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

2011 jw-v-usaf-complaint-08192011

2011 jw-v-usaf-complaint-08192011

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

Category:Lawsuit

Number of Pages:4

Date Created:August 19, 2011

Date Uploaded to the Library:July 30, 2013

Tags:seeks, Mission, produce, jurisdiction, failed, access, grant, search, requested, Street, public, requests, Pursuant, south, responsive, defendant, Pentagon, government, plaintiff, Obama, watch, request, records, judicial, states, Washington, united, court, EPA, IRS, ICE, 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, 
UNITED STATES AIR FORCE, 1000 Air Force Pentagon Washington, 20330-1000, 
Defendant. 
Civil Action No.  Case: 11-cv-01496  Assigned To: Roberts, Richard  Assign. Date 8/19/2011  Description: FOIA/Privacy Act  

Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Air Force 
("Air Force") 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 
1000 Air Force Pentagon, Washington, 20030-1000. Defendant has possession, custody, and 
control records which Plaintiff seeks access. 
STATEMENT FACTS June 28, 2011, Plaintiff submitted FOIA request, certified mail, 
Defendant seeking access the following: 	Any and all records concerning mission taskings First Lady Michelle Obama's June 21-27, 2011 trip South Africa and Botswana;1 	Any and all records concerning transportation costs for Mrs. 
Obama's June 21-27, 2011 trip South Africa and Botswana; 	Any and all passenger manifests (DD-2131) for Mrs. Obama' June 21-27, 2011 trip South Africa and Botswana. According U.S. Postal Service records, Plaintiffs FOIA request was received 
Defendant July 2011. email dated July 21, 2011, Defendant acknowledged receipt Plaintiffs June 
Pursuant U.S.C.  552(a)(6)(A)(i), Defendant's response Plaintiffs June 

28, 2011 FOIA request and assigned tracking number 2011-05547-F. 
28, 2011 FOIA request was due within twenty working days July 2011, August 2011. the date this Complaint, Defendant has failed produce any records responsive Plaintiffs June 28, 2011 FOIA request demonstrate that responsive records are 
exempt from production. Nor has indicated whether when any responsive records will 
"The First Lady's Trip Africa," http://www.whitehouse.gov/youngafrica 

produced. fact, Defendant has failed respond Plaintiffs June 28, 2011 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 28, 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 Plaintiffs June 28, 2011 FOIA request and 
demonstrate that employed search methods reasonably likely lead the discovery records responsive Plaintiffs June 28, 2011 FOIA request; (2) order Defendant produce, date 
certain, any and all non-exempt records responsive Plaintiffs June 28, 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 June 28, 
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 19> 2011 Respectfully submitted> 
JUDICIAL WATCH> INC. 

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



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