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Judicial Watch • 2011 jw-v-nlrb-complaint-08152011

2011 jw-v-nlrb-complaint-08152011

2011 jw-v-nlrb-complaint-08152011

Page 1: 2011 jw-v-nlrb-complaint-08152011

Category:Lawsuit

Number of Pages:5

Date Created:August 15, 2011

Date Uploaded to the Library:July 30, 2013

Tags:seeks, decision, trade, failed, access, search, Street, public, EXECUTIVE, requests, Pursuant, south, responsive, International, defendant, government, president, Union, watch, plaintiff, request, White House, records, State, judicial, 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, Case: 11-cv-014 Plaintiff, Assigned Collyer, Rosemary Assign. Date 8/15/2011 Description: FOIA/Privacy Act LABOR 
RELATIONS BOARD 
1099 14th Street, N.W. 
Washington, 20570 Defendant. 

COMPLAINT 
Plaintiff Judicial Watch, Inc. brings this action against Defendant National Labor Relations 

Board ("NLRB") 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.  1391(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 
1099 14th Street, N.W., Washington, 20570. Defendant has possession, custody, and 
control records which Plaintiff seeks access. 

STATEMENT OFF ACTS July 14, 2011, Plaintiff submitted FOIA request Defendant seeking access the following: 	Records communications between officials, officers, employees the NLRB concerning, regarding relating the Boeing Company. 	Records communications between the NLRB and the following entities concerning, regarding, relating the Boeing Company: 	
The White House; 	
The Executive Office the President; 	
The State Washington; 	
The State Oregon; 	
The Boeing Company; 

The International Association Machinists and Aerospace Workers; 	
The AFL-CIO, the SEIU, and/or any additional third party trade union; 	
Any additional non-governmental entities. 	Records concerning, regarding, relating the impact the Boeing Company's new assembly plant North Charleston, South Carolina employment South Carolina. 	Records concerning, regarding, relating the decision file complaint against the Boeing Company Case 19-CA-32431. 	Records communications between officials, officers, employees the NLRB concerning, regarding, relating the decision file complaint against the Boeing Company Case 9-CA-32431. 	Records communications between the NLRB and the following entities concerning, regarding, relating the decision file complaint against the Boeing Company Case 19-CA-32431: 	
The White House; 	
The Executive Office the President; 	
The State Washington; 	
The State Oregon; 	
The Boeing Company; 	
The International Association Machinists and Aerospace Workers; 	
The AFL-CIO, the SEIU, and/or any additional third party trade union; 	
Any additional non-governmental entities. 

The timeframe for this request January 20, 2009 July 14, 2011. letter dated July 28, 2011, Defendant acknowledged receipt Plaintiffs FOIA 
request July 14, 2011 and assigned Tracking Number LR-2011-0727. 
Pursuant U.S.C.  552(a)(6)(A)(i), Defendant's response Plaintiffs July 
14, 2011 FOIA request was due within twenty working days July 14, 2011, August 11, 
2011. the date this Complaint, Defendant has failed produce any records 
responsive Plaintiffs July 14, 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 Plaintiffs July 14, 2011 FOIA request any substantive manner. 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 July 14, 2011 FOIA request. U.S.C.  552(a)(6)(C). 

COUNTl 
(Violation FOIA, U.S.C.  552) 

10. Plaintiff realleges paragraphs through fully stated J-1erein. 11. Defendant unlawfully withholding records requested Plaintiff pursuant U.S.C.  552. 

12. 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 Plaintiffs July 14, 2011 FOIA request and demonstrate that employed search methods reasonably likely lead the discovery records responsive Plaintiffs July 14, 2011 FOIA request; (2) order Defendant produce, date certain, any and all non-exempt records responsive Plaintiffs July 14, 2011 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 Plaintiffs July 14, 2011 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 12, 2011 Respectfully submitted, JUDICIAL WATCH, INC. 

D.C. 
Bar No. 99574.9 

D.C. 
Bar No. 429716 425 Third Street, S.W., Suite 800 Washington, 20024 

(202) 646-5172 

Attorneys for Plaintiff



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