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Judicial Watch • Leopold v. State complaint 00123

Leopold v. State complaint 00123

Leopold v. State complaint 00123

Page 1: Leopold v. State complaint 00123

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Number of Pages:5

Date Created:January 25, 2015

Date Uploaded to the Library:March 11, 2016

Tags:00123, Leopold, Times, complaint, Secretary, defendant, filed, clinton, plaintiff, request, document, records, FOIA, department, office, states, Washington, united


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Case 1:15-cv-00123-RC Document Filed 01/25/15 Page
UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JASON LEOPOLD,
1669 Benedict Canyon Drive
Beverly Hills, 90210,
PLAINTIFF
vs.
DEPARTMENT STATE,
2201 St.,
Washington, 20520,
DEFENDANT Judge _____________ Civil Action No. ____________
COMPLAINT
THE PARTIES
Plaintiff Jason Leopold citizen the United States.
Plaintiff investigative reporter for VICE News covering wide-range
issues, including Guantanamo, national security, counterterrorism, civil liberties, human rights,
and open government. Additionally, his reporting has been published The Guardian, The Wall
Street Journal, The Financial Times, Salon, CBS Marketwatch, The Los Angeles Times, The
Nation, Truthout, Jazeera English and Jazeera America.
Defendant Department State DOS agency the United States within
the meaning USC 552 (f).
Case 1:15-cv-00123-RC Document Filed 01/25/15 Page
The DOS has possession, custody and control the records Plaintiff seeks.
JURISDICTION AND VENUE
This action arises under the Freedom Information Act FOIA USC 552.
This Court has jurisdiction over the parties and subject matter pursuant USC
552(a)(4)(B). Jurisdiction also lies with this Court under USC 1331.
Venue proper this district pursuant USC 552(a)(4)(B).
STATEMENT FACTS
BACKGROUND
Hillary Rodham Clinton served Secretary the Department State from
January 21, 2009 February 2013.
How cabinet Secretary performs his her functions always matter public
interest. This particularly true the case Secretary Clinton due the widespread
speculation that she will run for President the United States 2016. Accordingly, how
Secretary Clinton managed personnel, conducted foreign policy, prioritized goals and negotiated
competing interests both domestically and abroad during her tenure the helm the State
Department great interest the American public.
PLAINTIFF FOIA REQUEST
10. letter dated November 2014, Plaintiff submitted FOIA request for any
and all records that were prepared, received, transmitted, collected and/or maintained the
Department State (DOS) mentioning referring prepared Secretary State Hillary
Clinton any member the Office the Secretary (S) from January 21, 2009 February
2013.
Case 1:15-cv-00123-RC Document Filed 01/25/15 Page
11.
Plaintiff FOIA request stated that includes, but not limited to, (1) Records
prepared Secretary Clinton, any member the Office the Secretary (S) whole part; and (2) Notes made Secretary Clinton about any meeting record prepared
any other person; and (3) Emails sent Secretary Clinton any member the Office the
Secretary (S); and (4) Records meetings, including individual participant notes, which
Secretary Clinton any member the Office the Secretary (S) attended which she
any member the Office the Secretary (S) otherwise participated.
12.
Plaintiff FOIA request provided his credentials published journalist and
requested fee waiver and expedited processing.
DEFENDANT FAILURE TIMELY RESPOND
PLAINTIFF FOIA REQUEST
13.
The DOS assigned Plaintiff FOIA request tracking number F-2014-20439.
letter dated November 24, 2014, DOS granted Plaintiff request for fee waiver but denied
Plaintiff request for expedited processing.
14. the filing this Complaint, Plaintiff has not received final response his
FOIA request the DOS with determination whether the agency will release withhold
all the requested records.
15.
Under USC 552(a)(6)(C)(i), Plaintiff deemed have exhausted his
administrative remedies with regard his FOIA request the DOS because Defendant has
failed comply with the statutory time limit set forth USC 552(a)(6)(A)(i).
COUNT
VIOLATION FOIA
16.
This Count realleges and incorporates reference all the preceding
paragraphs.
Case 1:15-cv-00123-RC Document Filed 01/25/15 Page
17.
Each the documents referred this Complaint incorporated herein
reference.
18.
The DOS has violated FOIA failing grant Plaintiff request for expedited
processing.
19.
The DOS has violated FOIA failing make final decision whether
these agency will release withhold all the requested records within the statutory timeframe.
20.
Plaintiff has been and will continue irreparably harmed until Defendant
ordered comply with FOIA.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court:
(1) Declare Defendant failure comply with FOIA unlawful;
(2) Declare that Plaintiff entitled expedited processing his FOIA request;
(3) Order Defendant search for and process the requested records without further delay;
(4) Grant Plaintiff award attorney fees and other litigation costs reasonably incurred
this action pursuant USC 552(a)(4)(E)(i);
(5) Grant Plaintiff such other and further relief which the Court deems proper.
Respectfully Submitted,
__/s/ Ryan James_______________
Ryan James
D.C. Bar #496272
5208 Capricorn Loop
Killeen, 76542
(254)289-7459
RSJamesLaw@gmail.com
Case 1:15-cv-00123-RC Document Filed 01/25/15 Page
Jeffrey Light
D.C. Bar #485360
1712 Eye St.,
Suite 915
Washington, 20006
(202)277-6213
Jeffrey.Light@yahoo.com
Counsel for Plaintiff