourage our cities to become pro-active about cybersecurity in the face of federal funding cuts, to conduct thorough due diligence for private contractors and to absolutely refuse contracts with Palantir or any Thiel-backed company.

------
Below is a template you can send by email or speak in person at your local city council meeting. Adapt as needed.

You can search for your reps from Federal to local level: here 

Template:

Good [morning/evening]. My name is [Name] and I'm a resident of [City].

I'm here to talk about something that may not have hit the radar recently — but it’s important we get out in front of it.

In March, Foster City (in the Bay area of California) declared a state of emergency after a ransomware attack paralyzed nearly all city services for several consecutive days. And this is not an isolated incident. Municipal cyberattacks have increased across California and the country.

Meanwhile federal funding for cyber security has been cut at the time we need it most. 

Last year, the federal govt cut funding and fired leadership of the Cybersecurity and Infrastructure Security Agency — CISA, which was specifically designed to help cities like ours defend against these kind of cyber attacks.

So what does this mean and what can we do?

What happens when the federal government defunds programs is that cities become vulnerable. And vulnerable cities become the easy prey of predatory private contractors who profit over people--something incredibly dangerous for such an essential public service

In particular, there is a private surveillance and data company, which you have likely heard of, called Palantir, that holds billions in federal contracts including for AI military infrastructure, and is actively expanding into municipal services. 

Its founder, Peter Thiel has publicly stated he does not believe in democracy. This is the same man has been going around the country, and now the world, giving speeches about the antichrist, who said might be Greta Thunberg the climate activist, at one point. The Vatican has intentionally distanced itself from him. This man has also been quoted in reputable news outlets saying that "date rape is belated regret," and that "women getting the right to vote was the worst thing to happen to our country."

I don’t have time to go into the specific implications of what contracts with Palantir or Peter Thiel means to community members… but suffice it to say:

But suffice it to say, if our city is ever approached by Palantir (or affiliated company, or any company backed by Peter Theil) to provide cybersecurity or any other municipal service, I am asking you to reject that contract. (This includes Flock cameras)

The solution to weakened federal cybersecurity funding is NOT handing our city's data and infrastructure to a private corporation with authoritarian ambitions.

The solution is demanding restored funding, at the federal and state level, investing in our own IT infrastructure, partnering with accountable public institutions and engaging in thorough due diligence of any private sector vendors.

Our city's data belongs to our residents. Not to shareholders. Not to surveillance companies.

Thank you.
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No Kings III: Defund the Broligarchy

3/22/2026

4 Comments

 
Harnessing the momentum from No Kings III towards sustained economic action.

You are welcome to share the graphics online, and/or download, print and handout the PDF below at any in person gathering.

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Print single sided for one flyer per page or Double Sided (flip on short side) for two flyers per page.
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no_kings_follow_up__full_page_.pdf
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Pressure State AGs to Form a Coalition

1/12/2026

0 Comments

 

Investigate the Heritage Foundation

I'm encouraging people to reach out to their State Attorneys Generals, especially the following Blue (and a few Red) States:

  • California - Rob Bonda
  • Washington
  • Oregon
  • Colorado
  • New Mexico - Michelle Lujan Grisham
  • Michigan - Dana Nessel
  • Illinois - Kwame Raoul
  • Minnesota - Keith Ellison
  • Maryland
  • New York - Letitia James
  • Connecticut
  • Massachusetts - Andrea Campbell
  • Vermont
  • Arizona 
  • Georgia

—to open an investigation into the Heritage Foundation and Project 2025. 

To find your state AG and their contact information, go to this site: 
  • https://www.naag.org/find-my-ag/

Sample Letter

Dear Attorney General [State Atty General’s Name]

I am writing as a concerned resident of [State of Residence] to request that your office open an investigation into the Heritage Foundation’s Project 2025, and its potential role in coordinating federal-level efforts to undermine constitutional governance, civil service protections, and individual civil rights.

Project 2025 is not simply a policy proposal—it is an operational blueprint that is currently being actively used to:
  • Politically purge federal agencies via reactivation of “Schedule F”
  • Erode federal protections for vulnerable communities, including LGBTQ+ people, immigrants, and reproductive rights
  • Centralize executive power in ways that appear to violate the separation of powers and due process

Many of these efforts have downstream consequences that directly harm residents of our State, especially marginalized and medically vulnerable populations. I believe your office has jurisdiction to investigate:
  • Whether any civil conspiracy, coordinated federal overreach, or violations of state rights have occurred under State law
  • The role of affiliated nonprofits and donors in potentially financing actions that may violate state constitutional protections

Given the unprecedented nature of this threat, I urge you to coordinate with other state Attorneys General, civil rights watchdogs, and constitutional scholars to assess whether legal action—including subpoenas or state-level RICO investigations—is warranted.

Please let me know what steps, if any, your office is taking to evaluate or respond to this growing concern. I would greatly appreciate a written reply.

Thank you for your time and service. 

Sincerely
[Your Name]
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    Amanda Ianthe Greene, Research, Policy and Systems Analyst,

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