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Judicial Watch • Jw v Secret Service

Jw v Secret Service

Jw v Secret Service

Page 1: Jw v Secret Service

Category:General

Number of Pages:4

Date Created:May 6, 2013

Date Uploaded to the Library:February 20, 2014

Tags:Drive, Murray, determination, Pursuant, responsive, service, defendant, government, Obama, watch, plaintiff, request, records, judicial, states, Washington, united, court, 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, SW, Suite 800 
Washington, D.C. 20024, 
Plaintiff, Civil Action No. 
U.S. SECRET SERVICE, 
245 Murray Drive, Building 410 
Washington, 20223, 
Defendant. 
___________________________________ 
 
COMPLAINT 
 
 Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Secret Service 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.  1391(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. Defendant agency the United States Government and headquartered 245 Murray Drive, Building 410, Washington, 20223.  Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS January 2013, Plaintiff sent FOIA request Defendant certified mail, return receipt requested, seeking access the following: 
All records concerning use U.S. Government funds provide security and/or any other services President Obama and any companions their January and 2013 trip Honolulu, Hawaii. According the United States Postal Services return receipt, Defendant received Plaintiffs FOIA request January 11, 2013. letter dated January 31, 2013, Defendant acknowledged receipt Plaintiffs request and assigned the request File Number 20130256. Defendant was required determine whether comply with Plaintiffs request within days, excepting Saturdays, Sundays, and legal public holidays, pursuant U.S.C.  552(a)(6)(A).  Pursuant this same provision, Defendant also was required notify Plaintiff immediately the determination, the reasons therefor, and the right appeal any adverse determination the head the agency.  Excluding weekends and the intervening Martin Luther King Jr., holiday (January 21, 2013), Defendant was required make its determination and provide Plaintiff with the requisite notifications February 11, 2013 the latest. the date this Complaint, Defendant has failed make determination about whether will comply with Plaintiffs request, notify Plaintiff any determination, 
notify Plaintiff his right appeal any adverse determination the head the agency.  Nor has Defendant produced any records responsive the request, indicated when any responsive records will produced, demonstrated that responsive records are exempt from production.      
 10. 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 with respect its FOIA request, pursuant U.S.C.  552(a)(6)(C). 
      COUNT 
(Violation FOIA, U.S.C.  552) 
 
 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 Defendants unlawful withholding requested records, 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 responsive records Plaintiffs FOIA request and demonstrate that employed search methods reasonably likely lead the discovery records responsive Plaintiff's 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 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: May 2013      Respectfully submitted, 
        JUDICIAL WATCH, INC. 
  
        /S/ Paul Orfanedes   
        D.C. Bar No. 429716 
        425 Third Street, S.W., Suite 800 
        Washington, 20024 
        (202) 646-5172 
 
        Attorneys for Plaintiff



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