University of Michigan Denies Request for Factual Basis of Christine Gerdes "Russia-Gate" Memorandum; Appeal and Narrowed FOIA Request Follow
In November 2025, the University of Michigan confirmed that two responsive memoranda authored by Associate General Counsel Christine Gerdes existed concerning allegations and related matters involving Dr. Bradley Foerster and Dr. Myria Petrou, including allegations commonly described in contemporaneous records as "Russia-Gate."
The University confirmed that the memoranda exist.
The University withheld both memoranda in full under claims of attorney-client privilege and/or advisory communications.
One of those memoranda remains the subject of ongoing FOIA requests seeking non-privileged factual information underlying statements reflected in the document.
On May 27, 2026, the University denied FOIA Request No. 261581, which sought non-privileged factual and administrative records relating to the two previously identified Gerdes memoranda.
The denial stated that the requests were "overly broad and burdensome," did not sufficiently describe records to permit a search, and invited submission of a narrower request.
Later that same day, an appeal was submitted to University of Michigan President Domenico Grasso.
The appeal requests reversal of the denial and production of non-privileged factual and administrative information relating to the two previously identified Gerdes memoranda.
The University had already identified the two memoranda in FOIA Request No. 260537.
The requests did not seek the memoranda themselves.
Instead, the requests sought non-privileged factual and administrative information relating to those previously identified records.
The appeal questions the University's conclusion that requests tied to two previously identified memoranda cannot be processed because there is "no mechanism for performing a global search of University records" to identify responsive records.
While that appeal remains pending, a narrower FOIA request was submitted on May 29, 2026 concerning only the first Gerdes memorandum.
The revised request does not seek the memorandum itself, attorney-client communications, legal advice, or attorney work product. Instead, it seeks only non-privileged factual material, if any exists, underlying statements reflected in the memorandum.
The memorandum remains withheld.
The request for its factual basis remains.
Related material
University of Michigan Confirms Two Christine Gerdes Memoranda Exist but Withholds Both in Full
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