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Judicial Watch • Navy Bin Laden Funeral

Navy Bin Laden Funeral

Navy Bin Laden Funeral

Page 1: Navy Bin Laden Funeral

Category:General

Number of Pages:4

Date Created:July 18, 2012

Date Uploaded to the Library:February 20, 2014

Tags:Naval, Osama, determination, laden, Pursuant, responsive, Pentagon, defendant, watch, plaintiff, request, records, judicial, department, Washington, 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, S.W., Suite 800  
Washington, 20024, 
Plaintiff, Civil Action No. 
DEPARTMENT THE NAVY, 
2000 Navy Pentagon 
Washington, 20350-2000, 
Defendant. 
____________________________________) 
 
COMPLAINT 
 
 Plaintiff Judicial Watch, Inc. brings this action against Defendant Department the Navy 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 Department the Navy agency the U.S. Government and headquartered Department the Navy, 2000 Navy Pentagon, Washington, 20350-2000.  Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS March 20, 2012, Plaintiff sent FOIA request Defendant seeking access the following: Any and all records utilized, referenced, relied upon during the preparation and execution any funeral ceremony, rite ritual for Osama bin Laden the USS Carl Vinson prior his burial sea.  This request includes, but not limited to, the text any prepared remarks prayers, any instructions provided those attendance, any instructions guidance regarding the handling bin Ladens remains. 
 
ii. Any and all records communication between any official employee the Department the Navy and any official employee any other government department, agency office regarding any funeral ceremony, rite, ritual for Osama bin Laden prior his burial sea. Defendant acknowledged receipt Plaintiffs FOIA request email dated March 22, 2012 and assigned the request Case File No. DON2012F030859. Plaintiff subsequently received letter dated April 2012 and email dated April 2012, both from Defendant, stating that Plaintiffs request had been redirected the Commander, Naval Air Forces and assigned FOIA Nos. 21-12 and 0732.  According the April 2012 letter, the Commander, Naval Air Forces received Plaintiffs request March 27, 2012. Pursuant U.S.C.  552(a)(6)(A)(i), Defendant was required determine whether comply with Plaintiffs request within twenty (20) working days after receipt the request and notify Plaintiff immediately its determination, the reasons therefor, and the right appeal any adverse determination.  Accordingly, Defendants determination was due April 24, 2012 the latest. the date this Complaint, Defendant has failed to:  (i) determine whether comply with Plaintiffs request; (ii) notify Plaintiff any such determination the reasons therefor; (iii) advise Plaintiff the right appeal any adverse determination; (iv) produce the requested records otherwise demonstrate that the requested records are exempt from production.   
10. Because Defendant has 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 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 the 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 records responsive 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:  July 18, 2012     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