The United States district court for the District of Columbia has rejected limited discovery requests filed by Aaron Greenspan, an American and founder of PlainSite, in a case concerning Freedom of Information Act (FOIA) requests for records relating to the alleged drug investigation involving President Bola Tinubu.
Beryl Howell, the district judge, ruled on October 30, 2026, that the limited discovery requests were “irrelevant” to the FOIA case.
In the context, the limited discovery refers to a request for permission to obtain specific information from another party to a case.
In 2022 and 2023, Greenspan filed 12 FOIA requests with six different US federal government agencies, seeking information relating to the criminal investigation information of a Chicago heroin ring that operated in the early 1990s.
Greenspan sought investigative records about four named individuals allegedly associated with the drug ring.
The individuals are Tinubu, Lee Andrew Edwards, Mueez Abegboyega Akande, and Abiodun Agbele.
Five of the US agencies issued Glomar responses to Greenspan’s FOIA requests, saying they could neither confirm nor deny the existence of the requested records.
In April 2025, the US district court held that the Glomar responses issued by the Federal Bureau of Investigation (FBI) and Drug Enforcement Administration (DEA) were “improper and must be lifted”.
The judge ruled that the FBI and DEA failed to provide information to “establish a cognizable privacy interest exists in keeping secret the fact that Tinubu was a subject of criminal investigation”.
Following the court judgement, FBI and DEA released some of the investigative records but withheld the majority of the information. Tinubu’s name did not appear in the released documents.
Recently, Greenspan returned to court to compel the FBI and DEA to release the withheld information and challenged the FOIA exemptions cited by the US agencies.
Amid the ongoing legal battle over the FOIA requests, Greenspan sought the court’s permission to obtain information from Tinubu over alleged cyberattacks on his website.
He also sought documents relating to DCI Group, a US-based public affairs and lobbying firm, hired by the federal government in a $9 million deal to communicate its efforts to protect Christians in Nigeria to the US government.
‘LACK OF RELEVANCY TO CASE AT HAND IS FATAL’
Delivering judgement on the discovery requests, Howell ruled that they were not directed at the US agencies involved in the case or their activities.
The judge held that determining the source of distributed denial of service (DDoS) attacks on Greenspan’s website could not resolve the “adequacy of the FBI and DEA’s searches and withholdings in response to plaintiff’s FOIA requests”.
“Without accusing intervenor-defendant (Tinubu) of being responsible for those DDoS attacks, plaintiff argues that the attacks suggest ‘behavior of someone who is A) watching this case closely and B) has a strong incentive to prevent public access to case and case-related materials,’ and that obtaining this discovery could help uncover the source,” the judge said.
“There is simply no “reasonable likelihood that allowing discovery . . . will lead to discovery of evidence relevant to the underlying action,” so plaintiff’s motion for limited discovery is denied.
“In addition, since plaintiff’s request for the Court to take judicial notice of certain records was filed solely to support plaintiff’s discovery motion, and the resolution of that discovery motion is not affected by the existence and contents of those records, plaintiff’s motion to take judicial notice is denied as moot.”