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May

24, 2017


U.S. Department of Education
Office of Management
Office of the Chief Privacy Officer
Attn: FOIA Public Liaison
400 Maryland Avenue, SW, LBJ 2E321
Washington, DC 20202-4536

Re: Freedom of Information Act Request


Dear FOIA Public Liaison:

Pursuant to the Freedom of Information Act, Allied Progress requests access to and copies
of all correspondence concerning the memorandum dated April 11, 2017 titled Student
Loan Servicer Recompete (attached) sent by, sent to, or carbon copying (CC) any
individual listed below or any staff member within any office listed below at any point since
January 1, 2017:

Secretary Betsy DeVos
Chief of Staff Josh Venable
Deputy Chief of Staff for Policy Ebony Lee
Senior Counselor Robert Eitel
Senior Advisor to the Under Secretary James Manning
White House Liaison Jana Toner
The Under Secretary of the Department of Education
The Office of Planning, Evaluation and Policy Development
The Office of Federal Student Aid, including the following sub-offices:
o Financial Institution Oversight Service
o Risk Management
o Business Operations
o Policy Liaison and Implementation Staff
o Business Optimization
o Enforcement
o Finance
o Performance Management
The Office of Postsecondary Education, including the following sub-offices:
o Office of Higher Education Programs
o Office of Policy, Planning and Innovation
The Federal Student Loan Support Center
The Default Resolution Group
The Federal Student Aid Ombudsman Group

1220 L Street NW, Suite 100/364 Washington, D.C. 20005-4018



(855) ALD-PRGS toll-free AlliedProgress.org

This should include, but is not limited to, all correspondence involving any of these
individuals which contains any of the following phrases:

John King
King Memo
Ted Mitchell
Mitchell Memo
past performance

If possible, I would prefer to receive this information electronically via e-mail at
karl@alliedprogress.org. If you have questions or need additional information, please feel
free to call me at (855) 253-7747.

Fee Waiver Request

Allied Progress requests a waiver of fees associated with processing this request for
records. The subject of this request concerns the operations of the federal government, and
the disclosures will likely contribute to a better understanding of relevant government
procedures by the general public in a significant way. Moreover, the request is primarily
and fundamentally for non-commercial purposes.

Allied Progress requests a waiver of fees because disclosure of the requested information is
in the public interest because it is likely to contribute significantly to public understanding
of government operations and is not primarily in the commercial interest of the requester.
The disclosure of the information sought under this request will document and reveal the
operations of the federal government, including how public funds are spent and how
officials conduct the publics business.

The public has expressed significant and specific concern over apparent and potential
conflicts of interest within the Department of Education.1 Secretary of Education Betsy
DeVos has previously disclosed her familys financial interest in a student loan debt
collector2, and the public has substantial interest in knowing if the actions taken by
Secretary DeVos or any other Department of Education official to revoke loan servicer
guidance were done in an effort to benefit the Secretary or her family by increasing the
number of defaulted student loans.

This request is primarily and fundamentally for non-commercial purposes. As a project of a
501(c)(3) organization, Allied Progress does not have a commercial purpose and the release
of the information requested is not in Allied Progresss financial interest. Allied Progresss
mission is to give voice to hard-working Americans by standing up to Wall Street and other
powerful special interests and holding their allies in Congress and the White House
accountable. Allied Progress will use the information gathered, and its analysis of it, to
educate the public through reports, press releases, or other media. Allied Progress will also
make materials it gathers available on our public website.


1 Michael Stratford, DeVos review identifies 102 financial interests with potential conflicts, Politico, January 20, 2017 and
Editorial, Big Worries About Betsy DeVos, New York Times, January 10, 2017.
2 Betsy DeVos Ethics Statement, Office of Government Ethics, January 19, 2017.


Accordingly, Allied Progress qualifies for a fee waiver.

Conclusion

If my request is denied in whole or part, I ask that you justify all deletions by reference to
specific exemptions of the act. Additionally, if any documents are withheld based on the
Agencys interpretation of any exemption, we request that you provide an index of those
documents as required under Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), cert. denied,
415 U.S. 977 (1974). Specifically, this Vaughn index should describe withheld documents
with enough specificity to determine whether the material is exempt under the act and
must describe each document or portion withheld.

Thank you for your assistance.

Sincerely,


Karl Frisch
Executive Director
Allied Progress





May 24, 2017


U.S. Department of Education
Office of Management
Office of the Chief Privacy Officer
Attn: FOIA Public Liaison
400 Maryland Avenue, SW, LBJ 2E321
Washington, DC 20202-4536

Re: Freedom of Information Act Request


Dear FOIA Public Liaison:

Pursuant to the Freedom of Information Act, Allied Progress requests access to and copies
of all correspondence concerning the Department of Education budget proposed by
President Donald Trump on May 23, 2017 sent by, sent to, or carbon copying (CC) any
individual listed below or any staff member within any office listed below at any point since
January 20, 2017:

Secretary Betsy DeVos
Chief of Staff Josh Venable
Deputy Chief of Staff for Policy Ebony Lee
Senior Counselor Robert Eitel
Senior Advisor to the Under Secretary James Manning
White House Liaison Jana Toner
The Under Secretary of the Department of Education
The Office of Planning, Evaluation and Policy Development
The Office of Federal Student Aid, including the following sub-offices:
o Financial Institution Oversight Service
o Risk Management
o Business Operations
o Policy Liaison and Implementation Staff
o Business Optimization
o Enforcement
o Finance
o Performance Management
The Office of Postsecondary Education, including the following sub-offices:
o Office of Higher Education Programs
o Office of Policy, Planning and Innovation
The Federal Student Loan Support Center
The Default Resolution Group
The Federal Student Aid Ombudsman Group

1220 L Street NW, Suite 100/364 Washington, D.C. 20005-4018


(855) ALD-PRGS toll-free AlliedProgress.org

This should include, but is not limited to, all correspondence involving any of these
individuals which contains any of the following phrases:

Public Service Loan Forgiveness
PSLF
PSL
income-driven repayment
IDR

To be clear, this request seeks only communication pertaining to the 2018 federal budget
proposed by President Trump. Such records can be recognized by the inclusion of any of the
following keywords or phrases:

Trump
white house
budget
Mulvaney
OMB
Reince
Priebus
Kushner
A New Foundation For American Greatness

If possible, I would prefer to receive this information electronically via e-mail at
karl@alliedprogress.org. If you have questions or need additional information, please feel
free to call me at (855) 253-7747.

Fee Waiver Request

Allied Progress requests a waiver of fees associated with processing this request for
records. The subject of this request concerns the operations of the federal government, and
the disclosures will likely contribute to a better understanding of relevant government
procedures by the general public in a significant way. Moreover, the request is primarily
and fundamentally for non-commercial purposes.

Allied Progress requests a waiver of fees because disclosure of the requested information is
in the public interest because it is likely to contribute significantly to public understanding
of government operations and is not primarily in the commercial interest of the requester.
The disclosure of the information sought under this request will document and reveal the
operations of the federal government, including how public funds are spent and how
officials conduct the publics business.

The public has expressed significant and specific concern over apparent and potential
conflicts of interest within the Department of Education.1 Secretary of Education Betsy
DeVos has previously disclosed her familys financial interest in a student loan debt


1 Michael Stratford, DeVos review identifies 102 financial interests with potential conflicts, Politico, January 20, 2017 and
Editorial, Big Worries About Betsy DeVos, New York Times, January 10, 2017.


collector2, and the public has substantial interest in knowing if the actions taken by
Secretary DeVos or any other Department of Education official to revoke loan servicer
guidance were done in an effort to benefit the Secretary or her family by increasing the
number of defaulted student loans.

This request is primarily and fundamentally for non-commercial purposes. As a project of a
501(c)(3) organization, Allied Progress does not have a commercial purpose and the release
of the information requested is not in Allied Progresss financial interest. Allied Progresss
mission is to give voice to hard-working Americans by standing up to Wall Street and other
powerful special interests and holding their allies in Congress and the White House
accountable. Allied Progress will use the information gathered, and its analysis of it, to
educate the public through reports, press releases, or other media. Allied Progress will also
make materials it gathers available on our public website.

Accordingly, Allied Progress qualifies for a fee waiver.

Conclusion

If my request is denied in whole or part, I ask that you justify all deletions by reference to
specific exemptions of the act. Additionally, if any documents are withheld based on the
Agencys interpretation of any exemption, we request that you provide an index of those
documents as required under Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), cert. denied,
415 U.S. 977 (1974). Specifically, this Vaughn index should describe withheld documents
with enough specificity to determine whether the material is exempt under the act and
must describe each document or portion withheld.

Thank you for your assistance.

Sincerely,


Karl Frisch
Executive Director
Allied Progress


2 Betsy DeVos Ethics Statement, Office of Government Ethics, January 19, 2017.





May 24, 2017


U.S. Department of Education
Office of Management
Office of the Chief Privacy Officer
Attn: FOIA Public Liaison
400 Maryland Avenue, SW, LBJ 2E321
Washington, DC 20202-4536

Re: Freedom of Information Act Request


Dear FOIA Public Liaison:

Pursuant to the Freedom of Information Act, Allied Progress requests access to and copies
of all correspondence between any of the individuals or entities listed in Appendix A and
any individual listed below or any staff member within any office listed below at any point
since January 1, 2017:

Secretary Betsy DeVos
Chief of Staff Josh Venable
Deputy Chief of Staff for Policy Ebony Lee
Senior Counselor Robert Eitel
Senior Advisor to the Under Secretary James Manning
White House Liaison Jana Toner
The Under Secretary of the Department of Education
The Office of Planning, Evaluation and Policy Development
The Office of Federal Student Aid, including the following sub-offices:
o Financial Institution Oversight Service
o Risk Management
o Business Operations
o Policy Liaison and Implementation Staff
o Business Optimization
o Enforcement
o Finance
o Performance Management
The Office of Postsecondary Education, including the following sub-offices:
o Office of Higher Education Programs
o Office of Policy, Planning and Innovation
The Federal Student Loan Support Center
The Default Resolution Group
The Federal Student Aid Ombudsman Group

1220 L Street NW, Suite 100/364 Washington, D.C. 20005-4018


(855) ALD-PRGS toll-free AlliedProgress.org
This should include, but is not limited to, all hardcopy, digital (e-mail or other digital
communication) or other correspondence sent by, sent to, or carbon copying (CC) any of
the individuals, entities, or representatives of the entities listed in Appendix A and involving
any Department of Education employee identified above.

If possible, I would prefer to receive this information electronically via e-mail at
karl@alliedprogress.org. If you have questions or need additional information, please feel
free to call me at (855) 253-7747.

Fee Waiver Request

Allied Progress requests a waiver of fees associated with processing this request for
records. The subject of this request concerns the operations of the federal government, and
the disclosures will likely contribute to a better understanding of relevant government
procedures by the general public in a significant way. Moreover, the request is primarily
and fundamentally for non-commercial purposes.

Allied Progress requests a waiver of fees because disclosure of the requested information is
in the public interest because it is likely to contribute significantly to public understanding
of government operations and is not primarily in the commercial interest of the requester.
The disclosure of the information sought under this request will document and reveal the
operations of the federal government, including how public funds are spent and how
officials conduct the publics business.

The public has expressed significant and specific concern over apparent and potential
conflicts of interest within the Department of Education.1 Secretary of Education Betsy
DeVos has previously disclosed her familys financial interest in Performant2, a student loan
debt collector, and the public has substantial interest in knowing if the actions taken by
Secretary DeVos or any other Department of Education official to revoke loan servicer
guidance were done in an effort to benefit the Secretary or her family by increasing the
number of defaulted student loans.

This request is primarily and fundamentally for non-commercial purposes. As a project of a
501(c)(3) organization, Allied Progress does not have a commercial purpose and the release
of the information requested is not in Allied Progresss financial interest. Allied Progresss
mission is to give voice to hard-working Americans by standing up to Wall Street and other
powerful special interests and holding their allies in Congress and the White House
accountable. Allied Progress will use the information gathered, and its analysis of it, to
educate the public through reports, press releases, or other media. Allied Progress will also
make materials it gathers available on our public website.

Accordingly, Allied Progress qualifies for a fee waiver.




1 Michael Stratford, DeVos review identifies 102 financial interests with potential conflicts, Politico, January 20, 2017 and
Editorial, Big Worries About Betsy DeVos, New York Times, January 10, 2017.
2 Betsy DeVos Ethics Statement, Office of Government Ethics, January 19, 2017.


Conclusion

If my request is denied in whole or part, I ask that you justify all deletions by reference to
specific exemptions of the act. Additionally, if any documents are withheld based on the
Agencys interpretation of any exemption, we request that you provide an index of those
documents as required under Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), cert. denied,
415 U.S. 977 (1974). Specifically, this Vaughn index should describe withheld documents
with enough specificity to determine whether the material is exempt under the act and
must describe each document or portion withheld.

Additionally, to aid in the processing of this request, Allied Progress is happy to accept
records as they become available rather than all at once.

Thank you for your assistance.

Sincerely,


Karl Frisch
Executive Director
Allied Progress


Appendix A

Anyone with an email address ending in @performantcorp.com
Performant Business Services, Inc.
Performant Financial Corporation
Performant Recovery
Performant Technologies
DCS Business Services, Inc. (dba Performant)
Diversified Collection Service, Inc.
Parthenon Capital Partners
Lisa Im, CEO/Board Chair of Performant Financial Corporation
Hal Leach, Chief Compliance Officer of Performant Financial Corporation
Hakan L. Orvell, Chief Financial Officer of Performant Financial Corporation
Jeff Haughton, Chief Operating Officer of Performant Financial Corporation
Griffin Gordon, VP Recovery Operations of Performant Financial Corporation
Todd R. Ford, Director of Performant Financial Corporation
Brian P. Golson, Director of Performant Financial Corporation
Bradley F. Fluegel, Director of Performant Financial Corporation
Bruce Hansen, Director of Performant Financial Corporation
William D. Hansen, Director of Performant Financial Corporation