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Judicial Watch • JW v CIA Russia Election Interference Complaint 00414

JW v CIA Russia Election Interference Complaint 00414

JW v CIA Russia Election Interference Complaint 00414

Page 1: JW v CIA Russia Election Interference Complaint 00414

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Number of Pages:4

Date Created:March 7, 2017

Date Uploaded to the Library:March 08, 2017

Tags:Interference, 00414, Russia, Election, determination, requested, complaint, responsive, defendant, filed, plaintiff, request, document, michael, records, FOIA, Washington, CIA


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Case 1:17-cv-00414 Document Filed 03/08/17 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
425 Third Street, S.W., Suite 800
Washington, 20024,
Plaintiff,
CENTRAL INTELLIGENCE AGENCY,
Office General Counsel
Washington, 20505,
Defendant.
Civil Action No.
COMPLAINT
Plaintiff Judicial Watch, Inc. brings this action against Defendant Central Intelligence
Agency 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. not-for-profit, educational organization
incorporated under the laws the District Columbia and headquartered 425 Third Street
S.W., Suite 800, Washington, 20024. Plaintiff seeks promote transparency,
accountability, and integrity government and fidelity the rule law. part its
mission, Plaintiff regularly requests records from federal agencies pursuant FOIA. Plaintiff
Case 1:17-cv-00414 Document Filed 03/08/17 Page
analyzes the responses and disseminates its findings and the requested records the American
public inform them about what their government to.
Defendant Central Intelligence Agency CIA agency the U.S.
Government and headquartered Langley, Virginia. The CIA has possession, custody, and
control records which Plaintiff seeks access.
STATEMENT FACTS December 13, 2016, the Wall Street Journal reported that Representative
Mike Turner (R., Ohio) requested that the CIA release unclassified assessment Russia
meddling foreign elections.
Subsequently, December 14, 2016, Plaintiff submitted FOIA request the
CIA seeking the production that unclassified assessment. letter dated January 2017, the CIA acknowledged receipt Plaintiff
FOIA request December 22, 2016 and assigned Reference Number F-2017-00540.
Pursuant U.S.C. 552(a)(6)(A)(i), the CIA was required determine
whether comply with the FOIA request within twenty (20) working days receipt the
request and notify Plaintiff immediately its determination, the reasons therefor, and the
right appeal any adverse determination.
The CIA determination regarding Plaintiff FOIA request was due January
24, 2017 the latest.
10. email dated March 2017, the CIA provided Plaintiff with estimated
completion date, subject change, December 28, 2017, approximately months after
determination due.
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Case 1:17-cv-00414 Document Filed 03/08/17 Page
11. the date this complaint, the CIA has failed to: (i) determine whether
comply with Plaintiff FOIA request; (ii) notify Plaintiff any such determination the
reasons therefor; (iii) advise Plaintiff the right appeal any adverse determination; (iv)
produce the requested records otherwise demonstrate that the requested records are exempt
from production.
12.
Because the CIA has failed comply with the time limit set forth U.S.C.
552(a)(6)(A), Plaintiff deemed have exhausted any and all administrative remedies pursuant U.S.C. 552(a)(6)(C).
COUNT
(Violation FOIA, U.S.C. 552)
13.
Plaintiff realleges paragraphs through fully stated herein.
14.
Defendant unlawfully withholding records requested Plaintiff pursuant U.S.C. 552.
15.
Plaintiff being irreparably harmed reason Defendant unlawful
withholding records responsive Plaintiff FOIA request, and Plaintiff will continue
irreparably harmed unless Defendant compelled conform their conduct the requirements the law.
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant
conduct searches for any and all responsive records Plaintiff FOIA request and demonstrate
that employed search methods reasonably likely lead the discovery records responsive Plaintiff FOIA request; (2) order Defendant produce, date certain, any and all nonexempt records Plaintiff FOIA request and Vaughn index any responsive records
withheld under claim exemption; (3) enjoin Defendant from continuing withhold any and
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Case 1:17-cv-00414 Document Filed 03/08/17 Page
all non-exempt records responsive Plaintiff FOIA request; (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.
Dated: March 2017
Respectfully submitted,
/s/ Michael Bekesha
Michael Bekesha
D.C. Bar No. 995749
JUDICIAL WATCH, INC.
425 Third Street, S.W., Suite 800
Washington, 20024
(202) 646-5172
Counsel for Plaintiff
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