This subseries contains materials from the files of the ACLU Foundation of Southern California, which represented Siminoski in his lawsuit against the FBI. The bulk of the documents--Siminoski's memoranda to Joan Howarth of February-June 1986, his "Searchability memo" of June 1986, and the three draft memoranda prepared by ACLU lawyers or paralegals (box 15, folders 8-12; box 16, folder 1)--all relate to the plaintiff's proposed statement of uncontroverted facts and conclusions of law, motion for summary judgment, and memorandum of points and authorities, dated June 23, 1986 (box 9, folders 1-2). Siminoski's memoranda are cut-and-paste drafts, with extensive manuscript analytical and statistical notes derived from the FBI documents attached. The correspondence folder includes communications between Siminoski and his ACLU lawyers, in particular Joan Haworth and John Heilman, as well as with the Texas law firm that represented Siminoski before the ACLU Foundation. The subseries also includes three folders of attorney notes and drafts, relating to the recovery of attorney’s fees (from the FBI), Judge A. Andrew Hauck and judicial prejudice, and miscellaneous matters.