Subseries Scope and Content From the Sub-Series: 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,...