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Judicial Watch • JW v DOJ 01239 public integrity IRS

JW v DOJ 01239 public integrity IRS

JW v DOJ 01239 public integrity IRS

Page 1: JW v DOJ 01239 public integrity IRS

Category:IRS Scandal

Number of Pages:4

Date Created:July 21, 2014

Date Uploaded to the Library:December 08, 2014

Tags:01239, DOJ, IRS


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  • demand_answers

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government agencies, entities and offices under FOIA shed light the operations the 
federal government and educate the public about these operations. Plaintiff then analyzes the 
agency records and disseminates its findings and the agency records the public. Defendant U.S. Department Justice agency the United States 
Government and headquartered U.S. Department Justice, 950 Pennsylvania Avenue, 
N.W., Washington, 20530-0001. Defendant has possession, custody, and control ofrecords which Plaintiff seeks access. 
STATEMENT FACTS 

mail, seeking access to: 	
Any and all records concerning, regarding, related meetings and/or communications between employees the Department Justice Public Integrity Section (PIN) and employees the Internal Revenue Service Tax Exempt and Government Entities Division regarding 50l(c)(4)s other tax-exempt organizations; 	
Any and all records concerning, regarding, related meetings and/or communications between PIN employees and the White House regarding 501 other tax-exempt organizations; 	
Any and all records concerning, regarding, related meetings and/or communications between PIN employees and Members Congress and/or congressional staff regarding 501(c)(4)s other tax-exempt organizations; and 	
Any and all records concerning, regarding, related communications and/or meetings between PIN employees and any non-government entity regarding 501(c)(4)s other tax-exempt organizations. 

The timeframe for this request January 2009 the present. According United States Postal Service records, Plaintiffs FOIA request was 
received Defendant April 28, 2014. Pursuant U.S.C.  552(a)(6)(A)(i), the Defendant was required 
determine whether comply with Plaintiff's request within twenty (20) working days 

after its receipt the request and notify Plaintiff immediately its determination, the 
reasons therefor, and the right appeal any adverse determination. Defendant's determination was due May 27, 2014. the date this complaint, the Defendant has failed to: (i) determine 
whether comply with Plaintiffs request; (ii) notify Plaintiff any such determination the reasons therefor; (iii) advise Plaintiff the right appeal any adverse 
determination; and/or (iv) produce the requested records otherwise demonstrate that 
the requested records are exempt from production. U.S.C.  552(a)(6)(A), Plaintiff deemed have exhausted any and all 
administrative remedies with respect its request, pursuant U.S.C.  552(a)(6)(C). 
COUNT (Violation FOIA, U.S.C.  552) 
10. 
Plaintiff realleges paragraphs through 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 records responsive Plaintiffs FOIA request, and 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 searches for any and all records responsive Plaintiffs FOIA requests and demonstrate 
that employed search methods reasonably likely lead the discovery records responsive Plaintiffs FOIA requests; (2) order Defendant 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 Defendant from continuing withhold 
any and all non-exempt records responsive Plaintiff's FOIA requests; 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 21, 2014  Respectfully submitted,  
JUDICIAL WATCH, INC. Ramona Cotca Ramona Cotca 
D.C. Bar No. 501159 425 Third Street, S.W., Suite 800 Washington, 20024 
(202) 646-5172 
Counsel for Plaintiff