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Judicial Watch • JW v State – Hillary Clinton Egypt Emails

JW v State – Hillary Clinton Egypt Emails

JW v State – Hillary Clinton Egypt Emails

Page 1: JW v State – Hillary Clinton Egypt Emails


Number of Pages:4

Date Created:March 4, 2015

Date Uploaded to the Library:March 04, 2015

Tags:Egypt, Hillary Clinton, State Department, FOIA

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425 Third Street, S.W., Suite 800
Washington, 20024,
The Executive Office
Office the Legal Adviser, Room 5519
2201 Street,
Washington, D.C. 20520,
Civil Action No.
Plaintiff Judicial Watch, Inc. brings this actions against Defendant U.S. Department
State compel compliance with the Freedom Information Act, U.S.C. 552 FOIA
grounds therefor, Plaintiff alleges follows:
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).
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,
accountability, and integrity 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 NW, Washington, D.C. 20520. Defendant
has possession, custody, and control records which Plaintiff seeks access.
STATEMENT FACTS August 27, 2014, Plaintiff submitted FOIA request Defendant,
facsimile and certified mail, seeking access the following:
Any and all records communication between Secretary State Hillary
Clinton and Nagla Mahmoud, wife ousted Egyptian president
Muhammad Morsi, from January 21, 2009 January 31, 2013; and
Any and all records communication between former State Department
Deputy Chief Staff Huma Abedin and Nagla Mahmoud from January
21, 2009 January 31, 2013. letter dated August 27, 2014, Defendant acknowledged receipt the request
and assigned the request Case Control Number F-2014-15095.
Pursuant U.S.C. 552(a)(6)(A)(i), Defendant was required determine
whether comply with the request within twenty (20) working days and notify Plaintiff
immediately its determination, the reasons therefor, and the right appeal any adverse
determination. Defendant determination was due September 26, 2014 the latest. 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; (iv) produce the
requested records otherwise demonstrate that the requested records are exempt from
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 pursuant U.S.C. 552(a)(6)(C).
(Violation FOIA, U.S.C. 552)
Plaintiff realleges paragraphs through fully stated herein.
Defendant unlawfully withholding records requested Plaintiff pursuant U.S.C. 552.
Plaintiff being irreparably harmed reason Defendant unlawful
withholding records responsive Plaintiff FOIA request, 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 FOIA request and demonstrate
that employed search methods reasonably likely lead the discovery records responsive Plaintiff FOIA request; (2) order Defendant produce, date certain, any and all nonexempt records Plaintiff 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 Plaintiff 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: February 2015
Respectfully submitted,
/s/ Michael Bekesha
Michael Bekesha (D.C. Bar No. 995749)
425 Third Street, S.W., Suite 800
Washington, 20024
(202) 646-5172
Counsel for Plaintiff