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Judicial Watch • Obama Travel Secret Service Suit

Obama Travel Secret Service Suit

Obama Travel Secret Service Suit

Page 1: Obama Travel Secret Service Suit

Category:Lawsuit

Number of Pages:6

Date Created:January 14, 2014

Date Uploaded to the Library:January 30, 2014

Tags:Barack, Plaintiffs, responsive, filed, September, defendant, government, president, document, plaintiff, Obama, request, records, Washington, EPA, IRS, ICE, CIA


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  • demand_answers

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THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

nJDICIAf, WATCH, 1NC., 
425 Third Street, SW, Suite 800  
Washington, D.C. 20024,  
Plaintiff,  Civil Action No.  
U.S. SECRET SERVICE,  
245 Murray Drive, Building 410  
WashlilbrtOn, 20223  
Defendant.  

COMPLAINT 
PlaintiffJudicial Watch, Inc. brings this action against Defendant United States Secret 
Service compel compliance with the Freedom oflnforrnation 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.  39l(e). 
Plaintiff Judicial Watch, Inc. not-for-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. Plaintiffseeks promote integrity, 
transparency, and accountability government and fidelity the rule oflaw. furtherance 

its public interest mission, Judicial Watch regularly requests access public records federal, state, and local government agencies and officials and disseminates its findings the public. Defendant United States Secret Service ("USSS'') agency the United States Government and headquartered 245 Murray Drive, Building 410, Washington, 
20223. Defendant has possession, custody, and control records which Plaintiff seeks 
access. 
STATEMENT FACTS 
.June 19, 2013 Request June 19, 2013, Plaintiff sent FOIA request the USSS seeking access 
records concerning the use U.S. Government funds provide security and other services First Lady Michelle Obama, Malia Obama, Sasha Obama, and any companions June 2013 trip Ireland. letter dated July 17, 2013, the USSS acknowledged receipt Plaintiff's 
request July 2013 and assigned the request File Number 20130859. Pursuant U.S.C.  552(a)(6)(A)(i), the USSS was required respond 
Plaintiff's request within twenty (20) working days July 2013, August 2013. 
July 2013 Request July 2013, Plaintiff sent FOIA request the USSS seeking access 
records concerning the use U.S. Government funds provide security and other services President Barack Obama and any companions June-July 2013 trip Africa. letter dated July 17, 2013, the USSS acknowledged receipt Plaintiffs 
request July 2013 and assigned the request File Number 20130823. 
10. Pursuant U.S.C.  552(a)(6)(A)(i), the USSS was required respond Plaintit'rs request within twenty (20) working days July 2013, August 2013. 
July 31, 2013 Request 
11. July 31, 2013, Plaintiff sent FOIA request the USSS seeking access records concerning the use U.S. Government fWlds provide security and other services First Lady Michelle Obama and any companions Summer 2012 trip London, England for the Olympics. 

12. letter dated August 30, 2013, the USSS acknowledged receipt Plaintiffs request August 12, 2013 and assigned the request File Number 20131297. 

Pursuant U.S.C.  552(a)(6)(A)(i), the USSS was required respond Plaintiffs request within twenty (20) working days August 12, 2013, September 10, 2013. 
August 2013 Request 
14. August 2013, Plaintiff sent FOIA request the USSS seeking access records concerning the use U.S. Government funds provide security and other services President Barack Obama and any companions December 2012 trip Honolulu, Hawaii. 

15. letter dated September 18, 2013, the USSS acknowledged receipt Plaintiff's request August 27, 2013 and assigned the request File Number 20131390. 

16. 
Pursuant U.S.C.  552(a)(6)(A)(i), the USSS was required respond 
Plaintiffs request within twenty (20) working days August 27, 2013, September 25, 
2013. 

August 2013 Request 
17. August 2013, Plaintiff sent FOIA request the USSS seeking access records concerning the use U.S. Government funds provide security and other services President Barack Obama and any companions August 2013 trip California. 

18. letter dated September 17, 2013, the USSS acknowledged receipt Plaintiff's request August 20, 2013 and assigned the request File Number 20131346. 

19. 
Pursuant U.S.C.  552(a)(6)(A)(i), the USSS was required respond Plaintiffs request within twenty (20) working days August 20, 2013, September 18, 2013. 

August 19, 2013 Request 
20. August 19, 2013, Plaintiff sent FOIA request the USSS seeking access records concerning the use U.S. Government funds provide security and other services President Barack Obama and any companions August 2013 trip Martha's Vineyard, Massachusetts. 

21. letter dated September 18, 2013, the USSS acknowledged receipt Plaintiffs request September 2013 and assigned the request File Number 20131414. 

22. 
Pursuant U.S.C.  552(a)(6)(A)(i), the USSS was required respond Plaintiff's request within twenty (20) working days September 2013, October 2013. the date this Complaint, the USSS has failed produce any records responsive Plaintiff's requests demonstrate that responsive records are exempt from production. Nor have they indicated whether when any responsive records will produced. 
24. Because Defendant bas failed comply with the time limit set forth U.S.C.  552(a)(6)(A)(i), Plaintiff deemed have exhausted any and all administrative remedies with respect its requests. U.S.C.  552(a)(6)(C). 
COUNT1 
(Violation FOIA, U.S.C.  552) 

Plaintiffrealleges paragraphs through fully stated herein. 
26. 
Defendant unlawfully withholding records requested Plaintiff pursuant u.s.c.  552. 

27. 
Plaintiff being irreparably hanned reason Defendant's unlawful withholding 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 responsive records Plaintiff's FOIA requests and demonstrate that employed search methods reasonably likely lead the discovery records responsive Plaintiff's FOIA requests; (2) order Defendant produce, date certain, any and all nonexempt records responsive Plaintiff's FOJA requests 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 requests; (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: January 13, 2013 Respectfully Submitted, 
Isl Paul Orfanedes 
D.C. Bar No. 429716 
ruDJCIAL WATCH, INC. 

425 Third Street, SW, Suite 800 
Washington, 20024 

(202) 646-5172 

Attorneys for Plaintiff



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