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Judicial Watch • JW v CIA Mina Airport complaint 00672

JW v CIA Mina Airport complaint 00672

JW v CIA Mina Airport complaint 00672

Page 1: JW v CIA Mina Airport complaint 00672

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Number of Pages:4

Date Created:March 11, 2019

Date Uploaded to the Library:March 19, 2019

Tags:Mina, 00672, Little Rock, Airport, complaint, FOIA, CIA


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Case 1:19-cv-00672 Document Filed 03/11/19 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
425 Third Street, S.W., Suite 800
Washington, 20024,
Plaintiff,
CENTRAL INTELLIGENCE AGENCY,
Office General Counsel
Washington, 20505,
Defendant.
Civil Action No.
COMPLAINT
Plaintiff Judicial Watch, Inc. brings this action against Defendant Central Intelligence
Agency CIA 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
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
Case 1:19-cv-00672 Document Filed 03/11/19 Page
analyzes agencies responses its requests and disseminates both its findings and the requested
records the public inform them about what their government to.
Defendant CIA agency the U.S. Government and headquartered
Langley, Virginia. The CIA has possession, custody, and control records which Plaintiff
seeks access.
STATEMENT FACTS June 29, 2018, Plaintiff submitted FOIA request the CIA, via certified
mail, seeking access the following:
The CIA Inspector General report issued November 1996 relating
drug-running, money laundering and intelligence gathering operation
involving airport Mena, Arkansas letter dated August 2018, Defendant acknowledged receiving Plaintiff
FOIA request July 11, 2018 and assigned the request Reference No. F-2018-02062. This was
the last communication Plaintiff received from Defendant connection with Plaintiff FOIA
request. the date this Complaint, Defendant has failed to: (i) produce the requested
records demonstrate that the requested records are lawfully exempt from production; (ii) notify
Plaintiff the scope any responsive records Defendant intends produce withhold and the
reasons for any withholdings; (iii) inform Plaintiff that may appeal any adequately specific,
adverse determination.
COUNT
(Violation FOIA, U.S.C. 552)
Plaintiff realleges paragraphs through fully stated herein.
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Case 1:19-cv-00672 Document Filed 03/11/19 Page
Plaintiff being irreparably harmed Defendant violation FOIA, and
Plaintiff will continue irreparably harmed unless Defendant compelled comply with
FOIA.
10. trigger FOIA administrative exhaustion requirement, Defendant was
required determine whether comply with Plaintiff request within the time limits set
FOIA. Accordingly, Defendant determination was due, the latest, August 22, 2018.
this date, Defendant was obligated to: (i) gather and review the requested documents; (ii)
determine and communicate Plaintiff the scope any responsive records Defendant intended produce withhold and the reasons for any withholdings; and (iii) inform Plaintiff that may
appeal any adequately specific, adverse determination. See, e.g., Citizens for Responsibility and
Ethics Washington Federal Election Commission, 711 F.3d 180, 188-89 (D.C. Cir. 2013).
11.
Because Defendant failed determine whether comply with Plaintiff request
within the time required FOIA, Plaintiff deemed have exhausted its administrative appeal
remedies. U.S.C. 552(a)(6)(C)(i).
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant
conduct search for any and all records responsive 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 responsive 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
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Case 1:19-cv-00672 Document Filed 03/11/19 Page U.S.C. 552(a)(4)(E); and (5) grant Plaintiff such other relief the Court deems just and
proper.
Dated: March 11, 2019
Respectfully submitted,
/s/ David Rothstein
David Rothstein
D.C. Bar No. 450035
JUDICIAL WATCH, INC.
425 Third Street SW, Suite 800
Washington, 20024
Tel: (202) 646-5172
Email: drothstein@judicialwatch.org
Counsel for Plaintiff
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