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Judicial Watch • JW v. DHS Bill Clinton Jeffrey Epstein 00915

JW v. DHS Bill Clinton Jeffrey Epstein 00915

JW v. DHS Bill Clinton Jeffrey Epstein 00915

Page 1: JW v. DHS  Bill Clinton  Jeffrey Epstein 00915

Category:Legal Document

Number of Pages:4

Date Created:June 15, 2015

Date Uploaded to the Library:June 19, 2015

Tags:Epstein, stamped, determination, Bill Clinton, complaint, security, responsive, clinton, defendant, filed, plaintiff, request, document, records, FOIA, states, Washington, court, united

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Case 1:15-cv-00915-BAH Document Filed 06/15/15 Page THE UNITED STATES DISTRICT COURT
425 Third Street SW, Suite 800
Washington, 20024,
Office the General Counsel
245 Murray Lane
Mailstop 0485
Washington, 20528,
Civil Action No.
Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. Department
Homeland Security 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.C. 552(a)(4)(B)
and U.S.C. 1331.
Venue proper this district pursuant U.S.C. 1391(e).
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, integrity, and
accountability government and fidelity the rule law. part its mission, Plaintiff
Case 1:15-cv-00915-BAH Document Filed 06/15/15 Page
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 United States Department Homeland Security agency the
United States Government and headquartered 601 South 12th Street, Arlington, 22202.
Defendant has possession, custody, and control records which Plaintiff seeks access.
STATEMENT FACTS January 2015, Plaintiff submitted FOIA request the U.S. Secret Service, component Defendant, seeking access to:
Any and all records reflecting expenses incurred provide
security and/or other services former President Bill Clinton and
any companions for trips the Caribbean island owned Jeffrey
Epstein known Little St. James from 2001 the present date.
Defendant subsequently acknowledged receiving Plaintiff request January
22, 2015 and assigned the request FOIA File Number 20150440.
Pursuant U.S.C. 552(a)(6)(A)(i), Defendant was required determine
whether comply with Plaintiff 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 determination. Defendant determination was due February 20,
2015 the latest. the date this Complaint, Defendant has failed to: (i) determine whether
comply with Plaintiff 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
Case 1:15-cv-00915-BAH Document Filed 06/15/15 Page
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 with
respect its request, pursuant U.S.C. 552(a)(6)(C).
(Violation FOIA, U.S.C. 552)
Plaintiff realleges paragraphs through fully stated herein.
Defendant violating FOIA unlawfully withholding records responsive
Plaintiff FOIA request.
Plaintiff being irreparably harmed reason Defendant violation FOIA,
and Plaintiff will continue irreparably harmed unless Defendant compelled comply
fully with FOIA.
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 the request; (2) order Defendant produce, date certain, any and all non-exempt records
responsive Plaintiff FOIA request and Vaughn index any responsive records withheld
under claim exemption; (3) enjoin Defendant from continuing withhold any and all nonexempt records responsive Plaintiff FOIA request; (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.
Case 1:15-cv-00915-BAH Document Filed 06/15/15 Page
Dated: June 15, 2015
Respectfully submitted,
/s/ Jason Aldrich
Jason Aldrich
D.C. Bar No. 495488
425 Third Street SW, Suite 800
Washington, 20024
(202) 646-5172
Counsel for Plaintiff