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Judicial Watch • Jw v Usaf Complaint 02102011

Jw v Usaf Complaint 02102011

Jw v Usaf Complaint 02102011

Page 1: Jw v Usaf Complaint 02102011

Category:General

Number of Pages:3

Date Created:February 11, 2011

Date Uploaded to the Library:February 20, 2014

Tags:02102011, Usaf, complaint


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THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

JUDICIAL WATCH, INC., 
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF 
Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Air Force compel compliance with the Freedom oflnfonnation Act, U.S.C.  552 ("FOIA"). grotmds 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. Plaint1ff seeks promote integrity, transparency, and accountability government and fidelity the rule law. furtherance its public interest 
425 Third Street, S.W., Suite 800 Washington, 20024, 
Plaintiff, 
UNITED STATES AIR FORCE 1000 Air Force Pentagon 
Washington, 20330-1000, 
Defendant.  Case: :11 -cv-00349 Assigned To: Leon, Richard Assign. Date: 2/10/2011 Description: FOIA/Privacy Act 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) 
10. Plaintiff realleges paragraphs through fully stated herein. Defendant Wllawfully withholding records requested Plaintiff pursuant u.s.c.  552. 
12. Plaintiff being irreparably harmed reason Defendant's Wllawful withholding requested records, and Plaintiff will continue irreparably harmed Wlless 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 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 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: Febmary 2011 Respectfully submitted, 
JUDICIAL WATCH, INC. 
D.C. Bar No. 429716 Aldrich 
D.C. Bar No. 495488 
Suite 800 
425 Third Street, S.W. 
Washington, 20024 

(202) 646-5172 

Attorneys for Plaintiff