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Judicial Watch • JW v DOJ 01048 – Clemency Complaint 6-23-2014

JW v DOJ 01048 – Clemency Complaint 6-23-2014

JW v DOJ 01048 – Clemency Complaint 6-23-2014

Page 1: JW v DOJ 01048 – Clemency Complaint 6-23-2014

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Number of Pages:4

Date Created:June 23, 2014

Date Uploaded to the Library:July 23, 2014

Tags:Clemency, department of justice, 2014, DOJ


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THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

ruDICIAL WATCH, INC., 
425 Third Street, S.W., Suite 800 
Washington, 20024, 
Plaintiff, Civil Action No. 
U.S. DEPARTMENT JUSTICE, 950 Pennsylvania Avenue, N.W., Washington, 20530, 
Defendant. 

) Plaintiff Judicial Watch, Inc. not-for-profit, educational foundation organized 
under the laws the District Columbia and has its principal place business 425 Third 
Street, S.W., Suite 800, Washington, 20024. Plaintiff seeks promote transparency, 
accountability, and integrity government, politics, and the law. part its educational 
mission, Plaintiff regularly requests records under FOIA shed light the operations the 

federal government and educate the public about these operations. Plaintiff then analyzes the agency records and disseminates the results its analysis, well the records themselves, the public. Defendant U.S. Department Justice agency the United States government and headquartered 950 Pennsylvania Avenue, N.W., Washington, 20530. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS March to, 2014, Plaintiff submitted FOIA request Defendant certified 
mail, seeking access to: 
Any and all records communication between employees officials the Office Deputy Attorney General James Cole and representatives the Federal Defenders, the ACLU, FAMM, the ABA and NACOL related to, connection with regarding the 
clemency Project 2014' from January 2014 the present date. 
According the United States Postal Service records, Plaintifrs FOTA request was delivered defendant March 19, 2014. May 16, 2014, Plain sent letter certified mail Defendant requesting status update regarding Plaintiffs FOTA request sent March 10, 2014. 
Pursuant U.S.C.  552(a)(6)(A)(i), the Defendant was required determine whether comply with Plaintiffs 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 detennination was due April 16, 2014. the date this complaint, the Defendant has failed to: (i) detennine whether comply with Plaintiffs 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. 
10. Because Defendant 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 with 
respect its request, pursuant U.S.C.  552(a)(6)(C). 

11. 
Plaintiff realleges paragraphs through fully stated herein. 

12. 
Defendant unlawfully withholding records requested Plaintiff pursuant 

u.s.c.  552. 
13. Plaintiff being irreparably harmed reason Defendant's unlawful 
withholding ofrecords responsive Plaintiffs FOIA request, and Plaintiff will continue 
irreparably harmed unless Defendant compelled conform its conduct the requirements 
the Jaw. 
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 ofrecords responsive Plaintiff's 1-'0IA 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 Plaintiff's 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: June 23, 2014  RespectfuUy Submjtted,  
Isl Jason Aldrich D.C. Bar No. 495488 JUDICIAL WATCH, INC. 425 Third Street, SW, SuJte 800 Washington, 20024 (202) 646-5172  
Attorneys for Plaintiff