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Judicial Watch • JW v. DHS Trump travel 00480

JW v. DHS Trump travel 00480

JW v. DHS Trump travel 00480

Page 1: JW v. DHS Trump travel 00480

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Number of Pages:8

Date Created:April 10, 2019

Date Uploaded to the Library:April 10, 2019

Tags:00480, Trump, Plaintiffs, DHS, defendant, plaintiff, FOIA


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Case 1:19-cv-00480 Document Filed 02/26/19 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
WDICIAL WATCH, INC.,
425 Third Street SW, Suite 800
Washington, 20024,
Plaintiff,
U.S. DEPARTMENT
HOMELAND SECURITY,
Office the General Counsel
245 Murray Lane
Mailstop 0485
Washington, 20528,
Defendant.
Civil Action No.
COMPLAINT
Plaintiff, Judicial Watch, Inc. brings this action against Defendant U.S. Department
Homeland Security compel compliance with the Freedom oflnformation 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 Columbia and headquartered 425 Third Street
SW, Suite 800, Washington, 20024. Plaintiff seeks promote transparency, integrity, and
accountability government and fidelity the rule oflaw. part its mission, Plaintiff
regularly requests records from federal agencies pursuant FOIA. Plaintiff analyzes the
Case 1:19-cv-00480 Document Filed 02/26/19 Page
agencies responses and disseminates both its findings and the requested records the American
public inform them about what their government to.
Defendant U.S. Department Homeland Security agency the U.S.
Government and headquartered 245 Murray Lane SW, Washington, 20528. Defendant
has possession, custody, and control ofrecords which Plaintiff seeks access.
STATEMENT FACTS
The U.S. Secret Service (Secret Service) component Defendant U.S.
Department Homeland Security. pursuit its mission promoting government accountability, Judicial Watch
regularly asks the Secret Service for records VIP travel expenses.
Beginning September and continuing through November 2018, Plaintiff served
multiple FOIA requests the Secret Service for records security costs and other travelrelated expenses for the following twenty-four trips taken President Donald Trump:
Billings, Montana- September 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA File No.:
11.
Buffalo, New York-September 10, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA File No.:
111.
09/10/2018
11/13/2018
12/12/2018
20190111
09/13/2018
11/13/2018
12/12/2018
20190112
Las Vegas, Nevada-September 20, 2018
Date Request:
09/24/2018 February 26, 2019, the agency has failed acknowledge and/or respond
the request.
-2-
Case 1:19-cv-00480 Document Filed 02/26/19 Page
1v.
Bedminster, New Jersey- September 21-23, 2018
Date Request:
09/24/2018 February 26, 2019, the agency has failed acknowledge and/or respond
the request.
Columbia, Missouri September 21, 2018
Date Request:
9/24/2018 February 26, 2019, the agency has failed acknowledge and/or respond
the request.
v1.
Wheeling, West Virginia September 29, 2018
Date Request:
10/01/2018 February 26, 2019, the agency has failed acknowledge and/or respond
the request.
vu.
Tennessee October 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
vm.
Mississippi 10/02/2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
IX.
10/02/2018
11/13/2018
12/12/2018
20190116
10/03/2018
11/13/2018
12/12/2018
20190117
Minnesota- October 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
10/05/2018
11/13/2018
12/12/2018
20190118
-3-
Case 1:19-cv-00480 Document Filed 02/26/19 Page
Topeka, Kansas October 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
XI.
Iowa- October 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
XU.
10/15/2018
11/13/2018
12/12/2018
20190110
Missoula, Montana- October 18, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
xv.
10/11/2018
11/13/2018
12/12/2018
201090120
Ohio October 12, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
XIV.
10/10/2018
11/13/2018
12/12/2018
20190119
Erie, Pennsylvania October 10, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
xm.
10/9/2018
11/13/2018
12/12/2018
20190108
10/19/2018
11/13/2018
12/12/2018
20190109
Mesa, Arizona- October 19, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
10/22/2018
11/13/2018
12/12/2018
20190114
-4-
Case 1:19-cv-00480 Document Filed 02/26/19 Page
XVI.
Houston, Texas October 23, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
XVll.
Wisconsin October 24, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
xvm.
10/29/2018
11/13/2018
12/12/2018
20190123
Ft. Myers, Florida- October 31, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
xx1.
10/29/2018
11/13/2018
12/12/2018
20190105
Illinois October 27, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
xx.
10/25/2018
11/13/2018
12/12/2018
20190122
North Carolina- October 26, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
XIX.
10/23/2018
11/13/2018
12/12/2018
20190121
11/01/2018
11/13/2018
12/12/2018
20190124
Columbia, Missouri- November 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA/File No.:
11/02/2018
11/13/2018
12/12/2018
20190126
-5-
Case 1:19-cv-00480 Document Filed 02/26/19 Page
xxn.
Huntington, West Virginia- November 2018
Date Request:
11/05/2018 February 26, 2019, the agency has failed acknowledge and/or respond
the request.
xxm.
Indianapolis, Indiana November 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA File No.:
xx1v.
Montana-November 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA File No.:
xxv.
11/05/2018
11/19/2018
12/18/2018
20190158
Cape Girardeau, Missouri November 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA File No.:
xxv1.
11/05/2018
11/19/2018
12/18/2018
20190156
11/06/2018
11/20/2018
12/19/2018
20190159
Palm Beach, Florida- November 21-25, 2018
Date Request:
FOIA Request Received:
Determination Due:
FOIA File No.:
11/26/2018
12/12/2018
01/11/2019
20190209
The requests were received the Secret Service, and the Secret Services determinations were
due the dates indicated. The Secret Service has assigned the requests the FOIA/File numbers
indicated. the date this Complaint, the Secret Service has failed to: (i) determine
whether comply with each request; (ii) notify Plaintiff any such determination the
reasons therefor; (iii) advise Plaintiff the right appeal any adverse determination; (iv)
-6-
Case 1:19-cv-00480 Document Filed 02/26/19 Page
produce the requested records otherwise demonstrate that the requested records are exempt
from production.
COUNTI
(Violation ofFOIA, U.S.C. 552)
Plaintiffrealleges paragraphs through fully stated herein.
10.
Defendant violating FOIA failing search for and produce all records
responsive Plaintiffs requests demonstrate that the requested records are lawfully exempt
from production.
11.
Plaintiff being irreparably harmed Defendants violations FOIA, and
Plaintiff will continue irreparably harmed unless Defendant compelled comply with
FOIA.
12. trigger FOIAs administrative exhaustion requirement, Defendant was
required make determinations with respect Plaintiffs requests within twenty (20) working
days ofreceiving the request. Accordingly, Defendants determinations were due before
the dates indicated paragraph minimum, Defendant was required 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).
13.
Because Defendant failed make determinations with respect Plaintiffs
requests within the time period required FOIA, Plaintiff deemed have exhausted its
administrative appeal remedies. U.S.C. 552(a)(6)(C)(i).
-7-
Case 1:19-cv-00480 Document Filed 02/26/19 Page
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant
search for any and all records responsive Plaintiffs FOIA requests and demonstrate that they
employed search methods reasonably calculated uncover all records responsive the
requests; (2) order Defendant produce, date certain, any and all non-exempt records
responsive Plaintiffs FOIA requests and Vaughn index any responsive records withheld
under claim exemption; (3) enjoin Defendant from continuing withhold any and all nonexempt records responsive Plaintiffs FOIA requests; (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.
Dated: February 26, 2018
Respectfully submitted,
Isl Paul Or[anedes
Paul Orfanedes
D.C. Bar No. 429716
JUDICIAL WATCH, INC.
Counsel for Plaintiff