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Judicial Watch • JW v Department of State (Huma Abedin documents)

JW v Department of State (Huma Abedin documents)

JW v Department of State (Huma Abedin documents)

Page 1: JW v Department of State (Huma Abedin documents)


Number of Pages:4

Date Created:September 10, 2013

Date Uploaded to the Library:September 24, 2013

Tags:control, determination, number, Pursuant, Plaintiffs, Abedin, responsive, defendant, filed, plaintiff, request, document, State, records, department, Washington, court, district, EPA, ICE, CIA

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Case 1:13-cv-01363 Document Filed 09/10/13 Page UNITED STATES DISTRICT COURT THE DISTRICT COLUMBIA
42. Third Street, S.W., Suite 800
Washington, D.C. 20024,
Plaintiff, Civil Acti No.
Office the Legal Adviser
2201 Street, N.W.
Washington, D.C. 20024,
,c,.~_zVvvvv..- as.:/V
Plaintiff Judicial Watch, Inc., and through its undersigned counsel, brings this action
against Defendant US. 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. 552(a)(4)(B) and U.S.C. 13314 Venue proper this district pursuant U.S.C. )1(e),
PARTIES Plaintiff non-profit, educational foundation organized under the laws the
District Columbia and having its principal place business Street, S.W., Suite
800, Washington, 20024. Plaintiff seeks promote integrity, transparency, and
accountability government and fidelity the rule law. furtherance its public interest
Case l:l3 cv-01363 Document Filed 09/10/13 Page Plaintiff regularly requests access the public records federal, state, and local
govemmcnt agencies, entities, and offices, and disseminates its find the public, Defendant agency the United States and headquartered 2201 Street,
N.W., Washington, 20520. Defendant has possession, custody. and control public records which Plaintiff seeks access.
ATEMENT May 21, 2013, Plaintiff sent FOIA request Defendant via certi mail
sec .ing access to: Any and all (Noti cation Personnel Action) forms
for Ms. Hiuna Abedin. Any and all contracts (including, but not limited to, personal
service contracts) between the Depamnent State and Ms.
Huma Abedin.
Any and all records regardin concerning, related the
authorization for Ms. Huma Abedin represent individual
clients and/or olherwise engage outside employment
while employed and/or engaged contractual
arrangement with the Department State.
The time frame for this request January 2010 the present. letter dated June 2013, Defendant acknowledged receiving Plaintiffs request
and assigned its request Case Control Number F~2013-08817.. Defendant was required determine whether comply with Plaintiffs request
within twenty (20) working days after its receipt the request, pursuant U.S.C
S52 )(6)(A). Pursuant this same provision. Defendant also was required notify Plaintiff
immediately the determination, the reasons therefor, and the right appeal any adverse
determination the head the agency.
Case 1:l3 cv-01363 Document Filed 09/10/13 Page the date Comp]:-tint, Defendant has failed make determination
about whether will comply with laintitt request, notify Plain any determination,
notify Plaintiff its right appeal any adverse determination the head the agency.
Moreover, Defendant has failed produce any records responsive the request. indicate when
any responsive records will produced, demonstrate that responsive records are exempt from
production. Because Defendant failed comply with the time limit set forth U.S.C. 
552(a)(6)[A)-(Bi), Plaintiff deemed have exhausted any and all administrative remedies with
OlA request, pursuant U.S.
(Violation FOIA, U.S.C. 552)
10. Plaintiff realleges paragraphs through fully stated herein.
11. Defendant unlawfully withholding records requested Plrtintil pursuant
12. Plaintiff being irreparably harmed reason Defendant unlaw withholding requested records, and Plaintiff will continue irreparably harmed unless
Defendant compelled confomi its conduct the requirements the law.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court: (1) order
Defendant conduct search for any and all responsive rccords Plaintiffs FOIA request, Case ntml Number F-2013-08812, and demonstrate that cmployed search methods reasonably
likely lead the discovery records responsive Plaintiffs FOIA reque order
Defendant produce, date cenain, any and all non-exempt records responsive Plaintiffs request, Case Control Number 20l3~08812, and Vaughn index any responsive
records withheld under claim exemp (3) Defendant from continuing withhold any
Case 1:13-cv~O1363 Document Filed 09/10/13 Page
and will non-exempt rwords responsive PIa5n -Amquest; (4i grant Pizintiffan award
atmemeys aLrI3 :her litigation costs msonably (1155 mint: pursuant [LS 
552(a)(4).(E); and {5} avast .P1ainV.i1T such other reiief the Court deems just and 3:r $;a,er3x}x i92.t1Xe
circumstances herein.
Dated: Sephambet Y6, 29,13
Respectfully subxnitxad.
Paul O:- nned
n.c. Bar No. 9716
425 sweat. %.w.,.sui:e 800
wasninmun. 20024
(292) 545-5172
(am) 646-5199, facsimile
por anedes@judiddwatolLorg Pli nfi