Friday, November 29, 2024

Ending Piermont Mayor Bruce Tucker's Reignbow: Part III.



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.

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.