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Judicial Watch • 2011 jw-v-hud-complaint-08192011

2011 jw-v-hud-complaint-08192011

2011 jw-v-hud-complaint-08192011

Page 1: 2011 jw-v-hud-complaint-08192011

Category:Obtained Document

Number of Pages:4

Date Created:August 19, 2011

Date Uploaded to the Library:July 30, 2013

Tags:urban, conduct, housing, seeks, Development, jurisdiction, produce, dated, failed, grant, access, search, Street, requested, public, requests, Pursuant, responsive, defendant, government, watch, plaintiff, request, records, judicial, department, states, Washington, united, court, EPA, ICE, CIA


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THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

JUDICIAL WATCH, INC., 425 Third Street, S.W., Suite 800 
Washington,  20024,  
Plaintiff,  Civil Action No.  

UNITED STATES DEPARTMENT HOUSING AND 
URBAN DEVELOPMENT, 
451 7th St., S.W. 
Washington, 20410, 

Defendant. 

COMPLAINT 
Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Department Housing and Urban Development ("HUD") compel compliance with the Freedom oflnformation Act, U.S.C.  552 ("FOIA"). grounds therefor, Plaintiff 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 non-profit, educational foundation organized under the laws the 
District Columbia and having its principal place business 425 Third Street, S.W., Suite 
800, Washington, 20024. Plaintiff seeks promote integrity, transparency, and accountability government and fidelity the rule law. furtherance its public interest 
mission, Plaintiff regularly requests access the public records federal, state, and local 
government agencies, entities, and offices, and disseminates its findings the public. Defendant agency the United States Government and headquartered 
451 7th St., S.W., Washington, D.C. 20410. Defendant has possession, custody, and control 
records which Plaintiff seeks access. 
STATEMENT FACTS June 2011, Plaintiff submitted FOIA request Defendant, certified 
mail, seeking access the following: 	Any and all records concerning relating the approval Affordable Housing Centers America (AHCA) housing agency under Section 106(a)(2) the Housing and Urban Development Act 1968. This request includes, but not limited copy all HUD-9900 forms and supporting documentation submitted by, behalf AHCA, well all records communication regarding AHCA's approval; 	Any and all records all application( for grants submitted AHCA HUD. 
According U.S. Postal Service records, Plaintiffs FOIA request was received 
Defendant acknowledged receipt Plaintiffs June 2011 FOIA request letter 
Pursuant U.S.C.  552(a)(6)(A)(i), Defendant's response Plaintiffs June the date this Complaint, Defendant has failed produce any records 

Defendant June 13, 2011. 
dated July 2011, and assigned tracking numbers 11-FI-HQ-01979 and FI-486197. 
2011 FOIA request was due within twenty working days June 13, 2011, July 12, 2011. 
responsive Plaintiff's June 2011 FOIA request demonstrate that responsive records are 
exempt from production. Nor has indicated whether when any responsive records will 

produced. fact, Defendant has failed respond Plaintiff's FOIA request any substantive 

manner. 
10. Because Defendant has failed comply with the time limit set forth U.S.C.  
552(a)(6)(A)(i), Plaintiff deemed have exhausted any and all administrative remedies with 
respect its June 2011 FOIA request. U.S.C.  552(a)(6)(C). 
COUNT 
(Violation FOIA, U.S.C.  552) 

11. 
Plaintiff realleges paragraphs through fully stated herein. 

12. 
Defendant unlawfully withholding records requested Plaintiff pursuant u.s.c.  552. 
13. Plaintiff being irreparably harmed reason Defendant's unlawful withholding requested records, and Plaintiff will continue irreparably harmed unless 
Defendant compelled conform its conduct the requirements the law. 
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant 
conduct search for any and all responsive records Plaintiff's June 2011 FOIA request and demonstrate that employed search methods reasonably likely lead the discovery records 
responsive Plaintiff's FOIA request; (2) order Defendant produce, date certain, any and 
all non-exempt records responsive Plaintiff's FOIA request and Vaughn index any 
responsive records withheld under claim exemption; (3) enjoin Defendant from continuing 
withhold any and all non-exempt records responsive Plaintiff's FOIA request; grant Plaintiff award attorneys' fees and other litigation costs reasonably incurred this action pursuant U.S.C.  552(a)(4)(E); and (5) grant Plaintiff such other relief the Court deems just and 
proper. 
Dated: August 19, 201 Respectfully submitted, 
JUDICIAL WATCH, INC. 

D.C. BarNo.10011557 
425 Third Street, S.W., Suite 800 Washington, 20024 
(202) 646-5172 
Attorneys for Plaintiff



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