Bruce Tucker's Rainbow Linens: Holtsville And Brookhaven.

Law Office of John J. Tormey III, Esq.
John J. Tormey III, PLLC
1636 Third Avenue, PMB 188
New York, New York  10128  USA
(212) 410-4142 (phone)
(212) 410-2380 (fax)
jtormey@optonline.net
https://www.tormey.org
 
REQUEST UNDER THE NEW YORK STATE FREEDOM OF INFORMATION LAW (“FOIL”)
Monday, February 17, 2025
 
VIA FAX: 1-631-451-9264, U.S. MAIL, and E-MAIL:
FOIL@BrookhavenNY.gov
 
Mr. John Doyle, FOIL Officer
Mr. Kevin J. LaValle – Town Clerk, Registrar, and FOIL Appeals Officer
Town Of Brookhaven, New York – Law Department
1 Independence Hill
Farmingville, New York  11738  USA
 
Re:     
FOIL Request: “Rainbow Linens, Inc.” In Holtsville, New York circa 2008
That Corporation’s Owner, Bruce Edward Tucker a/k/a “Bruce Tucker”

Dear Mr. Doyle, Mr. LaValle, and Colleagues:
 
Attached is the only current evidence I have, that a New York corporation called “Rainbow Linens, Inc.” owned by Bruce Edward Tucker, was doing business in Holtsville, New York circa Year 2008. It is the first page of a complaint in a New Jersey civil litigation of that same general time-frame. Rainbow Linens and Bruce Tucker sold sheets and towels wholesale. Rainbow Linens and Bruce Tucker also were once busted by Good Housekeeping and The Wall Street Journal for falsifying thread-counts in the sheets they sold. As for the attached document, I need to follow this thread and seek any Records relating to Holtsville, and “Rainbow Linens, Inc.” or Bruce Tucker, under FOIL. I would first ask that the search-parameters be set for any Records dating from Year 2000 through Year 2020.
 
I am an attorney in New York, and a citizen and resident of the Town of Orangetown and the County of Rockland. Under the New York State Freedom of Information Law:
http://www.dos.ny.gov/coog/foil2.html
and, as may be applicable, its state, federal, and other counterparts, including without limitation New York Public Officers Law, Article 6, Sections 84-90, and Title 5 of the United States Code, Section 552 (collectively herein referred to as “FOIL”), request is hereby made that each of you provide to this, my law office, full and complete copies of each and every document and other item of material dated, generated, or otherwise materializing from January 1, 1979 forward to the present day (collectively, “Records”) which may be at all responsive to the following requests:
 
1. Rainbow Linens, Inc. In summary, I am seeking all Records relating to “Rainbow Linens, Inc.” and Holtsville, New York.
 
2. Bruce Edward Tucker a/k/a “Bruce Tucker”. In summary, I am seeking all records relating to an individual named Bruce Edward Tucker a/k/a “Bruce Tucker” and Holtsville, New York. Bruce Tucker was the owner of “Rainbow Linens, Inc.”
 
3. Subject Matter Listing. I have reviewed your Town’s Internet website to try to determine where in Town records “Rainbow Linens, Inc.” might appear. While I am not yet certain which of your Town’s Records and departments would be most likely responsive to this FOIL regarding “Rainbow Linens, Inc.” and Bruce Tucker, I have thusfar identified these of your Town’s apparent subject-matter categories, as of the likeliest greatest potential initial interest. That said, other thoughts you have would be welcome, too:
 
-Building Records
-Fire Prevention Records
-Police And Law Enforcement Records
-Assessor Records
-Violations Records - Housing
-Violations Records – Law
-Violations Records – Zoning
-Violations Records – Building Code
-Housing And Community Development Records
-Highway Department Records
-Wetlands And Bulkheads Records
-Tax Bills
-Zoning Of Property Records
-Board Of Zoning Appeals Records
 
Assuming that the attached “Holtsville” reference in the New Jersey litigation file is accurate, and therefore assuming that “Rainbow Linens, Inc.” once actually had some form of physical presence in Holtsville circa 2008 - I do not yet know if the company rented a leasehold, or alternatively, owned property.
 
4. Incidents, Complaints, Claims, And Litigations. Specifically, I am seeking all Records reflecting, referencing, or otherwise relating to any incidents, complaints, claims, mediations, arbitrations, or litigations, about, concerning, or otherwise relating to “Rainbow Linens, Inc.” or Bruce Tucker, if any.
 
5. Enforcement Actions. Specifically, I am seeking all Records reflecting, referencing, or otherwise relating to any enforcement actions or comparable actions against, about, concerning, or otherwise relating to “Rainbow Linens, Inc.” or Bruce Tucker, if any.
 
6. License Transfers. Specifically, I am seeking all Records reflecting, referencing, or otherwise relating to any transfer of any license or other transfers of value, of, by, for, or otherwise concerning “Rainbow Linens, Inc.” or Bruce Tucker.
 
7. E-Mails And Correspondence. Specifically, I am seeking all Records of any e-mails, memos, notes, correspondence, documents, or other writings to, from, referencing, or otherwise relating to “Rainbow Linens, Inc.” or Bruce Tucker.
 
8. Fines Or Other Penalties. Specifically, I am seeking all Records reflecting, referencing, or otherwise relating to any fines or other penalties assessed against or otherwise imposed upon “Rainbow Linens, Inc.” or Bruce Tucker, if any.
 
9. Violations, If Any. Specifically, I am seeking all Records reflecting, referencing, or otherwise relating to any violation or claimed violation of any other laws, statutes, ordinances, regulations, rules, requirements, or standards by, concerning, or otherwise relating to “Rainbow Linens, Inc.” or Bruce Tucker – if any. I am seeking each and every Record reflecting any “violation”, “reporting violation”, or other past, present, future, or anticipated violation, breach, or other transgression of 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 enforced by or otherwise relating to or concerning any of the following:
 
United States Department Of Justice (USDOJ)
U.S. Attorney’s Office (USATTY)
Federal Bureau Of Investigation (FBI)
Office of the New York State Governor (NYS GOV)
New York State Attorney General’s Office (NYSAG)
New York State Department of Financial Services (NYSDFS)
All other New York state and local agencies.
Any other potentially-relevant government agency or authority.
 
10. All Other Records. Specifically, I am seeking all other Records of any other kind or nature relating to “Rainbow Linens, Inc.” or Bruce Tucker.
 
11. 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...” (FOIL,§86[4]) 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:
http://www.dos.ny.gov/coog/foil2.html#s86
 
12. Headings And Subheadings. The headings and subheadings used in this letter 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 FOIL request.
 
13. 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 FOIL should be considered a matter of public importance, and as its results will be shared with the general public and published, 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.
 
14. Denials And Appeals. 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.
 
15. Additional Requests. This FOIL request is not intended to be exhaustive, and I may make additional and 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, and with thanks,

John J. Tormey III, Esq.
 
cc:
VIA FAX: 1-518-474-1927, U.S. MAIL, and E-MAIL:
coog@dos.ny.gov
NYS Committee on Open Government (COOG)
Department of State
One Commerce Plaza, 99 Washington Avenue, Suite 650
Albany, New York 12231 USA