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Judicial Watch • Air Force Obama Travel 00046

Air Force Obama Travel 00046

Air Force Obama Travel 00046

Page 1: Air Force Obama Travel 00046

Category:Lawsuit

Number of Pages:6

Date Created:February 27, 2014

Date Uploaded to the Library:February 27, 2014

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


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Case 1:14-cv-vu046-RLW Document Filed 01/131..1.4 Page 1of6 THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

nJD1CIAL 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  
Was.hilJ.brton, 20223  

COMPLAINT 
PlaintiffJudicial Watch, Inc. brings this action against Defendant United States Secret 
Service compel compliance with the Freedom ofinformation Act, U.S.C.  552 ("FOIA"). grounds therefor, Plaintiff alleges follows: 
JURIS.DICTION AND 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.  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 government and fidelity the rule oflaw. furtherance 

Case 1:14-cv-0u046-RLW Document Filed 01/13/.L4 Page 
its public interest mission, Judicial Watch regularly requests access public records federal, state, and local goverrunent agencies and officials and disseminates its findings the public. Defendant United States Secret Service ("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 
June 19, 2013 Request June 19, 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, Malia Obama, Sasha Obama, and any companions June 2013 trip Ireland. letter dated July 17, 2013, the USSS acknowledged receipt Plaintiffs request July 2013 and assigned the request File Number 20130859. 
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. 

July 2013 Request July 2013, Plaintiff sent FOIA request the USSS seeking access records conceming the use U.S. Government funds provide security and other services President Barack Obama and any companions June-July 2013 trip Africa. letter dated July 17, 2013, the USSS acknowledged receipt Plaintiffs 
request July 2013 and assigned the request File Number 20130823. 

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. 

Case 1:14-cv-ull046-RLW Document Filed 01/131.1.4 Page 
July 31, 2013 Request 
11. July 31, 2013, Plaintiff sent FOIA request the USSS seeking access records concerning the use U.S. Government fwids provide security and other services First Lady Michelle Obama and any companions Swnmer 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)(i), the 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 Barack Obama and any companions December 2012 trip Honolulu, Hawaii. 
15. 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.C.  552(a)(6)(A)(i), the USSS was required respond 
Plaintiffs request within twenty (20) working days August 27, 2013, September 25, 
2013. 

Case 1:14-cv-uu046-RLW Document Filed 01/131.L4 Page 
August 2013 Request 
17. August 2013, Plaintiff sent FOlA 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 Plaintiff's 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 Plaintiffs 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. Govenunent 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 Number 20131414. 

22. 
Pursuant 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 Plaintiffs requests demonstrate that responsive records are exempt from production. Nor have they indicated whether when any responsive records will produced. 
Case 1:14-cv-uu046-RLW Document Filed 01/13/.L4 Page 

24. 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. 
26. 
Defendant unlawfully withholding records requested Plaintiff pursuant u.s.c.  552. 

27. 
Plaintiff being irreparably harmed reason Defendant's unlawful withholding requested records, and Plaintiff will continue irreparably hanned 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 Plaintiffs FOIA 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 nonexempt 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 FOIA requests; (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-uu046-RLW Document Filed 01/13/.l.4 Page 
Dated: January 13, 2013 Respectfully Submitted,, 

D.C. Bar No. 429716 JUDICIAL WATCH. INC. 425 Third Street, SW, Suite 800 Washington, 20024 
(202) 6465



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