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Judicial Watch • 2006 DOD-complaint

2006 DOD-complaint

2006 DOD-complaint

Page 1: 2006 DOD-complaint

Category:Lawsuit

Number of Pages:3

Date Created:February 27, 2006

Date Uploaded to the Library:July 29, 2013

Tags:videotape, refusal, advised, place, seeks, produce, jurisdiction, enforcement, official, requested, Street, Pursuant, obtained, September, defendant, Pentagon, plaintiff, watch, request, records, federal, department, judicial, school, states, Washington, united, court, EPA, CIA


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  • demand_answers

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THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

JUDICIAL WATCH, INC. 

501 School Street, S.W., Suite 500 
Washington, 20024, Plaintiff, Civil. 
U.S. DEPARTMENT DEFENSE 1950 Defense Pentagon 
Washington, 20301-1950 
Defendant. 

COMPLAINT FOR DECLARATORY AND 
INJUNCTIVE RELIEF 

Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. Department Defense compel compliance with the Freedom oflnformation Act, U.S.C.  552 ("FOIA"). grounds therefor, Judicial Watch, Inc. alleges follows: 
JURISDICTION AND VENUE The Court has jurisdiction over this action pursuant U.S.C.  552(a)(4)(B) and U.S.C.  1331. Venue proper this district pursuant U.S.C.  139l(e). 
PARTIES 
Plaintiff Judicial Watch, Inc. non-profit, educational organization incorporated under the laws the District Columbia and having its principal place business 501 School Street, S.W., Suite 500, Washington, 20024. 
Defendant U.S. Department Defense ("DOD") agency the United States government. DOD has its principal place business the District Columbia. Defendant has possession, custody, and control records which Plaintiff seeks access. 

STATEMENT FACTS December 15, 2004, Plaintiff sent FOIA request Defendant, facsimile and certified U.S. mail, return receipt requested, seeking access any and all records concerning relating the following subjects: 	
Video camera recording(s) obtained federal official(s) and/or law enforcement from the Sheraton National Hotel Arlington, Virginia about September 11, 2001; 	
Video camera recording(s) obtained any federal official(s) and/or law enforcement from Nexcomm/Citgo gas station the vicinity the Pentagon about September 11, 2001; 	
Pentagon security video camera recording(s) showing Flight strike and/or hit and/or crash into the Pentagon September 11, 2001; 

Closed Circuit television (CCTV) video camera recording(s) obtained any federal official(s) and/or law enforcement from the Virginia Department Transportation ("VDOT") and/ the VDOT "Smart Traffic Center" about September 11, 2001. about January 26, 2005, DOD advised Plaintiff that possessed videotape responsive the December 15, 2004 request, but declined produce the videotape, citing 
U.S.C.  552(b)(7)(A). DOD advised Plaintiff that had the right seek administrative appeal this determination, which Plaintiff did about March 27, 2005. about June 10, 2005, DOD denied Plaintiffs administrative appeal, citing the following grounds: have been advised that the video the September 11, 2001, attack the Pentagon sill part ongoing investigation involving Zacarias Moussaoui, and exempt from release. Consequently, must deny this information pursuant U.S.C.  552(b)(7)(A). 
You are advised that you have the right judicial review this decision United States District Court, accordance with U.S.C.  552(a)(4)(B). Plaintiff has statutory right the records that seeks, and there legal basis 
for defendant's refusal disclose these records Plaintiff. 

(Violation FOIA) Plaintiff realleges paragraphs through8 fully stated herein. 
WHEREFORE, Plaintiff respectfully requests that this Court: (1) declare that Defendant's refusal disclose the records requested Plaintiff unlawful; (2) enjoin Defendant from continuing withhold the requested records from Plaintiff; (3) order Defenda produce the requested records Plaintiff without further delay; award Plaintiff its costs and reasonable attorneys' fees pursuant U.S.C.  552(a)(4)(E); and (5) grant such other relief the Court deems just and proper. 
Respectfully submitted, JUDICIAL WATCH, INC. 

D.C. Bar No. 429716 Suite 500 501 School Street, S.W. Washington, 20024 
(202) 646-5172 
Counsel for Plaintiff



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