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Judicial Watch • JW v DOJ FISA application complaint 00245

JW v DOJ FISA application complaint 00245

JW v DOJ FISA application complaint 00245

Page 1: JW v DOJ FISA application complaint 00245


Number of Pages:3

Date Created:February 2, 2018

Date Uploaded to the Library:February 02, 2018

Tags:orders, 00245, Copies, FISA, application, peterson, Trump, complaint, responsive, justice, defendant, filed, plaintiff, request, document, records, FBI, DOJ, department, FOIA, Washington

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Case 1:18-cv-00245 Document Filed 02/02/18 Page THE UNITED STATES DISTRICT COURT
425 Third Street SW, Suite 800
Washington, 20024,
950 Pennsylvania Avenue
Washington, 20530-0001,
Civil Action No.
Plaintiff Judicial Watch, Inc. Plaintiff brings this action against Defendant U.S.
Department Justice Defendant 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. Plaintiff 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
Case 1:18-cv-00245 Document Filed 02/02/18 Page
the responses receives and disseminates its findings and any responsive records the
American public inform them about what their government to.
Defendant U.S. Department Justice Defendant DOJ agency the
United States Government and headquartered 950 Pennsylvania Avenue NW, Washington, 20530-0001. information and belief, Defendant has possession, custody, and control
records which Plaintiff seeks access.
STATEMENT FACTS July 19, 2017, Plaintiff submitted FOIA request the Federal Bureau
Investigation FBI component Defendant, seeking the following records for the
timeframe specified:
Copies all proposed and all final signed FISA
applications submitted the FISC relating Russian interference
the 2016 election, allegations collusion between people associated
with the Trump campaign and Russia, and any known Trump
associates regardless context;
Copies all FISC responses the above-mentioned
applications which the Court notified the FBI Justice
Department that would not grant the proposed applications
recommended changes. any such FISC responses were provided
orally, rather than writing, please provide copies FBI Justice
Department records memorializing otherwise referencing the
relevant FISC responses;
Copies all FISC orders relating the abovementioned applications, whether denying the applications and
certifications, denying the orders, modifying the orders, granting the
orders, other types orders.
The FBI denied Plaintiff request letter dated August 2017.
Subsequently, the FBI denied Plaintiff appeal the denial letter dated December 14, 2017
(Appeal No. DOJ-AP-2018-000876; Request No. 1380709-000).
Case 1:18-cv-00245 Document Filed 02/02/18 Page
(Violation FOIA, U.S.C. 552)
Plaintiff realleges paragraphs through fully stated herein.
Defendant has violated FOIA refusing produce any and all non-exempt
records responsive the request.
Plaintiff being irreparably harmed Defendant violation FOIA, and
Plaintiff will continue irreparably harmed unless Defendant compelled comply with
Plaintiff has adequate remedy law.
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant
conduct searches for any and all records responsive Plaintiff 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
Plaintiff request and Vaughn index any responsive records withheld under claim
exemption; (3) enjoin Defendant from continuing withhold any and all non-exempt records
responsive the 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: February 2018
Respectfully submitted,
/s/ James Peterson
James Peterson
D.C. Bar No. 450171
425 Third Street SW, Suite 800
Washington, 20024
Phone: (202) 646-5172
Counsel for Plaintiff