This subseries comprises the copies of FBI files released to Siminoski by the Bureau as a consequence of his letter of October 22, 1982, and his lawsuit filed on October 11, 1983. The files are arranged alphabetically by the name of the gay or lesbian organization they concern: the Daughters of Bilitis, East Coast Homophile Organization (ECHO), Gay Activists Alliance, Gay Liberation Front, Mattachine Society, National Gay Task Force, ONE, Radical Lesbians, and Society for Individual Rights. Within each organizational group, files are ordered according to the FBI office that maintained the file: FBI Headquarters in Washington, DC, and the following field offices, in alphabetical order: Albany, Baltimore, Boston, Chicago, Cincinnati, Cleveland, Denver, Detroit, Los Angeles, Miami, Minneapolis, New York, Newark, Philadelphia, San Diego, San Francisco, and the Washington, DC. The materials total approximately 2,200 documents, or 7,000 pages, and date from the early 1950s to the late 1970s. The bulk of the materials relate to the Mattachine Society and the Gay Liberation Front; the earliest documents concern the Mattachine Society, and the Daughters of Bilitis. The files for the Mattachine Society also include material on ONE Magazine and One., Inc. Over half the materials consist of organizational publications, including newsletters, pamphlets, calendars, and magazines, several of which, such as the Ladder, Mattachine Review, and ONE Magazine, were publicly sold on newsstands. Other materials include descriptions of private and public meetings and lists of people attending them, photographs of public demonstrations, and correspondence concerning the activities of known and suspected homosexuals. There is considerable duplication of materials, in particular between FBI Headquarters and the individual field offices, but also between various field offices. Approximately 70 per cent of the materials are redacted (censored), some heavily so: many sheets are place-holders for pages withheld in their entirety. Both photocopies of original redacted pages and place-holder sheets are marked with one or more "exemption" codes indicating the reason for the redaction or withholding. The series also includes a number of "revised" documents, second releases of materials already delivered to Siminoski. In most cases the "revised" documents contain fewer redactions than those released earlier; however, in a few cases, they contain more revisions.

This subseries contains the materials created or collected by Siminoski in the course of analyzing the documents released to him by the FBI. The FBI was required to deliver to Siminoski a "Vaughn Index" to the documents it released, identifying each document, indicating the statutory exemption (for redaction or withdrawal) claimed, and explaining how disclosure would damage the interests protected by the claimed exemption. The subseries contains two versions of this index, both incomplete. The subseries also contains summaries of the documents released by the FBI, in typescript (documents numbers 1011-2047), manuscript (2048-2227), and on audio tape cassette (12-2047). Few of the FBI documents are marked with the number assigned them in the Vaughn index: a series of folders contains copies of documents that are so marked, arranged in numerical order. Because one of the pillars of his case was the FBI's improper use of exemptions to redact and withhold information, Siminoski and his legal counsel spent considerable effort to determine precisely what exemptions were claimed on each document. The subseries contains Siminoski's manuscript notes, listing each document in Vaughn index number order, and indicating for each document the code for each exemption claimed. The subseries includes a tally sheet, listing each exemption in numerical order and indicating the number of documents in which each exemption was claimed. Siminoski also arranged copies of the FBI documents for analysis by FBI Headquarters or field office. These records were marked with the name of the office and a number representing the year of the document and the sequence of each document within that year, e.g., "LA 53-1"; in most cases, a form for analyzing the contents of the document was also attached. A small number of these documents survive, relating primarily to the Mattachine Society; these documents have been arranged by FBI office name and file number. Siminoski encoded all documents for entry into a computer database, and held "coding parties" each week at Jim Kepner's archives on North Hudson St., in Los Angeles. His correspondence with his ACLU legal counsel also refers to a printout of the information in this database. The collection contains no copy of this printout, and only a handful of encoded documents were found when the collection was processed. A representative number of these coded documents has been retained, as well as sample coding sheets and document coding instructions. The subseries also contains a small folder of Siminoski's analytical and statistical notes on the documents; a larger number of similar notes will be found attached to Siminoski's 1986 memoranda to his legal counsel in Series 2, Subseries 2 (box 15, folders 9-10).

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.

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.

This subseries consists of materials created or collected by Siminoski in the course of his lawsuit against the FBI. The correspondence files document Siminoski’s relations with other individuals either seeking, or who had already obtained, access through the FOIA to FBI surveillance files on GLBT organizations; his travels and lectures on FBI surveillance of gays and lesbians; and his move in the summer of 1983 from Texas to Los Angeles, where his project found a home at Jim Kepner’s Western Gay Archives at 1654 North Hudson St. They also include a proposal from an admirer in Harrisburg, Pennsylvania, for an unrealized television movie on Siminoski's life. The files contain both original and copy letters, many with Siminoski's handwritten notes attached; correspondents include Harry Hay, Frank Kameny, and Morris Kight. The interview notes and followup correspondence document Siminoski’s visits to Washington, DC, in 1982 and 1983, to interview members of the administration, Congressional staffers, and government experts concerning the FOIA; the latest notes in the file document a conversation with the assistant to journalist Randy Shilts, who had also obtained photocopies of many of the same FBI documents through his own FOIA request, and had published an account of these records in the San Francisco Chronicle in September 1989. Additional files in the subseries evidence the intensive media campaign Siminoski launched with the filing of his lawsuit in October 1983. These files include consultation with a media consultant, correspondence with the gay media, extensive mailing lists of gay media organizations and individuals, and a press kit. The subseries also includes press releases relating to the lawsuit issued by the ACLU Foundation, and itineraries documenting Siminoski’s extensive travels in furtherance of his project. Siminoski also collected information on leading GLBT organizations, such as the Gay Rights National Lobby (where he also applied for the position of executive director), Lambda Legal Defense, and the National Gay Task Force. The records of the Freedom of Information Project, which Siminoski instituted in late 1984 with the help of Kepner and his archives (renamed the International Gay and Lesbian Archives earlier in the year), are of particular interest, as they include Privacy Act Waiver Forms with the notarized signatures of many prominent members of the GLBT community in 1984, including Virginia Apuzzo, Allen Ginsberg, Frank Kameny, and Bruce Voeller.