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Judicial Watch • complaint

complaint

complaint

Page 1: complaint

Category:Obtained Document

Number of Pages:5

Date Created:July 16, 2007

Date Uploaded to the Library:July 30, 2013

Tags:library, place, required, period, seeks, jurisdiction, produce, Street, search, defendants, public, requests, Pursuant, responsive, college, government, defendant, watch, clinton, National, plaintiff, request, records, judicial, school, states, Washington, court, united, 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.  
501 School Street, S.W., Suite 500  
Washington, 20024,  
Plaintiff,  
U.S. NATIONAL ARCHIVES AND  
RECORDS ADMINISTRATION  
8601 Adelphi Road  
College Park, 20740-6001,  
Defendant.  

VERIFIED COMPLAINT FOR DECLARATORY 
AND INJUNCTIVE RELIEF 

Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. National Archives and Records Administration compel compliance with the Freedom ofinformation Act, 
U.S.C.  552 ("FOIA"). grounds therefor, Plaintiff alleges follows: 
JURISDICTION AND VENUE The 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 non-profit, educational foundation organized under the laws the District Columbia and having its principal place business 501 School Street, S.W., Suite 500, Washington, 20024. Plaintiff seeks promote integrity, transparency, and 
accountability government and fidelity the rule law. furtherance its public interest 

mission, Plaintiff regularly serves FOIA requests federal, state, and local government agencies, entities, and offices, and disseminates its findings the public. Defendant agency the United States Government. Defendant has its principal place business 8601 Adelphi Road, College Park, 20740-6001. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS about April 2006, Plaintiff sent FOIA request the Clinton Presidential Library ("the Library"), which operated and maintained Defendant, requesting access the following records: 
First Lady Hillary Rodham Clinton's calendar, include but not limited her daily office diary, schedule, day planner, telephone log book, and chronological file. 
The time-frame for the request was from January 1993 January 20, 2001, which approximates the time period during which Mrs. Clinton was First Lady. Plaintiff also requested waiver both search and duplication fees pursuant 
U.S.C.  552(a)(4)(A)(ii)(ll) and U.S.C.  552(a)(4)(A)(iii). letter dated April 13, 2006, the Library acknowledged receiving Plaintiff's FOIA request April 2006 and notified Plaintiff that had assigned the request FOIA Case No. 2006-0886-F. The Library also acknowledged that possessed substantial volume records potentially responsive the request. 
Pursuant U.S.C.  552(a)(6)(A)(i), the Library was required respond the request within twenty (20) working days, before May 2006. July 16, 2007, the Library has failed produce any records responsive 

the request demonstrate that responsive records are exempt from production. Nor has indicated when any responsive records would produced. 
COUNT 
(Violation FOIA) Plaintiff realleges paragraphs through fully stated herein. 

11. 
Defendant has violated FOIA failing produce any and all non-exempt records responsive Plaintiff's April 2006 request within the twenty (20) day time period required U.S.C.  552(a)(6)(A)(i) and failing demonstrate that any withheld records responsive this same request are exempt from production. 

12. 
Plaintiff being irreparably harmed reason Defendant's violation ofFOIA, and Plaintiff will continue irreparably harmed unless Defendant compelled conform its conduct the requirements the law. 

WHEREFORE, Plaintiff respectfully requests that the Court: (!) declare Defendants' failure comply with FOIA unlawful; (2) order Defendants search for and produce any and all non-exempt records responsive Plaintiff's April 2006 request and Vaughn index allegedly exempt records responsive the request date certain; (3) enjoin Defendants from continuing withhold any and all non-exempt records responsive the request; (4) grant Plaintiff award attorney's 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: July 16, 2007 Respectfully submitted, 
JUDICIAL WATCH, INC. 

D.C. 
Bar No. 429716 Jason Aldrich 

D.C. 
Bar No. 495488 Suite 500 

501 School Street, S.W. Washington, 20024 
(202) 646-5172 
Attorneys for Plaintiff 
VERIFICATION verify, under penalty perjury, that the Director Investigations and Research for Judicial Watch, Inc., that have read the foregoing VERIFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, and that its contents are true and correct the best personal knowledge, information, and belief. Executed July ?,'2007 Washington, DC. 

Christopher