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Judicial Watch • Mi Familia Vota

Mi Familia Vota

Mi Familia Vota

Page 1: Mi Familia Vota

Category:General

Number of Pages:4

Date Created:April 30, 2013

Date Uploaded to the Library:February 20, 2014

Tags:Vota, Familia


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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, S.W., Suite 800 Washington, D.C. 20024, 
Plaintiff, Civil Action No. 
U.S. DEPARTMENT JUSTICE, 950 Pennsylvania Avenue, N.W. 
Washington, D.C. 20530-0001, 
Defendant. 

COMPLAINT 
Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Department Justice compel compliance with the Freedom oflnformation Act, .S.C.  552 ("FOIA' grounds therefor, Plaintiff alleges follows: 
JURISDICTION 
VENVE 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, D.C. 20024. Plaintiff seeks promote integrity, transparency, and accowitability government and fidelity the rule law. furtherance ofits 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 
950 Pennsylvania Ave., N.W., Washington, D.C. 20530-0001. Defendant has possession, 
custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS June 14, 2012, Plaintiff sent FOIA request Defendant certified mail, 
return receipt requested, seeking access the following: 
All records communications between the Department Justice and the American Civil Liberties Union (ACLU) concerning, regarding, relating Familia Vota Education Fund Detzner, 12-cv-t294, 
U.S. District Court, Middle District Florida (Tampa). According the United States Postal Service's return receipt, Defendant received 
Plaintiff's FOIA request June 18, 2012. letter dated Jllle 18, 2012, Defendant acknowledged receipt Plaintiff's 
request and assigned the request FOI/PA No. 12
-00361-F. Defendant was required determine whether comply with Plaintiffs request 
within days, excepting Saturdays, SWldays, 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 Independence 
Day (July 2012) holiday, Defendant was required make its determination and provide 
Plaintiff with the requisite notifications July 17, 2012 the latest. the date ofthis Complaint, Defendant has failed make determination 
about whether will comply with Plaintiff's 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.  5S2(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). 
COUNTl (Violation ofFOIA, U.S.C.  552) 
11. Plaintiff realleges paragraphs through iffully stated herein. 
12. 
Defendant unlawfully withholding records requested Plaintiff pursuant u.s.c.  552. 

13. 
Plaintiff being irreparably harmed reason Defendant's unlawful withholding requested records, and Plaintiff will continue irreparably harmed unless Defendant compelled confonn its conduct the requirements the law. 

WHEREFORE, Plaintiff respectfully requests that the Court: (1) Order Defendant conduct search for any and all responsive records Plaintiff's 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 Plaintiff's 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 
. 
attomeys1 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. 

Daed: Ap,dl 30, 2013 	Repeetfully submitted, JUDICIAL WATCH, INC. 
Washington, D.C. 20024 
(202) 6-S 172 
Attorneys for Plaintiff