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Judicial Watch • 40814 London AF travel suit

40814 London AF travel suit

40814 London AF travel suit

Page 1: 40814 London AF travel suit

Category:Lawsuit

Number of Pages:10

Date Created:April 8, 2014

Date Uploaded to the Library:April 08, 2014

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


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2014w00003-L THE UNITED ATES 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, lnc. brings this action against Defendant U.S. Department 
Defense compel compliance with the Freedo oflnfonnation 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 pub! 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. Department Defense agency the United States Government 
and headquartered 1600 Defense Pentagon, Washington, 20301-1600. Defendant has possession, custody, and control ofrecords 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 ofDefense, seeking access records concerning 
mission taskings, transportation costs, and passenger manifests (DD-2131) for First Lady 
Michelle Obama's flightto London for the 2012 Summer Olympics. The time frame the 
request was identified "March 2012 August 31, 2012." The USAF acknowledged receipt Plaintiff's request August 2013, 
assigned the request case number FOIA 2013-05496-F and represented that "[w will 
respond your request September 18, 2013." Pursuant U.S.C.  552(a)(6)(A)(i), the USAF was required respond 
Plaintiff's 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 ofthe request was identified "December 15, 2012 December 31, 2012." 
According U.S. Postal Service records, Plaintiff's 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 Plainti fl' request within twenty (20) working days August 13, 2013, September 11, 2013. 

August 2013 Request 
11. August 2013, Plaintiff sent FOJA request the USAF seeking access records conceming mission taskings, transportation costs, and passenger manifests (DD-2131) for President Obama's August 2013 visit California. The time frame 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. 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, Plaintiffs 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 Plaintiff's requests demonstrate that responsive records are exempt from production. Nor have they indicated 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). 

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

19. 
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 ofDefendant's unlawful withholding requested records, and Plaintiff will continue irreparably hanned unless Defendant compelled conform its conduct the requirements the law. 
WHEREFORE, Plaintiff respectfully requests that the Court: (I) order Defendant conduct search for any and all responsive records Plaintiffs FOlA requests and demonstrate that employed search methods reasonably likely lead the discovery records responsive Plaintiffs FOIA requests; (2) order Defendant produce, date certain, any and all non
exempt records responsive Plaintiff's FOlA requests and Vaughn index any responsive records withheld under claim exemption; (3) enjoin Defendant from continuing withhold any nnd all non-exempt records responsive Plainlif'rs FOIA requests; (4) granl Plaintiff award attorneys' fees and other litigation costs reasonably incu1red 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,  
/s/ 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 Flied 01/13/14 Page 1of6 THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

JUDIClAL WATCH, JNC., 425 Third Street, SW, Suite 800 Washington, D.C. 20024, Plaintiff, Civil Action No. 
U.S. SECRET SERVICE, 245 Murray Drivet Building 410 Washington, 20223 

Defendant. 

COMPLAINT 
Plaintiff Judicial. Watch, Inc. brings this action against Defendant United States Secret 
Service compel compliance with the Freedom oflnfonnation Act, U.S.C.  552 ("FOIA"). grounds therefor, Plaintiff' alleges follows: 
The Court bas jurisdiction over this action pursuant U.S.C.  552 (a)(4)(B) 
Venue proper this district pursuant U.S.C.  1391(e). 
Plaintiff Judicial Watch, Inc. not-for-profit, educational foundation. organized 

and u.s.c.  1331. 
under the .laws...otthe. 
its principal 
.of.h.usiness 425 Third 
Street, S.W., Suite 800, Washington,DC 20024. Plaintiff seeks promote integrity, 
transparency, and accounta.bility government and fidelity the rule ofla.w. furtherance 
Case 1:14-cv-00046-RLW Document Filed 01/13114 Page 
Aug11st 2013 Request 
17. August 9,2013, Plaintiffsent FOJA request the USSS seeking access records conceming the use U.S. Government funds ptovide security and other services PresidentBarack Obama and any companions August 2013 trip California. 
18. letter dated September 17, 20131 the USSS acknowledged teceipt Plaintiff 
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 respond10 
Plaintiff's reqlest within twenty (20) working days August 20, 2013, September 18, 
2013. 
August 19, 2013 Rcqoest 
20. August 19, 2013, Plaintiff sent FOIA request the USSS seeking 
records concerning the use U.S. Government funds provide security and other services 
PresidentBarack Obama and any companions August 2013 trip Martha's Vineyard, 

Massachusetts. 
21. letter dated September 18, 2013, the USSS acknowledged receipt Plaintiff's 

22. 
Pursuant .S.C.  552(a)(6)(A)(i), the USSS was required respond t;O 

request September 2013 and assigned the request File Number 20131414. 
Plaintiff's request withintwenty (20) working days September 2013, October 2013. 
23. the date ofthis Complaint, the USSS has failed produce any records 
responsive Plamtiff' requests demonstrate that responsive records are exempt from 
production. Nor have they indicated whether when any responsive records will produced. 
Case L14-cv-00046RLW Document Filed 01/13/14 Page 
10. Pursuant U.S.C.  552(a)(6)(A)(i), the USSS was required respond 
Plaintiff's request withintwenty (20) working days ofJuly 2013, August 2013. 
July 31, 2013 Request 
11. July 31, 2013, Plaintiff sent FOIA request the USSS seeking access 
records concerning the use U.S. Govenunent funds provide secwity and other services First Lady Michelle Obama and any companioruJ Smnmer 2012 trip London, England for the Olympics. letter dated August 30, 2013, the USSS acknowledsed receipt ofPlaintiffs request August 12,2013 and assigned the request File Number 20131297. 
13. Pursuant U.S.C.  552(a)(6)(A)(i), 1he USSS was required respond 
Plaintiffs request within twenty (20) working days August 12, 2013, September 10, 
2013. 
August '.2013 Request August 2013, Plaintiff sent FOIA request the USSS seeking access 
records concerning the use U.S. Government funds provide security and other services President Bal'ack Obama and any companions aDecember2012 trip Honolulu, Hawaii. letter dated September 18, 2013, the USSS acknowledged receipt Plaintiff's 
request August 27, 2013 and assigned the request File Number 20131390. 
16. Pursuant U.S.  552( a)(6)(A)(i), the USSS was required respond 
Plaintiff's request within twenty (20) working days August27, 2013, September 25, 2013. 
Case 1:14-cv-00046-RLW Document Filed 01/13/14 Page 
24. 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). 
COUNT1 
(Violation FOJA, .S.C.  552) 
2.5. Plaintiffrealleges paragrapru 1through24 iffully stated he.re.in. 
26. Defendant unlawfully withholding records requested Plaintiff pursuant U.S.C.  SS2. 
27. Plaintiff being irrepatablyhanned reason ofDefendant'11 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: order Defendant 
conduct search for any and all responsive records Plaintiff's FOIA requests and demonstrate 
that employed search methods reasonably likely lead the discovery records responsive Plaintiff's FOIA requests; (2) order Def.end.ant produce, date certain, any and all non
exempt records responsive Plaintifr FOJA requests and Vaughn index ofany responsive 
records withheld under claim ex.emption; (3) enjoin Defendant from continuing withhold 
any and all non-exempt records responsive Plaintiffs FOIA req,ucsts; (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 relief the Court deems just and 
proper. 
Case 1:14-cv-00046-RLW Document Flied 01113/14 Page lltlU.ll:T ta.1013 
JUDICIAL WATCH, INC. 
425 T.bird Stteet. SW, Suite aoo Washhlgtan. 2002A 
(202) 646-5172 
Atl0171$)18{or Pllllntf/f



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