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THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT COLUMBIA 

ruDICIAL WATCH, INC., 
425 Third Street, S.W., Suite 800  
Washington, 20024,  
Plaintiff,  Civil Action No.  
UNITED STATES DEPARTMENT HOivffiLAND SECURITY,  
Office the General Counsel  
245 Murray Lane S.W.  
Washington, 20528-0485,  

Plaintiff Judicial Watch, Inc. brings this action against Defendant United States 
Department Homeland Security (''DRS") 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.  139l(e). 
PARTIES Plaintiff Judicial Watch, Inc. not-for-profit, educational organization 
incorporated under the laws the District Co11Ullbia and headquartered 425 Third Street 
S.W., Suite 800, Washington, 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 FOlA. Plaintiffanalyzes the 
responses and dissem.lnates its findings and the requested records the American public 
inform them about "what their government to." Defendant OHS agency the United States Government and 
headquartered South 12th Street, Arlington, 22202. Defendant has possession, 
custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS July 2014, Plaintiff submitted FOIA request U.S. Immigration and 
Customs Enforcement ("ICE"), component Defendant, certified mail, seeking access 
the following: 
Any and all records the Enforcement Removal Operations 
(ERO) Field Office Juvenile Coordination Meeting Washington, 25-27 February 2014, include, but not limited to: 
schedule, participants, training materials, PowerPoint 
presentations, handouts, policies, etc. letter dated July 23, 2014, Defendant acknowledged receipt the 
request July 18, 2014 and assigned reference number 2014-ICF0-02806. Defendant 
also infonned Plaintiff that Defendant had invoked 10-day extension time process 
the request, authorized U.S.C.  SS2(a)(6)(B). Pursuant U.S.C.  552(a)(6)(A)(i), Defendant was required 
determine whether comply with the request within thirty (30) working days receipt 

and notify Plaintiff immediately its determination, the reasons therefor, and the right appeal any adverse determination. Defendant's determination was due August 29, 
2014. 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 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). 
COUNT1 
(Violation ofFOIA, U.S.C.  552) 
Plaintiffrealleges paragraphs through fully stated herein. 
Defendant unlawfully withholding records requested Plaintiff 

pursuant U.S.C.  552. 
10. Plaintiff being irreparably harmed reason Defendant's unlawful 
withholding records responsive Plaintiff's FOIA request, and will continue 
irreparably banned 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 Plaintiff's 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 FOlA 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