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Judicial Watch • DNI Suit Stamped Complaint – 5/13/14

DNI Suit Stamped Complaint – 5/13/14

DNI Suit Stamped Complaint – 5/13/14

Page 1: DNI Suit Stamped Complaint – 5/13/14

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Number of Pages:4

Date Created:April 24, 2014

Date Uploaded to the Library:May 13, 2014

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THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

JUDICIAL WATCH, INC.,  
425 Third Street, S.W., Suite 800  
Washington,  20024,  
Plaintiff,  Civil Action No.  
OFFICE THE DIRECTOR NATIONAL INTELLIGENCE,  
Washington, 20511,  
Defendant.  

COMPLAINT 
Plaintiff Judicial Watch, Inc. brings this action against Defendant Office the Director 
National Intelligence ("ODNI") compel compliance with the Freedom Information 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 Judicial Watch, Inc. 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. part its educational mission, Plaintiff regularly requests records under the FOIA shed light the operations the federal government and educate the public about these operations. Plaintiff then analyzes the records obtains and disseminates its findings the public. Defendant ODNI agency the United States Government and headquartered Washington, 20511. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS December 18, 2013, Plaintiff sent FOIA request Defendant facsimile 
and certified mail, return receipt requested, seeking access the following: 
All Notifications Personnel Action (SF-50's), financial disclosure forms, conflict interest forms, and expense reports for former ODNI and National Intelligence Council advisor Theodore Moran from January 2007, the present. All memoranda and reports produced Theodore Moran connection with his role advisor ODNI the National Intelligence Council from January 2007, the present. letter dated December 30, 2013, Defendant acknowledged receipt Plaintiffs request and assigned the request Case No. DF-2014-00079. 
Pursuant U.S.C.  552(a)(6)(A)(i), Defendant was required respond Plaintiffs request within twenty (20) working days December 23, 2013, January, 23, 2014. the date this Complaint, Defendant has failed make determination about whether will comply with Plaintiffs request, notify Plaintiff any determination, notify Plaintiff its right appeal any adverse determination the head the agency. Nor has Defendant produced any records responsive the request, indicated when any responsive records will produced, demonstrated that responsive records are exempt from production. Because Defendant failed comply with the time limit set forth U.S.C.  552(a)(6)(A), Plaintiff deemed have exhausted any and all administrative remedies with respect its FOIA request, pursuant U.S.C.  552(a)(6)(C). 
COUNT (Violation FOIA, U.S.C.  552) 
10. Plaintiff realleges paragraphs through9 fully stated herein. 
11. 
Defendant unlawfully withholding records requested Plaintiff pursuant U.S.C.  552. 

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 the law. 

WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant conduct search for any and all responsive records Plaintiffs 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 any responsive records withheld under claim exemption; (3) enjoin Defendant from continuing withhold any and all non-exempt records responsive Plaintiffs FOIA request; grant Plaintiff award attorneys' fees and othr 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: April 24, 2014 
Respectfully submitted, 
JUDICIAL WATCH, INC. 
Isl Jason Aldrich 
D.C. Bar No. 495488 425 Third Stree S.W., Suite 800 Washington, 20024 
(202) 646-5172 
Attorneys/or Plaintiff



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