This subseries contains the legal papers filed and proposed in Siminoski v. FBI, as well as the correspondence between Siminoski and the FBI, and between Siminoski's legal counsel, the ACLU Foundation of Southern California (represented by Joan Howarth, John Heilman, Paul Hoffman, and Jon W. Davidson), and the FBI and its counsel. The principal records are the complaint for injunctive relief (October 11, 1983; box 8, folder 9); the plaintiff's proposed statement of uncontroverted facts and conclusions of law, motion for summary judgment, and memorandum of points and authorities (June 23, 1986; box 9, folders 2-3); the report and recommendation of the Special Master, Ralph J. Geffen (November 3, 1988); transcripts of proceedings before Judge William D. Keller (June 19 and July 20, 1989; box 9, folder 19, and box 10, folder 3); and Judge Keller's decision (January 16, 1990; box 10, folder 5). While Geffen found for Siminoski on most points, Judge Keller reversed most of Geffen's recommendations; after discussion with Siminoski, who for health reasons had withdrawn from active participation in the case in 1986, the ACLU lawyers did not appeal Judge Kellers decision. The records also include the motion and supporting memorandum of points and authorities to disqualify Judge A. Andrew Hauck, to whom the case had originally been assigned, for anti-homosexual bias (November 7, 1985; box 8, folders 29-30). The memorandum of points and authorities of June 23, 1986, is incomplete, lacking exhibit 6 of volume 1, and all of volumes 2-5; however, the declarations of Robert J. Chester (June 15, 1985; box 8, folder 27) and Philip W. Thomas (October 11, 1985; box 8, folder 28) may be identical to exhibits 8 and 7, respectively, referenced in the index to volume 2. The litigation correspondence includes a copy of Siminoski's initial letter to the FBI, dated October 20, 1982, requesting under the FOIA photocopies of all FBI documents relating to the surveillance of gay and lesbian groups, as well as letters of transmittal that accompanied the release, beginning in March 1984, of records by FBI Headquarters and its offices in various cities; the FBI was still releasing documents under Siminoski's request in May, 1990. Although Siminoski began receiving copies of FBI documents in the first quarter of 1984, the lawsuit continued, on the grounds that FBI was not releasing documents in a timely manner, and that many of the documents released were improperly redacted. The correspondence between Siminoski's lawyers and those of the FBI constitute an important supplement to the court papers, as they provide additional discussion of issues raised in the latter.