Aaron Greenspan, the plaintiff seeking the release of U.S. government records relating to President Bola Ahmed Tinubu, has asked a federal court in Washington for permission to put four questions to Tinubu over a series of denial-of-service attacks on his 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 said 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 filings, however, do not allege that Tinubu or DCI Group carried out the attacks, and they contain no evidence identifying who was responsible for them.

Greenspan Challenges Tinubu’s Claim Of No Independent Verification

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 claim, pointing to a mitigation report attached to his earlier motion and generated on May 29, 2025 by PlainSite’s internet service provider from its own mitigation system.

According to Greenspan’s filing, the report 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 said Tinubu’s opposition did not address the report, challenge its authenticity or provide contrary technical evidence.

Attacks Allegedly Resumed Around Court Filings

Greenspan also told the court that the attacks resumed after he filed his motion on September 9.

In a supplemental declaration made under penalty of perjury, he 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 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 side and the Justice Department filed their respective submissions.

His declaration also shows that the latest attacks were less disruptive than those recorded in August.

Unlike the August attacks, which he said drove the server’s load average above 300, the September attacks “did not overwhelm the server,” with the load remaining below 25 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 on September 23 and 24 appeared in what the firewall classified as ordinary visitor traffic because attack traffic was counted there before its sources were identified and blocked.

Greenspan’s latest filing follows his September 9 request for limited discovery concerning the attacks.

He is seeking permission to serve Tinubu with four requests for admission concerning whether he, 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 Foreign Agents Registration Act filings.

Greenspan’s argument is instead that the timing and pattern of the attacks justify limited discovery into who may have been responsible.

In his earlier filing, he acknowledged that timing alone does not establish responsibility, stating: “Correlation is not attribution.”

Greenspan Accuses Counsel Of Misstatements

Greenspan also accused Tinubu’s lawyers of making unsupported assertions about the attacks and of mischaracterising statements 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 not responded to his motion within the period provided under Local Civil Rule 7(b).

The court had not ruled on Greenspan’s request in the filings reviewed by SaharaReporters.

The latest filing therefore establishes that Greenspan is seeking permission to question Tinubu about the attacks.