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Judicial Watch • JW v DOD CIA Amended Complaint 692011

JW v DOD CIA Amended Complaint 692011

JW v DOD CIA Amended Complaint 692011

Page 1: JW v DOD CIA Amended Complaint 692011

Category:General

Number of Pages:4

Date Created:June 8, 2011

Date Uploaded to the Library:February 20, 2014

Tags:Plainti, Intelligence, laden, Plaintiffs, defendants, Defense, AGENCY, requests, filed, Pentagon, document, plaintiff, request, records, department, states, district, united, EPA, ICE, CIA


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  • demand_answers

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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. 11-00890 (JEB)  

U.S. DEPARTMENT DEFENSE, 1600 Defense Pentagon Washington, 20301-1600, and CENTRAL INTELLIGENCE AGENCY Office General Counsel Washington, 20505, Defendants. 

Plaintiff Judicial Watch, Inc. brings this action against Defendants U.S. Department Defense and the 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.  139l(e). 

PARTIES Plaintiff 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. furtherance its public interest mission, Plaintiff regularly requests access the public records federal, state, and local government agencies, entities, and offices, and disseminates its findings the public. 
The U.S. Department Defense ("the DoD") agency the United States Government and headquartered 1600 Defense Pentagon, Washington, 20301-1600. Defendant has possession, custody, and control ofrecords which Plaintiff seeks access. 
The Central Intelligence Agency ("the CIA") agency the United States Government and headquartered Langley, Virginia. Defendant has possession, custody, and control records which Plaintiff seeks access. 

STATEMENT FACTS May 2011, Plaintiff sent FOIA request the DoD seeking access all photographs and/or video recordings Osama (Usama) Bin Laden taken during and/or after the 
U.S. military operation Pakistan about May 2011. letter dated May 2011, the DoD acknowledged receipt Plaintiffs FOIA 

request and designated the request case number 11-F-0931. addition, the DoD advised 
Plaintiff: this time, are unable make release determination your request within the 20-day statutory time period. Although the FOIA contains provisions for extension more business days, that additional time will not sufficient complete the work required process your request and arrive final release decision. Pursuant U.S.C.  552(a)(6)(A)(i), the DoD was required respond Plaintiff's FOIA request within twenty (20) 
working days May 2011 June 2011. May 2011, Plaintiff also sent FOIA request the CIA seeking access all photographs and/ video recordings Osama sama) Bin Laden taken during and/or after the 
U.S. military operation Pakistan about May 2011. 
10. letter dated May 23, 2011, the CIA acknowledged receipt May 2011 Plaintiff's FOIA request and designated the request case number F-2011-01345. 

11. 
Pursuant U.S.C.  552(a)(6)(A)(i), the CIA was required respond Plaintiff's FOIA request within twenty (20) working days May 2011 June 2011. 

12. the date this Complaint, Defendants have failed produce any records responsive Plaintiff's requests demonstrate that responsive records are exempt from production. Nor have they indicated whether when any responsive records will produced. 

13. 
Because Defendants have 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 FOIA requests. U.S.C.  552(a)(6)(C). 

COUNTl (Violation FOIA, U.S.C.  552) 
14. Plaintiff realleges paragraphs through fully stated herein. 
15. 
Defendants are unlawfully withholding records requested Plaintiff pursuant .S.C.  552. 

16. 
Plaintiff being irreparably harmed reason Defendants' unlawful withholdings requested records, and Plaintiff will continue irreparably haimed unless Defendants are compelled conform their conduct the requirements the law. 

WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendants conduct searches for any and all records responsive Plaintiff's FOIA requests and demonstrate that they have employed search methods reasonably likely lead the discovery records responsive Plaintiffs FOIA requests; (2) order Defendants produce, date certain, any and all non-exempt records responsive Plaintiffs FOIA requests and Vaughn index any responsive records withheld under claim exemption; (3) enjoin Defendants from continuing withhold any and all non-exempt records responsive Plaintiffs FOIA requests; (4) grant 

Plaintiff award attorneys' fees and other litigation costs reasonably incurred this action pursuantto U.S.C.  552(a)(4)(E); and (5) grant Plaintiff such other relief the Court deems just and proper. 
Dated: June 2011 Respectfully submitted, 
JUDICIAL WATCH, INC 
D.C. Bar No. 450171 

425 Third Street, S.W., Suite 800 Washington, 20024 
(202) 646-5172 
Attorneys for Plaintiff



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