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Judicial Watch • DSCC Benghazi Filed Stamped Complaint 4

DSCC Benghazi Filed Stamped Complaint 4

DSCC Benghazi Filed Stamped Complaint 4

Page 1: DSCC Benghazi Filed Stamped Complaint 4

Category:Legal Document

Number of Pages:4

Date Created:October 15, 2014

Date Uploaded to the Library:January 26, 2015

Tags:DSCC, libya, complaint, Benghazi, FOIA

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425 Third Street, SW, Suite 800 
Washington, D.C.  20024, 
Plaintiff, Civil Action No. 
The Executive Office 
Office the Legal Adviser, Room 5519 
2201 Street, 
Washington, D.C.  20520, 
 Plaintiff Judicial Watch, Inc., through its attorneys, brings this action against Defendant U.S. Department State 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 organization incorporated under the laws the District Columbia and headquartered 425 Third Street SW, Suite 800, Washington, D.C.  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 NW, Washington, D.C.  20520.  Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS June 12, 2014, Plaintiff submitted FOIA request Defendant, certified mail, seeking access the following: 
Any and all activity logs, reports, other records produced the 
Diplomatic Security Command Center between September 10, 2012 
and September 13, 2012 regarding, concerning, related the attack the U.S. Special Mission Compound and Classified Annex Benghazi, Libya. June 19, 2014, Defendant acknowledged receipt Plaintiffs request and assigned the request Case Control Number F-2014-10167. 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.  Defendants determination was due July 18, 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; 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).  
(Violation FOIA, U.S.C.  552) 
10. Plaintiff realleges paragraphs through fully stated herein. 
 11. Defendant unlawfully withholding records requested Plaintiff under FOIA. 
 12. Plaintiff being irreparably harmed reason Defendants unlawful withholding records responsive Plaintiffs 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 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; (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:  October 16, 2014     Respectfully submitted, 
        /S/ Ramona Cotca   
        Ramona Cotca 
        D.C. Bar No. 501159 
        425 Third Street, S.W., Suite 800 
        Washington, 20024 
        (202) 646-5172 
        Attorneys for Plaintiff