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Judicial Watch • JW v DOJ James Baker_Perkins Coie complaint 00573

JW v DOJ James Baker_Perkins Coie complaint 00573

JW v DOJ James Baker_Perkins Coie complaint 00573

Page 1: JW v DOJ James Baker_Perkins Coie complaint 00573


Number of Pages:3

Date Created:March 1, 2019

Date Uploaded to the Library:March 04, 2019

Tags:00573, Coie, sussman, Perkins, baker, peterson, Plaintiffs, complaint, responsive, defendant, filed, plaintiff, request, document, records, FBI, James, DOJ, FOIA, Washington

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Case 1:19-cv-00573 Document Filed 03/01/19 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 oflnformation 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-00573 Document Filed 03/01/19 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 ofrecords which Plaintiff seeks access. Defendant
headquartered 950 Pennsylvania Avenue, N.W., Washington, 20530-0001.
STATEMENT FACTS October 2018, Plaintiff submitted FOIA request the Federal Bureau
Investigation, component Defendant through its online system seeking access to:
Any and all records communication between former FBI General
Counsel James Baker and former Department Justice attorney and
current Perkins Coie Partner Michael Sussman.
Any and all records created preparation for, during, and/or pursuant
any meetings between Mr. Baker and Mr. Sussman.
Any and all calendars, agendas, similar records, either paper
electronic format, documenting the schedule and activities Mr. Baker.
The time frame for this request January 2016 December 31, 2016. letter dated October 16, 2018, Defendant acknowledged receipt Plaintiffs
request and assigned the request FOIAPA Request Number 1418827-000. the date this Complaint, Defendant has failed to: (i) produce the
requested records demonstrate that the requested records are lawfully exempt from
production; (ii) notify Plaintiff the scope any responsive records Defendant intends
produce withhold and the reasons for any withholdings; (iii) inform Plaintiff that may
appeal any adequately specific, adverse determination.
(Violation FOIA, U.S.C. 552)
Plaintiff realleges paragraphs through fully stated herein.
Case 1:19-cv-00573 Document Filed 03/01/19 Page
Plaintiff being irreparably harmed Defendants violation ofFOIA, and
Plaintiff will continue irreparably harmed unless Defendant compelled comply with it.
10. 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, the latest, November 29, 2018.
Because Defendant failed make final determination Plaintiffs FOIA
request within the time limits set FOIA, 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 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 indices 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
Respectfully submitted,
Dated: March 2019
Isl James Peterson
James Peterson
D.C. Bar No. 450171
425 Third Street S.W., Suite 800
Washington, 20024
(202) 646-5172
Counsel for Plaintiff