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Judicial Watch • DoD and CIA Answer

DoD and CIA Answer

DoD and CIA Answer

Page 1: DoD and CIA Answer

Category:General

Number of Pages:4

Date Created:February 16, 2012

Date Uploaded to the Library:February 20, 2014

Tags:sentence, allegations, Programs, paragraph, statement, Defense, defendants, Marcia, response, complaint, email, Pentagon, watch, plaintiff, DOJ, federal, judicial, Washington, 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., Civil Action No. Plaintiff, 1:12-cv-00049-RBW 

U.S. DEPARTMENT DEFENSE, and CENTRAL INTELLIGENCE AGENCY, 
Defendants. 
DEFENDANTS ANSWER PLAINTIFFS COMPLAINT 
Defendants U.S. Department Defense (DoD) and Central Intelligence Agency (CIA), through their undersigned counsel, hereby answer plaintiffs Complaint follows. 
This paragraph contains plaintiffs statement the jurisdictional basis for this action, which response required. 
This paragraph contains plaintiffs statement the venue for this action, which response required. 
Defendants lack knowledge information sufficient form belief the truth the allegations this paragraph. 
Defendants admit the allegations the first sentence this paragraph, except deny that DoD headquartered 1600 Defense Pentagon, Washington, 20301-1600. DoDs address listed its website 1400 Defense Pentagon, Washington, 20301-1400. The second sentence this paragraph contains conclusions law, which response required. 
Defendants admit the allegations the first sentence this paragraph.  The second sentence this paragraph contains conclusions law, which response required. 
Defendants admit that plaintiff sent FOIA request DoD August 2011, and respectfully refer the Court plaintiffs August 2011 letter DoD for complete and accurate statement plaintiffs FOIA request. 
Defendants admit the allegations the first sentence this paragraph. Regarding the second sentence, defendants respectfully refer the Court DoDs August 22, 2011 response letter for complete and accurate statement its contents. This paragraph contains conclusions law, which response required. 
Defendants admit that plaintiff sent FOIA request the CIA August 2011, and respectfully refer the Court plaintiffs August 2011 letter the CIA for complete and accurate statement plaintiffs FOIA request. 

10. 
Defendants admit the allegations the first sentence this paragraph. Regarding the second sentence, defendants respectfully refer the Court the CIAs August 16, 2011 response letter for complete and accurate statement its contents. 

11. This paragraph contains conclusions law, which response required. 
12. Defendants deny the allegations this paragraph, except admit that the date the Complaint, defendants have neither produced records responsive plaintiffs requests nor indicated whether any such records will produced.  Defendants respectfully refer the Court DoDs August 22, 2011 letter and the CIAs August 16, 2011 letter for complete and accurate statement their contents. 
13. 
This paragraph contains conclusions law, which response required. 

14. 
The answers all preceding paragraphs are incorporated herein reference. 

15. 
Defendants deny the allegations this paragraph. 

16. 
Defendants deny the allegations this paragraph. 

Defendants deny any and all allegations the Complaint not expressly admitted herein. addition, defendants deny that plaintiff entitled the relief requested its Prayer for Relief, any relief whatsoever. 
WHEREFORE, defendants respectfully request that this action dismissed with prejudice and that the Court grant defendants such other relief may appropriate. 
Respectfully Submitted, 
TONY WEST Assistant Attorney General 
JOHN TYLER Assistant Director, Federal Programs Branch
 /s/ Marcia Berman                              MARCIA BERMAN (PA Bar No. 66168) United States Department Justice Civil Division, Federal Programs Branch Massachusetts Avenue N.W.  Room 7132 Washington, D.C.  20530 Tel.: (202) 514-2205 Fax: (202) 616-8470 Email:  marcia.berman@usdoj.gov 
Attorneys for Defendants. 

CERTIFICATE SERVICE hereby certify that February 16, 2012, true and correct copy the foregoing Defendants Answer Plaintiffs Complaint was served upon plaintiffs counsel record the address listed below: 
Via ECF: 
Paul Orfanedes 
Chris Fedeli 
JUDICIAL WATCH, INC. 
425 Third Street, 
Suite 800 
Washington, 20024 

(202) 646-5172 
Email: porfanedes@judicialwatch.org CFedeli@judicialwatch.org 
 /s/ Marcia Berman                              MARCIA BERMAN



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