NEW REQUEST UNDER THE FREEDOM OF INFORMATION ACT (“FOIA”)
Wednesday, November 27, 2024
VIA FAX: 1-301-504-0127, U.S. MAIL, and E-MAIL:
CPSCFOIARequests@cpsc.gov
aoyewole@cpsc.gov
Abioye Oyewole, Chief FOIA Officer
US Consumer Product Safety Commission (CPSC)
4330 East West Highway, Room 820
Bethesda, Maryland 20814
USA
VIA FAX: 1-301-504-0127, U.S. MAIL, and E-MAIL:
cpsc-foia@cpsc.gov
rdalton@cpsc.gov
Robert Dalton, FOIA Public Liaison
US Consumer Product Safety Commission (CPSC)
4330 East West Highway, Room 820
Bethesda, Maryland
20814 USA
Re: “Rainbow Linens, Inc.”/“Bruce
Edward Tucker alias “Bruce Tucker”/Elizabeth, New Jersey
Dear Abioye Oyewole, Robert
Dalton, and Colleagues:
I am an attorney in New
York, and a citizen and resident of the Hamlet of Pearl River, the Town of
Orangetown, and the County of Rockland.
Under Title 5 of the United
States Code, Section 552 (5 U.S.C. §552) (“FOIA”):
http://www.law.cornell.edu/uscode/text/5/552
request is hereby made that
your offices timely provide to this, my law office, full, complete, unredacted,
and otherwise unexpurgated copies of each and every document and other item of
material (collectively, “Records”) which may be at all responsive to the
following:
1. Time-Frame. I am hereby requesting
the production of any and all Records from January 1, 1989 to the
present day, as follows.
2. “Rainbow Linens, Inc.”. In Year 1989, an
individual named Bruce Edward Tucker started a sheet-and-towel wholesale
company called “Rainbow Linens, Inc.” in Elizabeth, New Jersey. I am hereby
requesting all Records that you may have naming, identifying, reflecting, or
bearing any other connection to “Bruce Edward Tucker”, “Bruce Tucker”,
“Rainbow Linens, Inc.”, or “Rainbow Linens”.
3. Bruce Tucker Is Now
The Mayor Of Piermont, New York. Interestingly, Bruce Tucker subsequently
became the Mayor of Piermont, New York in Year 2018, and remains the Mayor of
Piermont through this day. However, I do not think that this fact will affect
your FOIA research in anyway.
4. The Merger. Bruce
Tucker is reported to have merged his “Rainbow Linens, Inc.” into a company
called “Royal Heritage Home, LLC” in Year 2009:
https://unhandpiermont.blogspot.com/2024/11/timeline-garmento-bruce-tucker-to.html
Bruce Tucker appears to have
then maintained a connection to the resulting post-merger business through at
least Year 2014, if not later.
5. Bruce Tucker And
Rainbow Linens, Inc. Falsified Sheet Thread-Counts. The main reason that I
believe Bruce Tucker and “Rainbow Linens, Inc.” may be reflected in CPSC past
files, is because in Year 2006, Bruce Tucker and “Rainbow Linens, Inc.” were identified
by the Good Housekeeping Research Institute in a newspaper article published by
the Wall Street Journal and picked-up by the Atlanta Constitution. In this
article, Bruce Tucker and “Rainbow Linens, Inc.” were exposed for having falsified
thread-counts in sheets that they sold:
https://unhandpiermont.blogspot.com/2024/11/piermont-mayor-bruce-tucker-and-rainbow.html
I would find it difficult to
believe if this discovery and garment-industry scandal did not result in some
form of governmental agency inquiry and civil and administrative claims at the
time, if not criminal liability for the perpetrator or perpetrators as well. I
have today served a FOIA request similar hereto on FTC, and I expect to serve
one upon U.S. Customs and Border Protection in short order. That said, I am
very interested in whether or not the sheets and towels wholesaled to retailers
by Bruce Tucker and his company “Rainbow Linens, Inc.” were ever
identified by any person or entity as posing any consumer product safety
issues of any kind, whether by way of flammability, toxicity, or otherwise. That
said, I have no current information regarding any such safety issues, other
than the falsified thread-counts which Bruce Tucker and his company “Rainbow
Linens, Inc.” propagated. In any event, I am counting of each of you and your
colleagues to now pull this thread for me.
6. Violations Of Laws – IF Ever Any.
I am hereby also seeking, to the extent if at all existing, each and every
Record reflecting any “violation”, “reporting violation”, or other breach, or
other transgression of any federal, state, county, town, local, or other
ordinance, rule, regulation, requirement, or other law or standard - including
without limitation any violation of rules, regulations or other laws promulgated
by, enforced by, or otherwise relating to or concerning your Consumer Products
Safety Commission (CPSC), the Federal Trade Commission (FTC), U.S. Customs and
Border Protection (US Customs), the United States Department Of Justice
(USDOJ), the U.S. Attorney’s Office (USATTY), the Federal Bureau Of
Investigation (FBI), the Office of the New Jersey Governor (NJGOV), the New Jersey
Attorney General’s Office (NJAG), all other federal, New Jersey state, and
local agencies, and any other relevant authorities.
7. Definition Of “Records”. “Records” should be construed in the
broadest sense and manner possible and should include any information kept,
held, filed, produced or reproduced by, with or for your agency or office in any
physical form whatsoever, including without limitation all audio recordings,
blog posts, correspondence, data maintained electronically, data, e-mails,
executive summaries, extracts, faxes, instant messages, Internet posts,
letters, log-book entries, memos, paper records, personal messages, social
media communications, spreadsheets, summaries, synopses, telephone records,
test-reports, visual recordings, and any other materials.
8. Headings. The headings to numbered Items #1
through #11 herein are for convenience of reference purposes only, and should
not be construed to be words of limitation or otherwise of any substantive
significance relative to this FOIA request.
9. Costs. If there
are any copying or other fees for this, please let me know what they are and
how they are calculated, before filling the request and forwarding the Records
to me. As this FOIA should be considered a matter of public importance, and as
its results will be shared with the general public, I am asking that any
otherwise-applicable fees be waived for this document-production. I am also
asking that all documents be provided to me electronically to the full extent
possible, so as to obviate the need for any photocopying expense.
10. Timing. As you
know, the Freedom of Information Act requires that any agency, including your
own, respond to a request such as this one within twenty (20) days of receipt
of the request. In the event that any portion of my request is denied, please
inform me of each of the specific reasons for any such denial in writing - and
provide me with the name, address, and other contact information of the person
or entity to whom an appeal should be directed.
11. Additional Requests.
This FOIA request is not intended to be exhaustive, and I may need to make
additional or follow-up requests.
I will appreciate a response
from you and your office as soon as possible. I look forward to hearing from
you. Thank you.
Respectfully submitted,
John J. Tormey III, Esq.
