Law Office of John J. Tormey
III, Esq.
John J. Tormey III, PLLC
1636 Third Avenue, PMB 188
New York , NY
10128 USA
(212) 410-4142 (phone)
(212) 410-2380 (fax)
jtormey@optonline.net
https://www.tormey.org
NEW REQUEST UNDER THE FREEDOM OF INFORMATION ACT (“FOIA”)
EXPEDITED SERVICE REQUESTED
Wednesday, November 27, 2024
VIA U.S. MAIL and
E-MAIL:
cbpfoiapublicliaison@cbp.dhs.gov
Sabrina Burroughs, FOIA Officer
U.S. Customs and Border Protection
1300 Pennsylvania Avenue NW, Mail Stop 1181
Washington, DC 20229 USA
VIA U.S. MAIL and E-MAIL:
cbpfoiapublicliaison@cbp.dhs.gov
Charlyse Hoskins, FOIA Public Liaison
U.S. Customs and Border Protection
1300 Pennsylvania Avenue NW, Mail Stop 1181
Washington, DC 20229 USA
Re: “Rainbow Linens, Inc.”/“Bruce
Edward Tucker alias “Bruce Tucker”/Elizabeth, New Jersey
Dear Ms. Burroughs and Ms.
Hoskins:
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”. Specifically,
without limitation to the foregoing, I am seeking all Records relating to the
importation of any sheets, towels, garments, housewares, or other consumer
products which may bear any connection to Bruce Tucker and “Rainbow Linens,
Inc.” My understanding is that Bruce Tucker and “Rainbow Linens, Inc.” may
have repeatedly imported product from Asia and possibly other overseas locales.
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. One additional reason I
believe that Bruce Tucker and “Rainbow Linens, Inc.” may be reflected in U.S.
Customs 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 FOIA requests similar hereto on FTC and CPSC. 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 or illegality of any kind, whether by way of flammability, toxicity, or otherwise. That said, I have no current information regarding any such safety or illegality 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 U.S. Customs and
Border Protection (US Customs), the Consumer Products Safety Commission (CPSC),
the Federal Trade Commission (FTC), 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.
John J. Tormey III, PLLC
1636 Third Avenue, PMB 188
(212) 410-2380 (fax)
jtormey@optonline.net
https://www.tormey.org
cbpfoiapublicliaison@cbp.dhs.gov
Sabrina Burroughs, FOIA Officer
U.S. Customs and Border Protection
1300 Pennsylvania Avenue NW, Mail Stop 1181
Washington, DC 20229 USA
cbpfoiapublicliaison@cbp.dhs.gov
Charlyse Hoskins, FOIA Public Liaison
U.S. Customs and Border Protection
1300 Pennsylvania Avenue NW, Mail Stop 1181
Washington, DC 20229 USA
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:
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.
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 FOIA requests similar hereto on FTC and CPSC. 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 or illegality of any kind, whether by way of flammability, toxicity, or otherwise. That said, I have no current information regarding any such safety or illegality 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.
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.
John J. Tormey III, Esq.