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Judicial Watch • 40814 Ireland AF travel suit

40814 Ireland AF travel suit

40814 Ireland AF travel suit

Page 1: 40814 Ireland AF travel suit


Number of Pages:4

Date Created:April 8, 2014

Date Uploaded to the Library:April 08, 2014

Tags:Defense, Plaintiffs, requests, Pentagon, responsive, defendant, filed, plaintiff, request, document, records, department, Washington, court, district, EPA, IRS, ICE, CIA

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Case 1:14-cv-00047-CKK Document Filed 01/13/14 Page 1of3 THE UNITED STATES DISTRICT COURT 
JUDICIAi. WATCH, INC., 425 Third Street. SW, Suite 800 Wahington, 20024, 
1600 Defense Pentagon 
Washington, 20301-1600, 

Defendant. Civil Action No.: 

Plaintiff Judicial Watch, Inc. brin this action against Defendant U.S. Department Defense compel compliance with the Freedomoflnfonuation Act, U.S.C.  552 ("FOIN'). grounds therefor, Plaintiff alleges follows: 

AND VENUE The Court has jurisdiction overthisactionpursuantto U.S.C.  S52(a)(4)(B) and u.s.c.  1331. Venue proper this district pursuant U.S.C.  1391(e). Plaintiff non-profit educational foundation organized under the laws the District Columbia and having its principal place business 425 Th.ird Street, Suite 800, Washington, 20024. Plaintiff seeks promote integrity, transparency, and 
accountability government and fidelity the rule Jaw. furtherance its public interest 
Case 1:14-cv-00047-CKK Document 	Filed 01/13/14 Page 
mission, Plaintiff
regularly requests access the public records federal, state, and local government agencies, entities, and offices, and disseminates its findings the public. The U.S. Department Defense agency the United States Government and headquartered 1600 Defense Pentagon, Washington, 20301-1600. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENTOlt' FACTS June 19, 2013, Plaintiffsent FOIA request the U.S. Air Force ("USAF") seeking access records concerning First Lady Michelle Obama' June 2013 trip Ireland. 
According U.S. Postal Service records, Plaintiffs June 19, 2013 request was received the USAF June 28. 2013. The USAF has never acknowledged receipt the request, however. 
Pursuant U.S.C.  SS2(a.)(6)(A)(i), the USAF was required respond Plaintiff's tequest within twenty (20) working days June 28, 2013. July 29, 2013. the dat this Complaint, the USAF 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. Because Defendant bas failed comply with the time limit set forth U.S.C.  552(a)(6)(A)(i), Plaintiffis deemed have exhausted any and all adminiatrative 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. 

Defendant unlawfully withholding records requested Plaintiff pursuant u.s.c. 	 552.
Case 1:14-cv-00047-CKK Document Filed 01/13/14 Page 
12. Plaintiffis being irreparably harmed reason Defendant's unlawful 
withholding requested records, and Plaintiff will continue iITeparabty harmed unless 
Defendant compelled conform its conduct the requirements the law. 
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant 
conduct seaxch for any and all responsive records 1>1aintiff's FOIA requests and demonstrate 
that employed search methods reasonably likely lead the discovery records responsive 
Plaintiff's FOIA requests; (2) ordi::r Defendant produce, date certain, any and all 
non-exempt records responsive Plaintiff's FOIA requests and Vaughn index any responsive 
records withheld under exemption; (3) enjoin Defendant from continuing withhold any 
and all non-exemptreoordsrespoDBive Plaintiff's F01A requests; (4) grant Plaintiffan award 
attorneys' fees and other litigation costs reasonably incurred this action pursuant U.S.C.  
SS2(a)(4)(E); and (5) grant Plaintiffsuch other relief the Court deems just end proper. 
Dated: January 13, 2014 

D.C. BarNo. 429716 JUDICJAL WATCH, INC. 
425 Third Street, SW, Suite 800 Washington, 20024 
(202) 646-5172 
Allorney.s for Plaintiff