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Judicial Watch • 3 31 14 Travel Suits 950 096 046 047

3 31 14 Travel Suits 950 096 046 047

3 31 14 Travel Suits 950 096 046 047

Page 1: 3 31 14 Travel Suits 950 096 046 047

Category:Lawsuit

Number of Pages:17

Date Created:March 31, 2014

Date Uploaded to the Library:March 31, 2014

Tags:Plaintiffs, Defense, requests, responsive, filed, September, defendant, Pentagon, president, document, plaintiff, Obama, request, records, Washington, court, EPA, IRS, ICE, CIA


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THE UNlTED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

JUDICIAL WATCH, INC., 
425 Third Street, SW, Suite 800 
Washington, D.C. 20024, 
Plaintiff, 

Civil Action No. 
U.S. SECRET SERVICE, Office the Chief Counsel 245 Murray Lane Washington, 20528-0485 
Defendant. 

COMPLAINT 
Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Secret Service compel compliance with the Freedom lnfonnation 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 .S.C.  1331. Venue proper this district pursuant U.S.C.  139l(e). 
PARTIES 
Plaintiff Judicial Watch, Inc. not-for-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 govemment and fidelity the rule oflaw. fut1herance 

its public interest mission, Judicial Watch regularly requests access public records federal, state, and local government agencies and officials and disseminates its findings the public. Defendant United States Secret St:rvice ("USSS") agency the United States Government and headquartered 245 Murray Drive, Building 410, Washington, 20223. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS February 15, 2013, Plaintiff sent FOIA request USSS, Freedom lnf01mation Act Privacy Acts Branch Communications Center, seeking access the following records: 
(I) 
Any and all records concerning, regarding related the expenditure U.S. Government funds provide security and/or other services President Obama and any companions during his February 2013 trip Palm Beach, Florida; 

(2) 
Any and all records concerning, regarding, related the expenditure U.S. Government funds provide security and/or other services First Lady Michelle Obama and any companions during her February 2013 trip Aspen, Colorado; 

(3) 
Any and all records concerning, regarding, related the expenditure U.S. Government funds provide security and/or other services Vice President Biden and any companions during his February 2013 trip Aspen, Colorado. letter dated March 18, 2013, USSS acknowledged receipt Plaintiffs FOIA request February 27, 2013 and assigned the request File Numbers 20130405, 20130406, and 20130406. 
Pursuant U.S.C.  552(a)(6)(A)(i), USSS was required determine whether comply with Plaintiff's request within twenty (20) working days after receipt the request. Pursuant this same provision, USSS also was required notify Plaintiff immediately its 

determination, the reasons therefor, and the right appeal any adverse determination. USSS's determination was due later than March 27>2013. the date this Complaint, USSS has failed to: (i) determine whether 
comply with Plaintiff's request; (ii) notify Plaintiff any such determination the reasons therefor; (iii) advise Plaintiff the right appeal any adverse determination; (iv) produce the requested record otherwise demonstrate that the requested records are exempt from production. Because USSS failed comply with the time limit set forth U.S.C.  
522(a)(6)(A), Plaintiff deemed have exhausted any and all administrative remedies with 
respect its request, pursuant U.S.C.  552(a)(6)(C). 
COUNT 
(Violation FOIA, U.S.C.  552) 
10. Plaintiffrealleges paragraphs through fully stated herein. 
11. Defendant unlawfully withholding public records requested Plaintiff pursuant U.S.C.  552. 
12. Plaintiff being irreparably harmed reason Defendant's unlawful 
withholding the requested public records, and Plaintiff will continue irreparably harmed 
unless Defendant compelled confonn its conduct the requirements the law. 
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant 
conduct search for any and all records responsive Plaintiff's FOIA request and 
demonstrate that employed search methods reasonably likely lead the discovery 
records responsive Plaintiffs FOIA request; (2) order Defendant produce, date 
certain, any and all non-exempt records responsive Plaintiffs FOIA request and Vaughn 
index aay responsive records withheld wider claim exemption; (3) enjoin Defendant from continuing withhold any and all non-exempt records responsive Plaintiffs FOlA 
request; (4) 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 
reliefas the Court deems just and proper.  
Dated: June 21, 2013  Respectfully Submitted,  
JUDICIAL WATCH, INC.  
Isl Paul Orfanedes D.C. Bar No. 4.29716 425 Third Street, S.W., Suite 800 Washington, 20024 (202) 646-5172   
Altorneys for Plaintiff  

2014-000 3-L THE UNITED STATES DISTRICT COURT FOR THE DISTRICT COLUMBIA 
JUDICIAL WATCH, INC., 
425 Third Street, SW, Suite 800 Washington, D.C. 20024, Plaintiff, Civil Action No. 
U.S. DEPARTMENT DEFENSE, 
1600 Defense Pentagon 
Washington, 20301-1600, 
Defendant. 

COMPLAINT 
Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. Department 
Defense compel compliance with the Freedom oflnfonnation Act, U.S.C.  552 ("FOTA''). grounds therefor, Plaintiff alleges follows: 
JURISDICTION AND VENUE The Court has jurisdiction over this action pursuant U.S.C.  552(a)(4)(B) 
and .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, W., Suite 
800, Washington, 20024. Plaintiff seeks promote integrity, transparency, and 
accountability government and fidelity the rule oflaw. 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. The U.S. Depattment Defense agency the United States Government and headquartered 1600 Defense Pentagon, Washington, 20301-1600. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS 
July 31, 2013 Request July 31, 2013, Plaintiff sent FOIA request the U.S. Air Force ("USAF"), component Defendant U.S. Department Defense, seeking access records concerning mission taskings, transportation costs, and passenger manifests (DD-2131) for First Lady Michelle Obama's flight London for the 2012 Summer Olympics. The time frame the request was identified "March 2012 August 31, 2012." 
The USAF acknowledged receipt Plaintiffs request August 2013, assigned the request case number "FOIA 2013-05496-F," and represented that "[w]e will respond your request September 18, 2013." Pursuant U.S.C.  552(a)(6)(A)(i), the USAF was required respond 
Plaintiffs request within twenty (20) working days August 2013, September 2013. August 2013 Request August 2013, Plaintiff sent FTA request the USAF seeking access records concerning mission taskings, transportation costs, and passenger manifests (DD-2131) for President Obama's December 2012 flight Honolulu, Hawaii. The time frame the request was identified "December 15, 2012 December 31, 2012." 
According U.S. Postal Service records, Plaintiffs August 2013 request was 
received the USAF August 13, 2013. The USAF has never acknowledged receipt the request, however. 
10. Pursuant U.S.C.  552(a)(6)(A){i), the USAF was required respond Plaintiffs request within twenty (20) working days August 13, 2013, September 11, 2013. 
August 2013 Request 
11. August 2013, Plaintiff sent FOTA request the USAF seeking access records concerning mission taskings, transportation costs, and passenger manifests (DD-2131) for President Obama's August 2013 visit California. The time rrame this request was identified August 2013 August 2013.' 

12. 
According U.S. Postal Service records, Plaintiff's August 2013 request was received the USAF August 23, 2013. The USAF has never acknowledged receipt the request, however. 

13. 
Pursuant U.S.C.  552(a)(6)(A)(i), the USAF was required respond Plaintiffs request within twenty (20) working days August 23, 2013, September 23, 2013. 

August 19, 2013 Request August 19, 2013, Plaintiff sent FOIA request the USAF seeking access 
records concerning mission taskings, transportation costs, and passenger manifests (DD2131) for President Obama's August 2013 flights and from Martha's Vineyard, MA. The time frame the request was identified "August 2013 the present." 
15. 
According U.S. Postal Service records, Plaintiff's August 19, 2013 request was received the USAF August 22, 2013. The USAF has never acknowledged receipt the request, however. 

16. 
Pursuant U.S.C.  552(a)(6)(A)(i), the USAF was required respond Plaintiffs request within twenty (20) working days August 22, 2013, September 20, 2013. 

17. the date this Complaint, the USAF has failed produce any records responsive Plaintiffs requests demonstrate that responsive records are exempt from production. Nor have they indfoated whether when any responsive records will produced. 

18. 
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 requests. U.S.C.  552(a)(6)(C). 

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

Plaintiff realleges paragraphs through fully stated herein. 
20. 
Defendant unlawfully withholding records requested Plaintiff pursuant u.s.c.  552. 

21. 
Plaintiff being irreparably harmed reason Defendant's unlawful withholding requested records, and Plaintiff will continue irreparably harmed unless Defendant compelled confonn its conduct the requirements the law. 

WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant conduct search for any and all responsive records Plaintifrs FOTA requests and demonstrate that employed search methods reasonably likely lead the discovery records responsive Plaintiffs FOTA requests; (2) order Defendant produce, date certain, any and all non
exempt records responsive Plaintiff's FOIA requests and Vaughn index any responsive 
records withheld under claim exemption; (3) enjoin Defendant from continuing withhold 
any and alJ non-exempt records responsive Plaintiff's FOIA requests; (4) grant Plaintiff 
award anorneys' 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: January 24, 2013  Respectfully Submitted,  
Isl Paul Orfanedes D.C. Bar No. 429716 JUDICIAL WATCH, INC. 425 Third Street, SW, Suite 800 Washington, 20024 (202) 646-5172  
Attorneys for Plaintiff  

Case 1:14-cv-00046-RLW Document Filed 01/13/14 Page 1of6 TUE UNITED STATES DISTRICT COURT FOR THE DISTRICT COLUMBIA 
JUDICIAL WATCH, INC . 425 Third Street, SW, Suite 800 Washington, D.C. 20024, 
Plaintiff, Civil Action No. 
U.S. SECRET SERVICE, 245 Murray Drive, Building 410 
Washington, 20223 
Defendant. 

COMPLAINT 
Plaintiff Judicial Watch, Inc. brings this action against Defend United State Secret 
Service compel compliance with the Freedom oflnfonnation Act, U.S.C.  552 ('FOIA0). grounds therefor, Plaintiff alleges follows: The Court has jurisdiction over this action pursuant U.S.C.  552 (a)( 4)(B) 
and 28U.S.C.  1331. 
Venue proper this district pursuant U.S.C.  1391(e). 

PARTIES Plaintiff Judicial Watch, Inc. not-for-profit, educational foundation organized --undet..the.laws the 

and having.its_principal.plaoe. business 425 Third_ Street, S.W., Suite 800, Washington, 20024. Plaintiff seeks promote integrity, transparency, and accountability government and fidelity the rule oflaw. furtherance 
Case 1:14-cv-00046-RLW Document Filed 01/13/14 Page 
August 2013 Request 
17. August 2013, Plaintiff sent FOIA request the USSS seeking access records concerning the use U.S. Government funds provide security and other services President Barack Obama and any companions August 2013 trip California. 

18. letter dated September 17, 2013, the USSS acknowledged receipt Plaintiffs request August 20, 2013 and assigned the request File Number 20131346. 

19. 
Pursuant U.S.C.  552(a)(6)(A)(i), the USSS was required respond Plaintiff's request within twenty (20) working days August 20, 2013, September 18, 2013. 

August 19, 2013 Request 
20. August 19, 2013, Plaintiff sent FOIA request the USSS seeking access records concerning the use U.S. Government funds provide security and other services President Barack Obama and any companions August 2013 trip Martha's Vineyard, Massachusetts. 

21. letter dated September 18, 2013, the USSS acknowledged receipt Plaintiff's request September 2013 and assigned the request File Number20131414. 

22. 
Pursuantto U.S.C.  552(a)(6)(A)(i), the USSS was required respond Plaintiff's request within twenty (20) working days September 2013, October 2013. the date this Complaint, the USSS has failed produce any records responsive Plaintiff's requests demonstrate that responsive records are exempt from production. Nor have they indicated whether when any responsive records will produced. 
Case 1:14-cv-00046-RLW Document Filed 01i13i14 Page 
10. Pursuant U.S.C.  552(a)(6)(A)(i), the USSS was required respond 
Plaintiff's request within twenty (20) working days July 2013, August 2013. 
Joly 31, 2013 Request 
11. July 31, 2013, Plaintiff sent FOIA request the USSS seeking access 
records concerning the use U.S. Government funds provide security and other services First Lady Michelle Obama and any companions Summer 2012 trip London, England for the Olympics. 
12. letter dated August 30, 2013, the USSS acknowledged receipt Plaintiff's 
request August 12, 2013 and assigned the request File Number 20131297. 
13. Pursuant U.S.C.  552(a)(6)(A)(j), the USSS was required respond 
Plaintiffs request withintwenty (20) working days August 12, 2013, September 10, 
2013. 
August 2013 Request 
14. August 2013 Plaintiff sent FOIA requestto the USSS seeking access 
records concerning the use U.S. Government funds provide security and other services 
President Barack Obama and any companions December 2012 trip Honolulu, Hawaii. 
15. letter dated September 18, 2013, the USSS aclmowledged receipt Plaintiff's 
request August 27, 2013 and assigned the request File Number 20131390. 
16. Pursuant .S.C.  552(a)(6)(A)(i), the USSS was required respond 
Plaintiff's request within twenty (20) working days August 27, 2013, September 25, 
2013. 
Case 1:14-cv-00046-RLW Document Filed 01/13/14 Page 
Because Defendant bas 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 requests. U.S.C.  552(a)(6)(C). 
COUNT! 
(Violation FOIA, U.S.C.  552) 

25. Plaintiffrealleges paragraphs 1through24 fully stated herein. 
26. 
Defendant wtlawfully withholding records requested Plaintiff pursuant u.s.c.  552. 

27. 
Plaintiff being irreparably banned reason ofDefendant>s unlawful withholding requested records, and Plaintiff will continue irreparably harmed unless Defendant compelled confonn 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 FOIA requests and demonstrate th.at employed search methods reasonably likely lead the discovery records responsive Plaintiff's FOIA requests; (2) order Defendant produce, date certain, any and all non
exempt records responsive Plaintifrs FOJA requests and Vaughn index any responsive records withheld under claim exemption (3) enjoin Defendant from continuing withhold a.ny and all non-exempt records responsive Plaintiff's FOIA requests; (4) grant Plaintiff award attorneys> fees and other litigation costs reasonably incurred this action pursuant 
U.S.C.  5S2(a)( 4)(E); and (5) grant Plaintiff such other relief the Court deems just and 
proper. 
Ca...ee 1:14-cv-00046-RLW Document FHed 01113/14 Page 
Dated: 11111U8.1:Y13,2013 Respectfully Submitte 

JUDIC'JAL WATCH, INC. 
425 Tliird Street. SW, Suite SOO WuhiDgton. 20024 
(202) 646--Sl72 
AttorMys for Pll)tntf/f 
Case 1:14-cv-00047 -CKK Document Filed 01/13/14 Page 
mission, Plaintiff regularly requests access the public records federal, state, and local government agencies, entities, and offices, and disseminates its findings the public. The U.S. Department Defense agency the United Stats Government and headquartered 1600 Defense Pentagon, Washington, 20301-1600. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT 014' FACTS June 19, 2013, Plaintiff sent FOIA request the U.S. Air Force ("USAF") see.king access records concerning First Lady Michelle Obama' June 2013 trip Ireland. 
According U.S. Postal Service records, Plaintiff's June 19, 2013 requei:;t was received the USAF June 28, 2013. The USAF has never acknowledged receipt the request, however. 
Pursuant U.S.C.  SS2(a)(6)(A)(i), the USAF was required respond 
Plaintiff's request within twenty (20) working days June 28, 2013, July 29, 2013. the date this Complaint, the USAF has failed produce any records responsive Plaintiff's requests demonstrate that responsive records are exempt from production. Nor have they indicated whether when any responsive records will produced. 
Recause 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 requests. U.S.C.  552(a)(6)(C). 

COUNT1 
(Violation FOIA, U.S.C.  552) 

10. 
Plaintiff realleges paragraphs through fully stated herein. 

11. 
Defendant unlawfully withholding records requested Plaintiff pursuant u.s.c.  552.
Case 1:14-cv-00047-CKK Document Filed 01/13/14 Page 
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 ofth.e law. 
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant 
conduct search for any and all responsive records Plaintiff's FOIA requests and demonstrate 
that itemployed search methods reasonably likely lead the discovery records responsive 
Plaintifrs FOIA requests; (2) order Defendant produce, date certain, any and all 
non-exempt records responsive Plaintiff's FOIA requests 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 FOIArequests; (4) grant Plaintiff award 
attomey11' fees and other litigation costs reasonably incurred this action pursuant U.S.C.  
S52(a)(4)(E); and (5) grant Plaintiff such other relief the Court deems just and proper. 
Dated: January 13, 2014 

JUDICIAL WATCH, INC. 
425 Third Street, SW, Suite
800 Washington, 20024 
(202) 646-5172 
AllorneyJ' for Plaintiff



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