Michigan’s Department of Licensing and Regulatory Affairs has obstructed public records requests about two physicians charged in America’s first federal FGM prosecution. I know because I filed the requests. LARA’s own internal emails, obtained through subsequent FOIA requests, show the obstruction tactics that protect the doctors at the center of the first federal prosecution of female genital mutilation.
As previously reported, Dr. Jumana Nagarwala and Dr. Fakhruddin Attar were federally prosecuted for performing female genital mutilation on minor girls in United States v. Nagarwala, the first federal FGM case in U.S. history. Both hold active, unrestricted Michigan medical licenses. Neither has any disciplinary record. They currently practice together at Livernois Primary and Urgent Care in Detroit. I have filed over 100 FOIA requests to LARA since January 2026 to find out why. Along the way I tested whether LARA’s appeals officer reads appeals before ruling on them. He failed thirty times out of thirty.
Here is what their own records show they did with those requests.
1. Directing denials before checking
On March 27, 2026, FOIA staff member Katie Hoffman asked FOIA Manager Andrea Moua how to handle eight requests targeting the inboxes of two former Bureau of Professional Licensing (BPL) employees for Nagarwala and Attar-related emails. Within minutes, Moua told her to deny them all.
“I think you can deny and claim Densmore and then say any other potentially responsive records are past retention?” Moua wrote. “Densmore” refers to a prior FOIA production. The strategy was to claim those earlier records already covered the new requests, without checking whether they actually did.
She did not instruct staff to contact the state’s IT department, DTMB, about archived mailboxes. She did not reference a retention schedule. She guessed: “I’m guessing this would also be past retention if the emails would be from 7 years ago.”
All eight denial letters issued April 1 and 2, 2026 matched Moua’s March 27 directive eight for eight. No denial identified a retention schedule number. No denial disclosed whether DTMB had been contacted.
2. Killing and narrowing searches
On January 16, 2026, Moua routed a FOIA request containing the search terms “Nagarwala,” “Jumana,” and “4301071795” to LARA’s Office of Policy and Legislative Affairs for processing. Then she told OPLA liaison Mackenzie Jones to disregard it.
“Mackenzie Jones you can disregard this one, I meant to route another one to you and accidentally did it on here. I will close yours out.”
OPLA handled FGM legislation during the 2017-2018 session, the same period as the Nagarwala prosecution. Jones herself told staff: “We have several files from the 2017-2018 session on legislation regarding the topic.” OPLA was never searched for Nagarwala-specific emails.
The same day, Moua narrowed a second request from “any LARA employee, official, or contractor” down to BPL and OPLA only, and removed “Somali” as a search term. She did this internally. No record in any production shows I was notified.
3. Searching one year of a sixteen-year request
OPLA liaison Mackenzie Jones tasked Regulatory Affairs Officer Elizabeth Arasim with searching her emails for records responsive to two requests. One covered January 1, 2010 to present. The other covered January 1, 2016 to present. Both times, Arasim searched only 2025.
“I checked the email messages I received or sent in 2025 and there were no messages concerning this topic that I received or sent during that time period.”
She wrote that sentence near-verbatim on both requests, one covering ten years and the other sixteen.
4. Searching only the mailbox it knew was gone
I requested emails sent to, sent from, or CC’ing Debra Wright-Chambers, a former BPL employee. LARA denied the requests on retention grounds. Its own determination explained that departed employees’ email is retained for 60 days, that Wright-Chambers left state service in 2025, and then added: “A search of current employees’ inboxes was not conducted as the request did not ask for that.”
The request asked for emails sent to and from her. Every email sent to her by a current employee sits in that employee’s sent items. Every email she sent to a current employee sits in that employee’s inbox. LARA searched the one mailbox it had already deleted, found nothing, and certified that no records exist.
5. Silently excluding identified records
On January 5, 2026, OPLA Legislative Analyst Griffin Drew found a SharePoint folder for Michigan House Bill 4190, a bill restricting gender reassignment procedures for minors. He flagged it to liaison Mackenzie Jones as potentially responsive to a FOIA request seeking records containing terms like “FGM,” “female circumcision,” and “female genital cutting.”
Jones reviewed the records and excluded them. “I reviewed the records and I do not believe they are responsive to the requestor’s request.”
A bill restricting genital procedures on minors is exactly the kind of record that OPLA’s legislative analyses and briefing materials would discuss alongside FGM policy. Jones was wrong about my intent, and the request didn’t ask her to guess it. It asked for records containing specific keywords. I wanted those records.
Instead, she substituted her editorial judgment for the keyword-matching the request demanded. I was not notified. LARA’s final response represented a complete production. The only reason this exclusion is documented is because I later obtained the processing emails through a separate FOIA request.
When I later filed a request for Drew’s emails on the same subject, LARA estimated the fee at $90.48, then billed $407.14 and withheld part of the records as deliberative. Sandoval upheld in two business days without addressing the appeal’s MCL 15.232 argument, which his determination quoted in full.
6. Lying about their own document system
On June 8, 2026, LARA denied two requests seeking metadata from BPL’s electronic document management system. Both denials said BPL IT staff is “not aware of” the Laserfiche system.
Ten days earlier, LARA had produced a screenshot of BPL’s own Laserfiche interface, complete with the Laserfiche logo and system identifiers. Processor Phillip Hendges signed both the production containing the screenshot and the denial claiming the system was unknown.
Two processors used nearly identical “not aware of Laserfiche” language, suggesting a shared instruction. On appeal, Adam Sandoval upheld the denial and declined to address the screenshot contradiction.
7. Certifying records don’t exist while calling the request too vague to search
On July 27, 2026, LARA denied a request on two grounds in a single letter signed by Phillip Hendges.
First, LARA certified that “the requested information does not exist within LARA under the description given or another reasonably known to LARA.” BPL affirmed “there are no other documents in the files maintained in our database” matching the request.
Second, LARA said the records were “not sufficiently described to enable the agency to find them.” BPL explained: “We cannot operate on vague descriptions. We must be able to determine where to search for a record.”
A certification that records do not exist means LARA searched and found nothing. The second ground says LARA could not determine where to search. Both appear in the same determination. One of them is not true.
8. Removing evidence from productions
I filed identical metadata requests on the Nagarwala and Attar complaint files. The Attar file produced an audit log. The Nagarwala file could not. “No audit log could be created.” Same request. Same system. Same fee. The file at the center of the federal prosecution has no audit trail. The other one does.
I filed five requests targeting Director Marlon Brown’s inbox for “Nagarwala,” “Attar,” “Brendon,” “Marotta,” and “Hegemon.” One came back: Brown forwarded my fee appeal to Sandoval and Gobbo, CC’ing Pendleton and McGonagle, eleven minutes after I sent it. The Director was aware of the investigation from its first month. But when LARA searched in June, “Nagarwala,” “Attar,” and “Hegemon” all returned zero results. Over 100 FOIA requests about two physicians, and the Director’s inbox contained no email mentioning either physician or the publication investigating them.
9. Calling different requests “duplicates”
LARA closed requests as “duplicates” when they were not duplicates. A request for emails containing “Nagarwala” returns different records than a request for emails containing “Attar.”
In May 2026, I filed seven requests on the inbox of Director of Legal Affairs Nicholas Gobbo. Each sought a different thing: “Brendon,” “Marotta,” “Nagarwala,” “Attar,” “Graham” over two date ranges, and any email with PGraham@bcbsm.com in the To, From, or CC fields. That last one was not a keyword search at all. It was a filter for the Blue Cross email address of Dr. Peter Graham, the Board of Medicine reviewer who had authorized Attar’s investigation in 2017. LARA kept one request open, closed the other six as “duplicates” of it, and billed the six under the one.
LARA’s justification: “These 7 requests all require the subject of the requests to search, so they have been combined and the other requests are closed.”
Closing a request as a “duplicate” eliminates the right to appeal that request individually. When I appealed, Sandoval recharacterized the appeals as fee-only disputes and refused to address whether the closures themselves were proper. His reason: “because LARA has not completed processing the request... there are no available statutory rights to an appeal under the FOIA, MCL 15.240(1), as LARA has not made a final determination denying your request.” LARA closed the request, then said the closure was not a final determination, so there was nothing to appeal.
His first determination also counted the seven requests as six, listed six search terms, and altered the quotation of LARA’s own fee notice from “These 7 requests” to “[6] requests.” The seventh request, the second “Graham” search, had disappeared. After I pointed this out, LARA issued an amended determination restoring the “7.” The amended determination still addressed none of the five arguments in the appeal. The requests remain closed. The appeal rights remain dead.
10. Manufacturing fees
Sandoval’s own certified math defeats his own conclusion. His appeal rulings show each keyword search costs approximately $10 in employee time. LARA’s published no-fee threshold is $20. The vast majority of individual requests fall below it.
Between June 5 and June 12, 2026, LARA consolidated 16 batches of individually filed requests into combined invoices totaling $1,098.98. The consolidation created the fee.
LARA processed requests selectively. Three requests targeting OPLA Legislative Analyst Griffin Drew’s inbox, filed the same day and overlapping in date range, were processed individually. Investigation-related keyword searches filed the same day were consolidated. The only variable is subject matter.
LARA staff anticipated in January that cost would stop me. When my first requests went to several bureaus, MOAHR Departmental Specialist Sheila Boensch wrote “I know the estimate would be outrageous.” On whether I would ask for an estimate: “I’m sure he won’t.” At BPL, Katie Hoffman, who compiled the $12,792.93 estimate on my first three requests, wrote that the manual search method “does not represent the most streamlined approach” and that “a DTMB search was overruled by other management.” LARA quoted me a fee for a method its own fee compiler said was not the most streamlined, while an alternative existed and was blocked by unnamed management.
11. Discouraging payment with false characterizations
On May 22, 2026, LARA granted a request for Jon Campbell’s emails containing closure-related terms during the July through September 2018 closure window. The grant letter contained an editorial advisory: “after a preliminary review, none of the results located contain information regarding the licensees and files customer has been pursuing.” The advisory characterized all hits as generic uses of common terms and concluded the records “will not be truly responsive.”
I paid the fee. On July 15, 2026, LARA issued a partial denial. LARA redacted the responsive records under MCL 333.16238(1), which protects information from a complaint file “investigated and closed” without a formal complaint, and under MCL 15.243(1)(g), which protects attorney-client communications between BPL and the AG.
Both exemptions presuppose the records contain complaint-file content and privileged communications from the closure process. LARA told me the records were irrelevant to my investigation. Then LARA applied exemptions that only apply if the records are directly relevant to my investigation.
12. Denying media status while granting it to others
FOIA staff member Katie Hoffman proactively asked whether to classify my requests as media requests after seeing my press email address. On March 16, 2026, Moua said no: “We aren’t considering this requestor a media requestor.”
Eight days later, Moua coordinated proactive courtesy outreach for Metro Times reporter Steve Neavling. She suggested reaching out “to make sure they don’t want to narrow/amend their request at all before we send the bill.” Communications director Emily Fitzgerald called Neavling twice. LARA has zero written policies governing media classification. LARA’s own certification confirms no written criteria exist. Moua classified three other journalists as media requestors during the same period she denied the classification to me.
My requests received the opposite of what Neavling got: consolidation to inflate fees, denial of media classification, denial of public interest fee waiver, and no proactive outreach.
I later filed a FOIA request for all of Moua’s emails containing “media requestor.” The production contained three chains showing her granting the status to other journalists. Her March 16 email denying it to me contains the phrase “media requestor” twice. It meets every parameter of the request. It is not in the production.
13. Inflating fees and destroying the Medscape trail
In December 2018, LARA told Medscape reporter Marcia Frellick that it had “open investigations” on both Nagarwala and Attar. FOIA-obtained records show the Nagarwala investigation was closed on September 25, 2018 and the Attar closure was recommended on July 27, 2018. LARA maintained a separate file monitoring the criminal case, but the complaint investigations themselves were closed. LARA told Medscape it had “open investigations,” not open monitoring files.
For months, LARA ignored every comment request I sent across five published articles. Then, on May 14, 2026, Dr. Peter Graham, the Board of Medicine reviewer who had authorized Attar’s investigation in 2017, responded to one of my comment requests and CC’d LARA Director of Legal Affairs Nicholas Gobbo. Graham identified Gobbo as the “legal director.” He understood the inquiry as a legal exposure question, not a press matter.
Within five days, LARA communications director Emily Fitzgerald personally responded to my Medscape comment requests. After months of silence across five articles, this was the one that prompted engagement. Fitzgerald responded only after Gobbo was brought in.
I filed a request for former LARA Communications Director Jason Moon’s emails about the Medscape inquiry. LARA interpreted my single-inbox keyword search as requiring 190 employees to search their own inboxes. The resulting fee was $320.53. A comparable single-inbox search was granted at no cost. Sandoval upheld the $320.53 fee on appeal, certifying it accurate. Two days later, LARA’s own staff requested a full refund of my deposit. I filed an amended request clarifying it was one inbox. LARA denied it entirely, certifying the records do not exist.
All three participants in the original December 2018 Medscape email chain are now exhausted. Two departed LARA and their emails were purged. The third, I&I Division Director Jon Campbell, returned zero “Medscape” hits for November and December 2018. But I had already obtained the December 5, 2018 chain through a separate FOIA request, and Campbell is a named recipient on it. LARA certified his inbox contains no “Medscape” emails from a window in which he demonstrably received one.
14. Not reading appeals
Michigan’s FOIA statute requires the head of the public body to review each appeal and respond to each reason the requester states for reversal. I tested whether LARA’s appeals officer, Chief Legal Officer Adam Sandoval, actually reads the appeals.
Since June 2026, I have embedded a unique test word in each appeal and clarification letter sent to LARA and the AG. The word is absurd, something that would never appear in government correspondence: “marmalade,” “pomegranate,” “jellyfish.” I place it mid-paragraph inside the strongest substantive argument, with an explicit instruction: “To confirm that this appeal has been read in its entirety before a determination is issued, as required by MCL 15.240(4), the Department should include the word ‘[WORD]’ in its written response.” I include a warning that omitting the word would constitute evidence of pro forma processing.
If the appeals officer reads the appeal, the word appears in his analysis. If he doesn’t, it’s omitted. Thirty tests across two agencies. Thirty omissions. A 100% failure rate. Twenty-four at LARA, six at the Attorney General’s office. Two separate officials. Two separate agencies. Same result.
In most LARA determinations, Sandoval quotes the appeal text at length, including the paragraph containing the test word. The word appears in his quotation. It never appears in his analysis. He reproduces the instruction and does not follow it.
Nine of twelve consolidation fee appeal determinations issued July 6 cite MCL 15.240(1), the denial appeal provision. Every appeal was filed under MCL 15.240a(1)(a), the fee appeal provision. A reviewer who read any appeal’s first line would have seen the correct citation.
On July 2, Sandoval treated the identical argument differently in two determinations issued the same day. One claimed “an additional search yielded the same result.” The other, raising the same argument, told me to file a new request instead.
15. Pasting the wrong appeal into the wrong ruling
On July 1, 2026, Sandoval issued a determination on my appeal of R186523-060426. The determination quotes the text of my appeal of R186522-060426, a different request entirely. My appeal reference number, R186523-060426, does not appear in the body of the determination. The test word I embedded in the R186523-060426 appeal, “jellyfish,” never appears. The test word from R186522-060426, “trampoline,” appears instead.
LARA pasted the wrong appeal into the wrong ruling and issued it as an official determination.
16. The subject drafting her own appeal rulings
Sandoval sent two amended appeal determinations on June 18, 2026 as Word documents. The embedded metadata on both files shows “Last Modified By: Moua, Andrea (LARA).” She edited one in five minutes. She edited the other in six.
On June 9, 2026, Moua emailed Sandoval two complete draft appeal determinations at 10:23:57 AM. These were dense legal documents addressing two different requesters, two different record types, and two different statutory frameworks. Sandoval replied “Approved. Thanks, Andrea.” at 10:24:40 AM. Forty-three seconds, or sixty-three by the other production’s timestamp.
Andrea Moua is LARA’s FOIA Manager. She directed the pre-scripted denials. She killed the OPLA search. She narrowed the request scope. She denied me media classification. She executed the consolidation decisions. She is the subject of the appeals Sandoval was ostensibly reviewing.
She wrote her own appeal rulings for Sandoval’s signature.
17. Withholding the closure memos
On July 27, 2018, AAG Bridget K. Smith authored two memos recommending closure of the state’s involvement in the Nagarwala and Attar disciplinary matters. These memos, Documents 72 and 78 on the AG’s privilege log, have been withheld in full under attorney-client privilege across every FOIA request and appeal.
The AG claims these are privileged legal advice. In BPL’s own complaint-management system, MiPLUS, the same documents are filed as “Supporting Documentation” alongside investigation reports, complaint source material, and Board Review responses. BPL staff uploaded them in December 2021, categorized them identically to non-privileged records, and staff who open the complaint record can view or download them. The memos withheld as privileged legal correspondence function in LARA’s own system as operational closure records.
The AG’s response to my first appeal addressed one of four arguments and got it wrong. The response to my second appeal reproduced the original denial verbatim, added a lawyer referral, and engaged with no arguments. PDF metadata reveals the response was prepared by AAG Sandra L. Ellis, a Court of Claims litigator. The person who drafted the denial is the person who would defend that denial in court.
18. Coordinating across agencies
On May 18, 2026, both LARA and the AG denied closure memo appeals on the same day using identical scare-quote formatting around the word “appeal.”
On June 29, 2026, the AG’s FOIA Coordinator collapsed seven individually filed requests into a single invoice for $534.47. The requests had been filed with explicit instructions to process each independently. The AG ignored the instructions and used the same consolidation tactic LARA had deployed against me three weeks earlier.
AG records show AAG Sandra Ellis and LARA Director of Legal Affairs Nicholas Gobbo have an ongoing working relationship on FOIA matters. Gobbo’s calendar for the disputed processing period contains a “FOIA Discussion re: METRC” meeting on June 12, 2026 with Ellis as an optional attendee and Moua also optional. That meeting occurred the same day Ellis drafted the AG’s denial of my second appeal on the closure memos.
19. Using legal action to deny requests
On July 30, 2026, I filed a pro se complaint in the Michigan Court of Claims challenging LARA’s consolidation fees and duplicate closures. On August 25, LARA began issuing blanket denials on my pending requests, citing MCL 15.243(1)(v), which exempts records relating to litigation between the requester and the public body.
Four denials. Two processors. Identical language. The exemption covers every category of request I have filed: 2026 FOIA processing mechanics, 2026 investigation substance, the 2018 closure window, and the 2017-2018 investigation period. One denial was applied retroactively to a request LARA had already extended for the purpose of searching and reviewing records. The extension letter cited search time. The denial references no search.
Every request LARA has answered since August 25 has been denied. The statute provides for the exemption. My argument is that 2017-2018 investigation records do not “relate to” a 2026 lawsuit about processing fees. LARA has made no such distinction. It applied the exemption to everything.
I filed a lawsuit over LARA’s fees and closures. LARA used the lawsuit itself to deny disclosure.
What LARA Didn’t Spend Time On
While LARA spent nine months deploying these tactics against records requests about Dr. Nagarwala, it renewed her medical license.
The renewal was processed in approximately seven minutes with no human review and no complaint history screening. She self-reported Garden City Hospital as her employer under oath. Her license is active through June 19, 2029.
The agency that devoted nine months to obstructing records requests about whether it disciplined this physician spent no human resources evaluating whether or not it should license a physician who had been federally charged with FGM.
How This Impacts My Reporting
Everything I have published about the Nagarwala and Attar complaint files is based on records LARA provided, presented as accurate. When I have reported that no records of certain events exist, I am reporting what LARA told me. The findings rest on their productions and their certifications.
LARA has now been caught lying to the press (the December 2018 Medscape statement), issuing denials before verifying whether records exist (Moua’s March 27 directive), omitting responsive records from productions (the missing media classification email), certifying that a custodian’s inbox contains no records from a window in which LARA already produced records showing that custodian received the email in question (Campbell and Medscape), and mischaracterizing the content of records to discourage payment (the Campbell editorial caveat). Given these documented patterns, I cannot be certain that the information LARA has provided me is accurate, complete, or honest.
Previous reporting that relied on “no responsive records” certifications may have been based on lies. I will continue to report what the records show. But readers should understand that this agency has a documented record of misrepresenting what it has and what it gives out.
Is This Legal?
I am not a lawyer. What follows is my own statement of opinion.
No, I do not believe what LARA is doing is legal.
Michigan’s FOIA statute requires agencies to conduct reasonable searches, respond truthfully, and review appeals in good faith. The records documented in this article show an agency that directed denials before checking whether records existed, lied about its own document management system, issued certifications it had no factual basis to issue, and had its FOIA Manager edit the appeal rulings reviewing her own decisions.
Can They Be Held Accountable?
Again, I am not a lawyer. What follows is my own statement of opinion.
No, I see no possible accountability within the existing system.
FOIA cases against state agencies in Michigan go to the Court of Claims. Filing requires fees and, realistically, legal representation. The statute does provide remedies: $1,000 in punitive damages for arbitrary and capricious denials under MCL 15.240(7), $500 for excessive fees under MCL 15.240a(7), and a civil fine of $2,500 to $7,500 per occurrence for willful and intentional violations under MCL 15.240b. But these penalties can never be assessed against an individual. They are assessed against the public body. Andrea Moua, Adam Sandoval, and Nicholas Gobbo face no personal financial consequence for anything documented in this article.
Individual officials are separately shielded by qualified immunity under federal civil rights law. To hold them personally liable under 42 U.S.C. § 1983, I would need to prove they violated “clearly established” constitutional rights. Proving that would require an expensive and challenging legal action.
I filed suit. LARA used the lawsuit to deny every request it has answered since. The system for holding this agency accountable is the system the agency controls.
There appears to be no legal remedy against the people responsible.
Who Is Responsible
The people responsible for what is documented in this article might prefer to remain a faceless bureaucracy. Their full legal names are on the documents.
Those names are:
At LARA:
Marlon Brown, Director
Courtney Pendleton, Chief Operating Officer
Adam Sandoval, Chief Legal Officer and Deputy Director
Nicholas Gobbo, Director of Legal Affairs
Andrea Moua, FOIA Manager
Jon Campbell, Investigation & Inspections Division Director
Phillip Hendges, FOIA Processor
DAndrea Smith, FOIA Processor
Katie Hoffman, BPL FOIA Staff
Emily Fitzgerald, Communications Director
At the Michigan Attorney General’s office:
Bridget K. Smith, Assistant Attorney General, Licensing & Regulation Division
Sandra L. Ellis, Assistant Attorney General, State Operations Division
Eric Jamison, Division Chief
Christy Wendling-Richards, FOIA Coordinator
At LARA’s Office of Policy and Legislative Affairs:
Mackenzie Jones, Department Specialist
Elizabeth Arasim, Regulatory Affairs Officer
Two physicians charged in the first federal FGM prosecution in American history continue to practice with active, unrestricted Michigan medical licenses.
Every person named above either participated in closing the investigations that should have led to their discipline, obstructed the records requests that revealed that closure, or both.
The Michigan House Oversight Committee, chaired by Rep. Jay DeBoyer, has jurisdiction over LARA. The Oversight Subcommittee on Child Welfare Systems, chaired by Rep. Luke Meerman, has received materials related to this investigation. Neither committee has acted.
This investigation is funded by reader donations. If you want to support, contribute at gofundme.com/f/expose-medical-board-for-licensing-an-fgm-doctor.