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Judicial Watch • DOD and CIA Answer to JW Complaint

DOD and CIA Answer to JW Complaint

DOD and CIA Answer to JW Complaint

Page 1: DOD and CIA Answer to JW Complaint

Category:

Number of Pages:4

Date Created:February 16, 2012

Date Uploaded to the Library:October 30, 2012

Tags:respectfully, sentence, allegations, Programs, paragraph, statement, Dod, Marcia, Defense, defendants, response, complaint, Pentagon, filed, plaintiff, document, FOIA, Washington, court, CIA


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Case 1:12-cv-00049-RBW Document
Filed 02/16/12 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
Plaintiff,
U.S. DEPARTMENT DEFENSE, and
CENTRAL INTELLIGENCE AGENCY,
Defendants.
Civil Action No.
1:12-cv-00049-RBW
DEFENDANTS ANSWER PLAINTIFF COMPLAINT
Defendants U.S. Department Defense DoD and Central Intelligence Agency CIA through their undersigned counsel, hereby answer plaintiff Complaint follows.
This paragraph contains plaintiff statement the jurisdictional basis for this
action, which response required.
This paragraph contains plaintiff statement the venue for this action, which response required.
Defendants lack knowledge information sufficient form belief the
truth the allegations this paragraph.
Defendants admit the allegations the first sentence this paragraph, except
deny that DoD headquartered 1600 Defense Pentagon, Washington, 20301-1600.
DoD address listed its website 1400 Defense Pentagon, Washington, 20301-1400.
The second sentence this paragraph contains conclusions law, which response
required.
Case 1:12-cv-00049-RBW Document
Filed 02/16/12 Page
Defendants admit the allegations the first sentence this paragraph. The
second sentence this paragraph contains conclusions law, which response required.
Defendants admit that plaintiff sent FOIA request DoD August 2011,
and respectfully refer the Court plaintiff August 2011 letter DoD for complete and
accurate statement plaintiff FOIA request.
Defendants admit the allegations the first sentence this paragraph.
Regarding the second sentence, defendants respectfully refer the Court DoD August 22, 2011
response letter for complete and accurate statement its contents.
This paragraph contains conclusions law, which response required.
Defendants admit that plaintiff sent FOIA request the CIA August 2011,
and respectfully refer the Court plaintiff August 2011 letter the CIA for complete and
accurate statement plaintiff FOIA request.
10.
Defendants admit the allegations the first sentence this paragraph.
Regarding the second sentence, defendants respectfully refer the Court the CIA August 16,
2011 response letter for complete and accurate statement its contents.
11.
This paragraph contains conclusions law, which response required.
12.
Defendants deny the allegations this paragraph, except admit that the
date the Complaint, defendants have neither produced records responsive plaintiff
requests nor indicated whether any such records will produced. Defendants respectfully refer
the Court DoD August 22, 2011 letter and the CIA August 16, 2011 letter for complete
and accurate statement their contents.
13.
This paragraph contains conclusions law, which response required.
Case 1:12-cv-00049-RBW Document
Filed 02/16/12 Page
14.
The answers all preceding paragraphs are incorporated herein reference.
15.
Defendants deny the allegations this paragraph.
16.
Defendants deny the allegations this paragraph.
Defendants deny any and all allegations the Complaint not expressly admitted herein. addition, defendants deny that plaintiff entitled the relief requested its Prayer for
Relief, any relief whatsoever.
WHEREFORE, defendants respectfully request that this action dismissed with
prejudice and that the Court grant defendants such other relief may appropriate.
Respectfully Submitted,
TONY WEST
Assistant Attorney General
JOHN TYLER
Assistant Director, Federal Programs Branch
/s/ Marcia Berman
MARCIA BERMAN (PA Bar No. 66168)
United States Department Justice
Civil Division, Federal Programs Branch Massachusetts Avenue N.W. Room 7132
Washington, D.C. 20530
Tel.: (202) 514-2205
Fax: (202) 616-8470
Email: marcia.berman@usdoj.gov
Attorneys for Defendants.
Case 1:12-cv-00049-RBW Document
Filed 02/16/12 Page
CERTIFICATE SERVICE hereby certify that February 16, 2012, true and correct copy the foregoing
Defendants Answer Plaintiff Complaint was served upon plaintiff counsel record the
address listed below:
Via ECF:
Paul Orfanedes
Chris Fedeli
JUDICIAL WATCH, INC.
425 Third Street,
Suite 800
Washington, 20024
(202) 646-5172
Email: porfanedes@judicialwatch.org
CFedeli@judicialwatch.org
/s/ Marcia Berman
MARCIA BERMAN