Name: Christine Brown
Affiliation: Nesenoff & Miltenberg
Location: UConn Storrs
Request Date Start: Withheld.
Request Date End: Withheld.
Details: This request pertains to the email communications and OIE reports outlined below. Please provide the email communication records with responses clearly listed for each specific portion:
Portion A: All email communications between UConn employees Junbo Zhao (junbo@uconn.edu) and (Susan) Shan Zuo (shan.zuo@uconn.edu) from August 1, 2021, until June 9, 2024. This includes all emails, including attachments, that mention my client, UConn employee Zongjie Wang (searchable by Zongjie Wang, Zongjie, or Lisa). I require all email communications regarding my client in any context.
Portion B: All email communications sent by (Susan) Shan Zuo (shan.zuo@uconn.edu) covering the following aspects:
Portion B.1: Communications to the United States Department of Energy (email addresses ending in @__.doe.gov, where __ can be searched as "ee", "hq", etc.). Titles of interest include “Urgent Concern: DoE PI’s Export Control Violations and Potential National Security Risks” or “Concerns about Dr. Zongjie Wang’s Export Control Violation and National Security Concerns.” Keywords to search include “Export Control Violation,” “National Security Risks,” and “National Security Concerns.” I need all related email communications from March 19, 2024, to June 9, 2024.
Portion B.2: Communications to the United States National Science Foundation (email addresses ending in @nsf.gov). Titles of interest include “Urgent Concern: DoE PI’s Export Control Violations and Potential National Security Risks” or “Concerns about Dr. Zongjie Wang’s Export Control Violation and National Security Concerns.” Keywords to search include “Export Control Violation,” “National Security Risks,” and “National Security Concerns.” I need all related email communications from March 19, 2024, to June 9, 2024.
Portion B.3: Communications to UConn leadership and the OIE office regarding any information, including allegations and evidence, against my client, Zongjie Wang. Recipients include John Chandy, Emmanouil Anagnostou, Kazem Kazerounian, Pamir Alpay, Anne D’Alleva, Radenka Maric, Sarah Chipman, and Cameron Liston. This request covers all communications from August 1, 2021, until June 9, 2024.
Portion B.4: Communications to any recipients (both internal and external to UConn) regarding my client, Zongjie Wang, from August 1, 2021, until June 9, 2024.
Portion C: This request relates to evidence provided as part of OIE Case No. 24-0044 regarding my client, Zongjie Wang. I formally request the release of all documents and records about my client pertaining to this investigation. Documents of specific interest include letters/interview evidence provided as evidence against my client, especially those provided by (Susan) Shan Zuo and any other involved parties.
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