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Judicial Watch • JW v U.S. National Archives and Records Administration (cv-07-1987)

JW v U.S. National Archives and Records Administration (cv-07-1987)

JW v U.S. National Archives and Records Administration (cv-07-1987)

Page 1: JW v U.S. National Archives and Records Administration (cv-07-1987)

Category:Lawsuit

Number of Pages:4

Date Created:November 2, 2007

Date Uploaded to the Library:November 01, 2013

Tags:Hillary Clinton


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  • demand_answers

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THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.
501 School Street, S.W., Suite 500
Washington, 20024,
Plaintiff,
U.S. NATIONAL ARCHIVES AND
RECORDS ADMINISTRATION
8601 Adelphi Road
College Park, 20740-6001,
VVVVC/vvvwvvvvv
Defendant.
COMPLAINT FOR DECLARATORY
AND INJUNCTIVE RELIEF
Plaintiff Judicial Watch, Inc. brings this action against Defendant US. National Archives
and Records Administration compel compliance with the Freedom Infoxmation Act,
USC. 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. 133]. Venue proper this district pursuant USC. 139l(e).
PARTIES Plaintiff non prof1t, educational foundation organized under the laws the
District Columbia and having its principal place ofbusiness 501 School Street, SW., Suite
500, Washington, 20024. Plaintiff seeks promote integrity, transparency, and
accountability government and delity the rule law. furtherance its public interest
mission, Plaintiff regularly serves FOIA requests federal, state, and local government
agencies, entities, and offices, and disseminates its ndings the public. Defendant agency the United States Government. Defendant has its
principal place ofbusiness 8601 Adelphi Road, College Park, 20740-6001, Defendant
has possession, custody, and control records wl1icl1 Plaintiff seeks access.
STATEMENT FACTS about April 2006, Plaintiff sent FOIA request the Clinton
Presidential Library the Library which operated and maintained Defendant, requesting
access records the Task Force National Health Care Reform chaired former First Lady
(now Senator) Hillary Rodham Clinton. Plaintiff also requested waiver botl1 search and duplication fees pursuant
U.s.C. 552(a)(4)(A)(ii)(H) and U.S.C. 552(a)(4)(A)(iii). letter dated April 10, 2006, the Library acknowledged receiving Plaintiff
FOIA request April 2006 and notified Plaintiffthat had assigned the request FOIA Case
No. 2006-0S85~F. The Library also acknowledged that possessed substantial volume
records potentially responsive the request. November 2007, the Library has failed allow Plaintiff access any
records responsive Plaintiffs April 2006 request indicate when access would allowed.
Nor has the Library demonstrated that responsive records are exempt from disclosure.
COUNT
(Violation FOlA) Plaintiff realleges paragraphs through fully stated herein.
10. Plaintiff has statutory right under 01A access and/or review any and all non 
exempt records responsive Plaintiff April 2006 request.
ll. Defendant has violated FOIA failing allow Plaintiff access any and all
non-exempt records responsive Plaintiffs April 2006 request and/or failing
demonstrate that any such records are exempt from disclosure.
12. Plaintiff being irreparably harmed reason Defendant violation FOIA,
and Plaintiff will continue irreparably harmed u11less Defendant compelled conform its
conduct the requirements the law.
WHEREFORE, Plaintiff respectfully requests that the Court: (1) declare Defendant
failure comply with FOIA unlawful; (2) enjoin Defendant from continuing deny
Plaintiff access any and all non-exempt records responsive its April 2006 request; (3)
order Defendant produce Vaughn index any allegedly exempt records responsive
Plaintiffs April 2006 request; (4) grant Plaintiff award attorney 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.
.3.
Dated: November 2007
Respectfully submitted,
JUDICIAL WATCH, INC.
 
D.C. Bar No. 429716
James Peterson
D.C. BzuN0. 45017]
Suite 500
501 School Street, SW.
Washington, 20024
(202) 646-5172
Afforneysfor Plaintiff