Aaron Greenspan, the plaintiff seeking the release of United States government records relating to President Bola Ahmed Tinubu, has asked a federal court in Washington, D.C., for permission to put four questions to the Nigerian president over a series of alleged denial-of-service attacks on his legal research website, PlainSite.
In a reply filed on September 28 in Greenspan v. Executive Office for U.S. Attorneys, Case No. 1:23-cv-01816-BAH, Greenspan argued that Tinubu, who has intervened in the case, had not denied that he, his government or anyone acting on his behalf, including DCI Group AZ, L.L.C., was involved in the attacks.
“If that is so, the four requests for admission can be answered in minutes,” Greenspan wrote.
The filing does not allege that Tinubu or DCI Group carried out the attacks, and it contains no evidence identifying who was responsible for them.
Tinubu’s opposition to Greenspan’s request, filed as ECF No. 109, argued that “there is no independent verification” of the alleged attacks.
Greenspan rejected that argument, pointing to a mitigation report attached to his earlier motion. According to his filing, the report was generated on May 29, 2025, by PlainSite’s internet service provider through its own mitigation system.
The report, as described by Greenspan, recorded traffic of 941.9 megabits per second and 1.8 million packets per second at PlainSite’s protected address. About half of the traffic was identified and dropped as hostile, while 110,700 source hosts were blocked.
Greenspan argued that Tinubu’s opposition did not address the report, challenge its authenticity or provide contrary technical evidence.
The plaintiff also told the court that the alleged attacks resumed after he filed his motion on September 9.
In a supplemental declaration made under penalty of perjury, Greenspan said the number of individual addresses blocked by PlainSite’s firewall had fallen to about 69,000 by September 7, after the acute attacks stopped in late August.
He said the number subsequently began rising sharply around September 18, reached approximately 500,000 on September 23 and stood at 390,957 on the morning of September 24.
Greenspan noted that September 18 was the original deadline for the government’s reply to his summary-judgment cross-motion before the deadline was extended to September 23, the same day Tinubu’s legal team and the Justice Department filed their respective submissions.
According to Greenspan, the latest attacks were less disruptive than those recorded in August.
He said the August attacks drove the server’s load average above 300, while the September attacks “did not overwhelm the server” because PlainSite’s adaptive firewall automatically identified and blocked attacking networks.
Greenspan said the firewall dropped more than 200,000 packets per minute on September 23, while total web traffic exceeded 480,000 packets per minute.
He explained that some of the largest spikes recorded on September 23 and 24 appeared under traffic classified by the firewall as ordinary visitor traffic because attack traffic was initially counted there before its sources were identified and blocked.
Greenspan’s latest filing follows his September 9 request for limited discovery concerning the alleged attacks.
He is seeking permission to serve Tinubu with four requests for admission concerning whether the president, the Nigerian government or people acting on his behalf directed, funded, authorised or facilitated attacks on PlainSite.
He also seeks information concerning DCI Group AZ, a Washington public affairs firm that Greenspan has previously linked to the Nigerian government through filings under the Foreign Agents Registration Act.
Greenspan’s argument is that the timing and pattern of the alleged attacks justify limited discovery into who may have been responsible.
In an earlier filing, however, he acknowledged that timing alone does not establish responsibility, stating: “Correlation is not attribution.”
Greenspan also accused Tinubu’s lawyers of making unsupported assertions about the alleged attacks and of mischaracterising statements contained in his earlier filings.
He cited Rule 11 of the Federal Rules of Civil Procedure in making the argument.
He further said the Justice Department defendants had failed to respond to his motion within the period provided under Local Civil Rule 7(b).
The underlying lawsuit concerns Greenspan’s efforts to obtain US government records relating to Tinubu through the Freedom of Information Act.
Tinubu has intervened in the case and opposed the disclosure of records sought by Greenspan, while the US government defendants have also defended their positions concerning the requested records.
Greenspan’s filings have brought the alleged cyberattacks into the wider dispute over the records, but the filings reviewed do not establish that Tinubu, the Nigerian government or DCI Group carried out or ordered the attacks.
The plaintiff is instead asking the court to allow limited discovery so that he can seek answers about whether Tinubu, Nigerian government officials or persons acting on their behalf had any role in directing, funding, authorising or facilitating the attacks.
The court had not ruled on Greenspan’s request in the filings reviewed.
The latest filing therefore establishes that Aaron Greenspan is seeking permission from the federal court to question President Bola Ahmed Tinubu about the alleged attacks and to investigate possible connections involving the Nigerian government and DCI Group AZ.