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Judicial Watch • JW v IRS 01872 Church Monitoring

JW v IRS 01872 Church Monitoring

JW v IRS 01872 Church Monitoring

Page 1: JW v IRS 01872 Church Monitoring

Category:Lawsuit

Number of Pages:4

Date Created:November 6, 2014

Date Uploaded to the Library:November 24, 2014

Tags:01872, church, IRS


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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, SW, Suite 800 Washington, D.C. 20024, 
Plaintiff, Civil Action No. 
INTERNAL REVENUE SERVICE, 
1111 Constitution venue, 
Washington, D.C. 20224, 
Defendant. 
COMPLAINT 
Plaintiff Judicial Watch, Inc. brings this action against Defendant Internal Revenue Service compel compliance with the Freedom oflnformation Act, U.S.C.  552 ("FOIA"). 
grounds therefor, Plaintiff alleges follows: 
Venue proper this district pursuant U.S.C.  139l(e). 
Plaintiff Judicial Watch, Inc. not-for-profit, educational organization u.s.c.  1331. 

incorporated under the laws the District Columbia and headquartered 425 Third Street SW, 
Suite 800, Washington, D.C. 20024. Plaintiff seeks promote transparency, integrity, and accountability government and fidelity the rule law. part its mission, Plaintiff 
regularly requests records from federal agencies pursuant FOIA. Plaintiff analyzes the responses and disseminates its findings and the requested records the American public inform 

them about "what their government to." 	Defendant Internal Revenue Service agency the United States Government 
and headquartered 1111 Constitution venue, NW, Washington, 20224. Defendant has 
possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS August 2014, Plaintiff sent FOIA request Defendant seeking access 
the following: 
(1) 	
Any and all records concerning, regarding, related communications between the IRS and the Freedom From Religion Foundation (FFRF) the promotion political issues, legislation, and candidates churches and other tax-exempt religious organizations; and 

(2) 	
Any and all records concerning, regarding, related IRS monitoring churches and other tax-exempt religious organizations ensure that such organizations are not engaging the promotion political issues, legislation, and candidates. letter dated September 2014, Defendant acknowledged receiving Plaintiffs 
request August 2014 and assigned the request case number F14220-0128. Defendant also 
informed Plaintiff that Defendant had invoked 10-day extension time process the request, 
authorized U.S.C.  552(a)(6)(B), and unilaterally granted itself additional, unauthorized 
extension until October 31, 2014: 
Unfortunately, will still unable locate and consider release the requested 
records September 22, 2014. have extended the response date October 
31, 2014 when believe can provide final response You may file suit 
you not agree extension beyond the statutory period. the date this complaint, Defendant has failed to: (i) determine whether comply with the 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. 
Because Defendant 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). 

COUNTl (Violation FOIA, U.S.C.  552) Plaintiff realleges paragraphs through fully stated herein. 
11. Defendant unlawfully withholding records requested Plaintiff under FOIA. 
12. Plaintiff being irreparably harmed reason Defendant's unlawful withholding records responsive Plaintiffs' FOIA request, and Plaintiff 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 search for any and all records responsive 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 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 Plaintiffs FOIA request; (4) 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: November 2014 Respectfully submitted, 
Isl Paul 
D.C. Bar No. 429716 
JUDICIAL WATCH, INC. 
425 Third Street, SW, Suite 800 Washington, 20024 
(202) 646-5172 
Attorney for Plaintiff