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Judicial Watch • JW v. DOJ James Baker comms complaint 00177

JW v. DOJ James Baker comms complaint 00177

JW v. DOJ James Baker comms complaint 00177

Page 1: JW v. DOJ James Baker comms complaint 00177


Number of Pages:3

Date Created:January 30, 2019

Date Uploaded to the Library:January 30, 2019

Tags:00177, Comms, baker, Pennsylvania, requests, Plaintiffs, complaint, responsive, defendant, filed, plaintiff, request, document, records, FBI, James, DOJ, FOIA, Washington

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Case 1:19-cv-00177 Document Filed 01/25/19 Page THE UNITED STATES DISTRICT COURT
425 Third Street, S.W., Suite 800
Washington, 20024,
950 Pennsylvania Avenue, N.W.
Washington, 20530-0001,
Civil Action No.
Plaintiff Judicial Watch, Inc. brings this action against the U.S. Department Justice
(Defendant) compel compliance with the Freedom Information Act, U.S.C. 552.
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
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 1:19-cv-00177 Document Filed 01/25/19 Page
responses and disseminates its findings and the requested records the American public
inform them about what their government to.
Defendant agency the United States Government. Defendant has
possession, custody, and control records which Plaintiff seeks access. Defendant
headquartered 950 Pennsylvania Avenue, N.W., Washington, 20530-0001.
STATEMENT FACTS January 2018, Plaintiff submitted FOIA request the Federal Bureau
Investigation (FBI), component Defendant, seeking access the following records:
Any and all records communication, including but not limited emails, text
messages and instant chats, sent between former FBI General Counsel James Baker
and any the following individuals: former British intelligence officer Christopher
Steele, principal ofOrbis Business Intelligence, Ltd.; Glenn Simpson Fusion GPS;
former Fusion contractor Nellie Ohr; and/ David Corn, reporter with
Mother Jones magazine.
The time frame the request was identified January 2016 the present. letter dated January 16, 2018, the FBI acknowledged receipt Plaintiffs
request and advised Plaintiff that the request had been assigned FOIA Request No. 1393291-000. letter dated July 25, 2018, the FBI denied Plaintiffs request, asserting had records responsive the request. August 14, 2018, Plaintiff administratively appealed the FBIs records
response the request. Plaintiff submitted its appeal certified mail. date, the FBI has failed respond Plaintiffs administrative appeal.
(Violation ofFOIA, U.S.C. 552)
Plaintiff realleges paragraphs through fully stated herein.
Plaintiff being irreparably harmed Defendants violation FOIA, and
Plaintiff will continue irreparably harmed unless Defendant compelled comply with it.
Case 1:19-cv-00177 Document Filed 01/25/19 Page
12. trigger FOIAs administrative exhaustion requirement, Defendant was
required make final determination Plaintiffs FOIA request within the time limits set
FOIA. Accordingly, Defendants determination was due September 12, 2018.
Because Defendant failed make final determination Plaintiffs FOIA
request within the time limits set IA, Plaintiff deemed have exhausted its
administrative appeal remedies.
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant
conduct searches for any and all records responsive Plaintiffs 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 requests and Vaughn indices any responsive
records withheld under claim exemption; (3) enjoin Defendant from continuing withhold
any and all non-exempt records responsive Plaintiffs FOIA requests; 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
Dated: January 25, 2019
Respectfully submitted,
Isl Paul Or[anedes
Paul Orfanedes
D.C. Bar No. 429716
Counsel for Plaintiff