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Judicial Watch • Judicial Watch v Department of Justice (1:14-cv-00816)

Judicial Watch v Department of Justice (1:14-cv-00816)

Judicial Watch v Department of Justice (1:14-cv-00816)

Page 1: Judicial Watch v Department of Justice (1:14-cv-00816)


Number of Pages:4

Date Created:May 21, 2014

Date Uploaded to the Library:June 10, 2014

Tags:00816, justice, department

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425 Third Street, S.W., Suite 800  
Washington, 20024,  
Plaintiff,  Civil Action No.  
950 Permsylvania Avenue, N.W.  
Washington, 20530-0001,  

Plaintiff Judicial Watch, Inc. notfor-profit, educational foundation organized
under the laws ofthe District Columbia and having its principal place business 425 Third 
Street SW, Suite 800, Washington, D.C. 20024. part ofits educational mission, Plaintiff 
regularly requests records under FOIA shed light the operations the federal government 
and educate the public about these operations. Plaintiff then analyzes the agency records and disseminates the results its analysis, well the records themselves, the public. Defendant U.S. Department Justice agency the U.S. Government and headquartered 950 Pennsylvania Avenue, N.W., Washington, D.C. 20530-0001. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS February 2014, Plaintiff submitted FOIA request, via certified mail, 
Defendant, seeking access the following public records: 
Any and all records communications between employees the Office the Attorney General, the Criminal Division the Department Justice and/or the Department Justice's Office Public Affairs with any third parties regarding the investigation and/or prosecution fonner Virginia Govemor Robert McDonnell and his wife, Maureen McDoru1ell, related their alleged improper acceptance gifts and loans from political donor. 
According U.S. Postal Service records, Defendant received PlaintifPs n:quest February 19, 2014. 
Pursuant U.S.C.  552(a)(6)(A)(i), Defendant was required determine whether comply with Plaintiff's request within twenty (20) working days after receipt the request and notify Plaintiff immediately its determination, the reasons therefor, and the right appeal any adverse deteimination. Accordingly, Defendant's determination was due March 19, 2014 the latest. the date this Complaint, Defendant has failed to: (i) detennine whether comply with Plaintifrs 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 production. Because Defendant has failed comply with the time limit set forth U.S.C.  
SS2(a)(6)(A), Plaintiff deemed have exhausted any and all administrative remedies with 
respect its request, pursuant U.S.C.  552(a)(6)(C). 
(Violation ofFOIA, U.S.C.  552) 
Plaintiff realleges paragraphs through fully stated herein. 

Defendant withholding public records requested Plaintiff pursuant U.S.C. 

12. Plaintiff being irreparably hanned reason Defendant's unlawful 
withholding the requested public records, and Plaintiff will continue irreparably harmed 
unless Defendant compelled conform its conduct the requirements the law. 
WHEREFORE, Plaintiff respectfully requests that the Comt: (1) order Defendant 
conduct search for any and all records responsive Plaintiffs FOIA request and demonstrate 
that employed search methods reasonably likely lead the discovery records responsive 
Plaintiffs FOIA request; (2) order Defendant produce, date certain, any and all non-exempt 
records responsive Plaintiffs FOIA requesl and Vaughn index any responsive records 
withheld under claim exemption; (3) enjoin Defendant from continuing withhold any and all 
non-exempt records responsive Plaintiff's FOIA request; grant Plaintiff award 
D.C. Bar No. 495488 

425 Third Street SW, Suite 800 
Washington, 20024 

(202) 646-5172 

Attorneys/or Plaintiff