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Judicial Watch • JW v. DOJ al-Hanooti 00655

JW v. DOJ al-Hanooti 00655

JW v. DOJ al-Hanooti 00655

Page 1: JW v. DOJ al-Hanooti 00655

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Number of Pages:4

Date Created:April 20, 2016

Date Uploaded to the Library:April 21, 2016

Tags:Hanooti, 00655, Pennsylvania, requested, Plaintiffs, responsive, justice, defendant, filed, plaintiff, request, FBI, document, records, DOJ, FOIA, department, Washington


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Case 1:16-cv-00655-RBW Document Filed 04/07/16 Page 1of4 THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
425 Third Street, SW, Suite 800
Washington, 20024,
Plaintiff,
U.S. DEPARTMENT rusTICE.
950 Pennsylvania Avenue,
Washington, 20530-0001,
Defendant.
Civil Action No.
COMPLAINT
Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. Department
Justice 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. l39l(e).
Plaintiff Judicial Watch, Inc. not-for-profit, educational organization
incorporated wider the laws the District Columbia and headquartered 425 Third Street
SW, 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 analyzes the
Case 1:16-cv-00655-RBW Document Filed 04/07/16 Page
responses and disseminates its findings and the requested records the American public
inform them about what their government to.
Defendant U.S. Department Justice agency the United States
Government. Defendant has possession, custody, and control records which Plaintiff seeks
access. Defendant headquartered U.S. Department Justice, 950 Pennsylvania Avenue,
NW, Washington, 20530-0001.
STATEMENT FACTS June 2015, Plaintiff submitted FOIA request the Federal Bureau
Investigation (FBI), component Defendant, seeking the folJowing:
Any and all records regarding, concerning, related
deceased individual, named Muhammad al-Hanooti, This
individual was born March 12, 1937 Haifa, British
Mandate Palestine (now Israel) and died June 2015
Virginia. proof death, please find endosed article
regarding Mr. al-Hanootis passing published National
Review.
The request was submitted via certified mail and online via the FBIs eFOIA system. letter dated July 31, 2015, Defendant acknowledged receiving Plaintiffs
request and advised Plaintiff that the request had been assigned FOIPA Request No. 1331182000. the date this Complaint, Defendant has failed to: (i) produce the
requested records demonstrate that the requested records are lawfully exempt from
production; (ii) notify Plaintiff the scope any responsive records Defendant intends
produce withhold and the reasons for any withholdings; (iii) infonn Plaintiff that may
appeal any adequately specific, adverse determination.
-2-
Case 1:16-cv-00655-RBW Document Filed 04/07/16 Page
COUNT
(Violation FOIA, U.S.C. 552)
Plaintiffrealleges paragraphs through fully stated herein.
Plaintiff being irreparably harmed reason Defendants violation ofFOIA,
and Plaintiff will continue irreparably harmed unless Defendant compelled comply
with FOIA.
10. trigger FOIAs administrative exhaustion requirement, Defendant was
required detennine whether comply with Plaintiffs request within twenty (20) working
days receiving the request July 31, 2015. Accordingly, Defendants detennination was due about August 28, 2015. minimum, Defendant was required to: (i) gather and review
the requested documents; (ii) detennine and communicate Plaintiff the scope any
responsive records Defendant intended produce withhold and the reasons for any
withholdings; and (iii) inform Plaintiff that may appeal any adequately specific, adverse
determination. See, e.g., Citizens for Responsibility and Ethics Washington Federal
Election Commission, 71lF.3d180, 188-89 (D.C. Cir. 2013).
11.
Because Defendant failed determine whether comply with Plaintiffs request
within the time period required FOIA, Plaintiff deemed have exhausted its administrative
appeal remedies. U.S.C. 552(a)(6)(C)(i).
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant
conduct searches 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 Plaintiffs FOIA request and Vaughn index any responsive records
withheld under claim exemption; (3) enjoin Defendant from continuing withhold any and
-3-
Case 1:16-cv-00655-RBW Document Filed 04/07/16 Page
all non-exempt records responsive Plaintiffs 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: April 2016
Respectfully submitted,
Isl Jason Aldrich
Jason Aldrich
D.C. Bar No. 495488
JUDICIAL WATCH, INC.
425 Third Street, SW, Suite 800
Washington, 20024
(202) 646-5172
Counsel for Plaintiff