Keystone United

To Whom It May Concern:

This is a request under the Freedom of Information Act. I hereby request the following records:

Records relating to or mentioning Keystone United, AKA Keystone State Skinheads (KSS). Keystone United, known until 2009 as the Keystone State Skinheads (KSS), is one of the largest and most active single-state racist skinhead crews in the country.

While its members attempt to project a mediagenic image of being part of a new breed of more sophisticated and less spasmodically violent skins, the truth is that the group’s members have been convicted of a string of remarkably violent attacks dating back to at least 1998, ranging from bar brawls to murder. Keystone United frequently sponsors white-power picnics and music festivals across Pennsylvania, including the annual "hatecore" event known as "Uprise."

The Keystone State Skinheads (KSS) formed near Harrisburg, Pa., in 2001. Like most racist skinhead outfits, the group says it is dedicated to white supremacy and cleaning up white society so that America will be more like "many other once great European nations." KSS says it is committed to "being active in our communities, public awareness, contacting local politicians, or just simply showing people we are not ashamed of who we are." Though the group holds picnics, hikes and other events it claims are "family-friendly," it has a history of criminal violence.

Membership quickly spread across the state, with associates in neighboring New Jersey and Maryland. In its early years, KSS was associated with the notoriously violent Hammerskin Nation — KSS helped organize the 2003 Hammerfest, a skinhead rock festival.

As KSS membership has flourished over the course of the crew's relatively brief history, the rap sheets of many of its prominent members have grown at a brisk pace as well. In June of 2002, three KSS members — Douglas Sonier, Joseph Hoesch and co-founder Robert Gaus — were arrested for assaulting a man who asked them to stop throwing food at his table at a diner in Feasterville, Pa., near Philadelphia. The three pleaded guilty to simple assault and were given suspended sentences.

In September that same year, three more KSS members — Todd Sager, Jason Hayden and Christopher Keough — attacked former KSS member Christopher Morosko after he refused to return his KSS colors. In March 2003, all three assailants pleaded guilty to assault and were sentenced to time served.

Also in March 2003, another three KSS members — Keith Carney, Steve Monteforte and Steven Smith — were arrested in Scranton for beating up Antoni Williams, a black man, using stones and chunks of pavement. Smith, a co-founder of the KSS, is a former Aryan Nations member and former leader of the Philadelphia chapter of National Association for the Advancement of White People, which was created by former Klan leader David Duke but is no longer associated with him. Smith was recruited into the neo-Nazi movement when he was a soldier at Fort Bragg, N.C. Carney is a former member of the neo-Nazi National Alliance who was arrested in December 2001 for placing National Alliance stickers on the Korean War and Vietnam Veterans memorials in Philadelphia. In the 2003 case, Smith and Monteforte pleaded guilty to terrorist threats and ethnic intimidation, with Monteforte getting a suspended sentence of a year's probation; Smith received a 60-day sentence and probation. Carney was charged with violating the terms of his probation from a previous criminal conviction and sentenced to a year in prison.

In April 2003, two KSS Lancaster chapter skinheads were charged with making terroristic threats and ethnic intimidation for racist and threatening comments directed at three black people in an area bar. The next documented violent incident involving KSS came in January 2006, when KSS Wilkes-Barre region leader Jason Honeywell was arrested for allegedly stabbing two anti-racist SHARP (Skinheads Against Racial Prejudice) skinheads outside an all-ages punk rock club. The stabbing occurred during a melée that erupted in the club and spread outside after KSS members made sieg-heil salutes and obscene gestures toward the black singer of the band River Side Riot, which was performing at the time. Both SHARPs — Timothy David Alonso and Sean Fitzmaurice — were severely injured. Honeywell was charged with four counts of aggravated assault.

Two weeks after the stabbings, the leader of the Pittsburgh and Greensburg chapters of the KSS, Todd Sager, was charged with criminal solicitation to commit homicide and criminal solicitation to commit aggravated assault. Sager was accused of ordering another KSS member, Edward Robert Locke, to stab a third KSS member during a brawl at a New Stanton sports bar. The fight erupted after the skinheads began allegedly harassing a mixed-race couple. Locke was charged with aggravated assault and attempted murder. The attempted murder charge was later dismissed.

In January 2007, KSS members Kenneth Hoover and Charles Marovskis were arrested for the 1998 murder of two homeless men in Tampa, Fla. At the time of the killing, the two were members of the Tampa division of Blood & Honour. The victims were attacked with a tire iron and an axe.

In 2009, KSS changed its name to Keystone United.

Please conduct a search of the Central Records System, including but not limited to the Electronic Surveillance (ELSUR) Indices, the Microphone Surveillance (MISUR) Indices, the Physical Surveillance (FISUR) Indices, and the Technical Surveillance (TESUR) Indices, for both main-file records and cross-reference records of both HQ and all field offices for all relevant names, agencies, organizations, companies and events including but not limited to those cited in the previous paragraphs and/or links as well as a cross-reference with the Southern Poverty Law Center to include any information provided by the SPLC. My request includes but is not limited to 137, 157, 176, 177, 183, 184, 188, 214 and 266 files. If previously released records are available, then I request a rolling release consisting of those records while additional records are located and processed for release.

I am a member of the news media and request classification as such. I have previously written about the government and its activities for AND Magazine, MuckRock and Glomar Disclosure and have an open arrangement with each. My articles have been widely read, with some reaching over 100,000 readers. As such, as I have a reasonable expectation of publication and my editorial and writing skills are well established. In addition, I discuss and comment on the files online and make them available through the non-profit Internet Archive, disseminating them to a large audience. While my research is not limited to this, a great deal of it, including this, focuses on the activities and attitudes of the government itself. As such, it is not necessary for me to demonstrate the relevance of this particular subject in advance. Additionally, case law states that “proof of the ability to disseminate the released information to a broad cross-section of the public is not required.” Judicial Watch, Inc. v. Dep’t of Justice, 365 F.3d 1108, 1126 (D.C. Cir. 2004); see Carney v. U.S. Dep’t of Justice, 19 F.3d 807, 814-15 (2d Cir. 1994). Further, courts have held that "qualified because it also had “firm” plans to “publish a number of . . . ‘document sets’” concerning United States foreign and national security policy." Under this criteria, as well, I qualify as a member of the news media. Additionally, courts have held that the news media status "focuses on the nature of the requester, not its request. The provision requires that the request be “made by” a representative of the news media. Id. § 552(a)(4)(A)(ii)(II). A newspaper reporter, for example, is a representative of the news media regardless of how much interest there is in the story for which he or she is requesting information." As such, the details of the request itself are moot for the purposes of determining the appropriate fee category. As such, my primary purpose is to inform about government activities by reporting on it and making the raw data available and I therefore request that fees be waived.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 20 business days, as the statute requires.

Sincerely,

Michael Best

I am appealing the decision to not perform the cross-reference searches and field office searches explicitly requested.

What page count are we looking at if we remove cross-references?

Sorry for the delay! Could you tell me the file types, the captions, or the classification codes?

Any suggestions on how to reduce the scope of this one? Any obvious duplications, etc.?

Let's just process the whole thing. Thanks!