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Judicial Watch • JW v. DOJ Clinton Foundation Complaint 02536

JW v. DOJ Clinton Foundation Complaint 02536

JW v. DOJ Clinton Foundation Complaint 02536

Page 1: JW v. DOJ Clinton Foundation Complaint 02536

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Number of Pages:3

Date Created:November 5, 2018

Date Uploaded to the Library:November 05, 2018

Tags:02536, deputy, investigation, Plaintiffs, Pennsylvania, Foundation, Attorney, responsive, clinton, defendant, filed, plaintiff, request, document, FBI, records, DOJ, FOIA, Washington


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Case 1:18-cv-02536 Document Filed 11/02/18 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
425 Third Street, S.W., Suite 800
Washington, 20024,
Plaintiff,
U.S. DEPARTMENT JUSTICE,
950 Pennsylvania Avenue, N.W.
Washington, 20530-0001,
Defendant.
Civil Action No.
COMPLAINT
Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. Department
Justice compel compliance with the Freedom Information Act, U.S.C. 552. 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
SW, 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 analyzes the
Case 1:18-cv-02536 Document Filed 11/02/18 Page
responses and disseminates its findings and the requested records the American public
inform them about what their government to.
Defendant U.S. Department Justice agency the United States
Government. Defendant has possession, custody, and control records which Plaintiff seeks
access. Defendant headquartered 950 Pennsylvania Avenue, N.W., Washington, 205300001.
STATEMENT FACTS May 2018, Plaintiff submitted FOIA request the FBI, component
Defendant, seeking the following records:
All records communication, including but not limited e-mails (whether sent received .gov non-.gov e-mail accounts), text messages, instant chats,
sent between officials the offices the FBI Director, Deputy Director and
General Counsel the one hand, and officials the offices the Attorney
General, Deputy Attorney General and Principal Associate Deputy Attorney
General the other hand, regarding the closure possible closure
investigation into the Clinton Foundation.
The time frame the request was given between January 2016 and December 31, 2016. letter dated May 14, 2018, the FBI acknowledged receiving Plaintiffs FOIA
request and assigned FOIPA Request Number 1405398-000. letter dated May 21, 2018, the FBI denied Plaintiffs request. letter dated May 29, 2018, Plaintiff submitted timely appeal the FBIs
denial Plaintiffs request. letter dated September 19, 2018, the FBI denied Plaintiffs appeal. Plaintiff
has therefore exhausted its administrative remedies with respect its May 2018 request.
10. the date this Complaint, the FBI has failed to: (i) produce the requested
records demonstrate that the requested records are lawfully exempt from production, and (ii)
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Case 1:18-cv-02536 Document Filed 11/02/18 Page
notify Plaintiff the scope any responsive records Defendant intends produce withhold
and the reasons for any withholdings.
COUNTI
(Violation ofFOIA, U.S.C. 552)
11.
Plaintiff realleges paragraphs through fully stated herein.
12.
Plaintiff being irreparably hanned Defendants violation IA, and
Plaintiff will continue irreparably harmed unless Defendant compelled comply with it.
13.
Because Defendant denied Plaintiffs FOIA request and its May 29, 2018 appeal,
Plaintiff deemed have exhausted its administrative appeal remedies. U.S.C.
552( a)(6)(A)(ii).
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant
conduct search for any and all records responsive Plaintiffs FOIA request and demonstrate
that employed search methods reasonably likely lead the discovery records responsive Plaintiffs FOIA request; (2) order Defendant produce, date certain, any and all nonexempt records responsive Plaintiffs 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 Plaintiffs 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.
Dated: November 2018
Respectfully submitted,
Isl Jason Aldrich
Jason Aldrich (D.C. Bar No. 495488)
JUDICIAL WATCH, INC.
Counsel for Plaintiff
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