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Judicial Watch • JW v State Clinton Notes Benghazi Complaint 01511

JW v State Clinton Notes Benghazi Complaint 01511

JW v State Clinton Notes Benghazi Complaint 01511

Page 1: JW v State Clinton Notes Benghazi Complaint 01511


Number of Pages:4

Date Created:September 3, 2014

Date Uploaded to the Library:September 10, 2014

Tags:01511, Benghazi, clinton, State Department, document

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425 Third Street, S.W., Suite 800  
Washington, 20024,  
Plaintiff,  Civil Action No.  
The Executive Office  
Office the Legal Adviser, Room 5519  
2201 Street, N.W.  
Washington, 20520,  

Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. Department State compel compliance with the Freedom oflnformation 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 organization incorporated under the laws the District Columbia and headquartered 425 Third Street S.W., Suite 800, Washington, 20024. Plaintiff seeks promote transparency, integrity, and accountability government and fidelity the rule law. part its mission, Plaintiff regularly requests records from federal agencies pursuant FOIA. Plaintiff analyzes the responses and disseminates its findings and the requested records the American public 

inform them about "what their government to." Defendant U.S. Department State agency the United States Government and headquartered 2201 Street N.W., Washington, 20520. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS June 13, 2014, Plaintiff submitted FOIA request Defendant, certified 
mail, seeking access the following: 
Any and all records concerning, regarding, related notes, 
updates, reports created response the September 11, 2012 
attack the U.S. Consulate Benghazi, Libya. This request 
includes, but not limited to, notes taken then Secretary 
State Hillary Rodham Clinton employees the Office the 
Secretary State during the attack and its immediate aftermath. 
The request stated, "The timeframe for this request September 11-15, 2012." July 2014, Defendant acknowledged receipt Plaintiffs request, assigned Case Control Number F-2014-11262, and noted that "[u]nusual circumstances ... may arise that would require additional time process your request." 
Pursuant U.S.C.  552(a)(6)(A)(i), Defendant was required 
determine whether comply with the request within twenty (20) working days receipt 
and notify Plaintiff immediately its determination, the reasons therefor, and the right appeal any adverse determination. Defendant's determination was due August 
2014. the date this complaint, Defendant has failed to: (i) determine 
whether comply with the request; (ii) notify Plaintiff any such determination the 

reasons therefor; (iii) advise Plaintiff the right appeal any adverse determination; 
and/or (iv) produce the requested records otherwise demonstrate that the requested 
records are exempt from production. 
Because the 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 pursuant U.S.C.  552(a)(6)(C). 
COUNT (Violation FOIA, U.S.C.  552) 
Plaintiff realleges paragraphs through fully stated herein. 

Defendant unlawfully withholding records requested Plaintiff 

pursuant U.S.C.  552. 
12. Plaintiff being irreparably harmed reason Defendant's unlawful 
withholding records responsive Plaintiffs FOIA request, and 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 searches for any and all records responsive Plaintiffs FOIA requests and demonstrate 
that employed search methods reasonably likely lead the discovery records responsive Plaintiffs FOIA requests; (2) order Defendant produce, date certain, any and all non
exempt records responsive FOIA 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; grant Plaintiff award 
attorney's 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: September 2014 
RespectfuUy submitted, 
Isl Paul Orfanedes 
Paul Orfanedes 
D.C. BarNo. 429716 
425 Third Street, S.W., Suite 800 Washington, 20024 
Tel: (202) 646-5172 
Attorneys for Plaintff