Skip to content

Judicial Watch • Stamped Complaint

Stamped Complaint

Stamped Complaint

Page 1: Stamped Complaint

Category:General

Number of Pages:4

Date Created:June 21, 2013

Date Uploaded to the Library:February 20, 2014

Tags:SECRET, Pursuant, responsive, service, government, defendant, watch, plaintiff, Obama, request, records, judicial, states, Washington, court, united, EPA, IRS, ICE, CIA


File Scanned for Malware

Donate now to keep these documents public!

  • demand_answers

See Generated Text   ˅

Autogenerated text from PDF

THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 
 
JUDICIAL WATCH, INC., 
425 Third Street, SW, Suite 800 
Washington, D.C. 20024, 
Plaintiff, Civil Action No. 
U.S. SECRET SERVICE, 
Office the Chief Counsel 
245 Murray Lane    
Washington, 20528-0485       
Defendant. 
___________________________________ 
  
COMPLAINT 
 Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Secret Service 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 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.  Plaintiff seeks promote integrity, transparency, and accountability government and fidelity the rule law. 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 February 15, 2013, Plaintiff sent FOIA request USSS, Freedom Information Act Privacy Acts Branch Communications Center, seeking access the following records: 
 (1) Any and all records concerning, regarding related the expenditure U.S. Government funds provide security and/or other services President Obama and any companions during his February 2013 trip Palm Beach, Florida; 
 
 (2) Any and all records concerning, regarding, related the expenditure U.S. Government funds provide security and/or other services First Lady Michelle Obama and any companions during her February 2013 trip Aspen, Colorado; 
 
 (3) Any and all records concerning, regarding, related the expenditure U.S. Government funds provide security and/or other services Vice President Biden and any companions during his February 2013 trip Aspen, Colorado. letter dated March 18, 2013, USSS acknowledged receipt Plaintiffs FOIA request February 27, 2013 and assigned the request File Numbers 20130405, 20130406, and 20130406. Pursuant U.S.C.  552(a)(6)(A)(i), USSS was required determine whether comply with Plaintiffs request within twenty (20) working days after receipt the request.  Pursuant this same provision, USSS also was required notify Plaintiff immediately its 
determination, the reasons therefor, and the right appeal any adverse determination.  USSSs determination was due later than March 27, 2013. the date this Complaint, USSS 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 record otherwise demonstrate that the requested records are exempt from production. Because USSS failed comply with the time limit set forth U.S.C.  522(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) 
 10. Plaintiff realleges paragraphs through fully stated herein. 
 11. Defendant unlawfully withholding public records requested Plaintiff pursuant U.S.C.  552. 
 12. Plaintiff being irreparably harmed reason Defendants unlawful withholding the requested public 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:  June 21, 2013     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