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Judicial Watch • 2011 jw-v-usaf-complaint-02102011

2011 jw-v-usaf-complaint-02102011

2011 jw-v-usaf-complaint-02102011

Page 1: 2011 jw-v-usaf-complaint-02102011

Category:Lawsuit

Number of Pages:3

Date Created:February 11, 2011

Date Uploaded to the Library:July 30, 2013

Tags:withhold, transparency, attorneys, conduct, jurisdiction, grant, search, requested, Street, Pursuant, responsive, defendant, Pentagon, plaintiff, watch, request, records, judicial, 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., 

425 Third Street, S.W., Suite 800  
Washington,  20024,  
Plaintiff,  Case: 11-cv-00349 Assigned To: Leon, Richard  Assign. Date 2/10/2011  
UNITED STATES AIR FORCE  Description: FOIA/Privacy Act  
1000 Air Force Pentagon  
Washington, 20330-1000,  
Defendant.  

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF 
Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Air Force compel compliance with the Freedom Information 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 Because Defendant failed comply with the time limit set forth U.S.C.  

552(a)(6)(A), Plaintiff deemed have exhausted any and all administrative remedies with respect its FOIA request, pursuant U.S.C.  552(a)(6)(C). 
COUNTl (Violation FOIA, U.S.C.  552) 
10. Plaintiffrealleges paragraphs through9 fully stated herein. 
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 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 Plaintiffs 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 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: February 2011 Respectfully submitted, 
JUDICIAL WATCH, INC. 

D.C. Bar No. 429716 

Attorneys for Plaintiff



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