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Judicial Watch • JW v. DOJ Rosenstein complaint 00481

JW v. DOJ Rosenstein complaint 00481

JW v. DOJ Rosenstein complaint 00481

Page 1: JW v. DOJ Rosenstein complaint 00481


Number of Pages:3

Date Created:March 8, 2019

Date Uploaded to the Library:March 08, 2019

Tags:00481, Rosenstein, defendants, Pennsylvania, Plaintiffs, complaint, responsive, September, defendant, filed, plaintiff, request, document, records, DOJ, FOIA, Washington

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Case 1:19-cv-00481 Document Filed 02/26/19 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-00481 Document Filed 02/26/19 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 September 21, 2018, Plaintiff submitted FOIA request Defendant, via
e-mail, seeking access the following records:
Any and all e-mails, text messages, other records communication addressed received Deputy Attorney General Rod Rosenstein between May 2017
and May 22, 2017. letter dated October 24, 2018, Defendants Office Information Policy
acknowledged receipt Plaintiffs request September 25, 2018 and provided Plaintiff with
the following designations for its request: DOJ-2018-008564 (DAG) VAV:KJK. 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 ofFOIA, U.S.C. 552
Plaintiff realleges paragraphs through fully stated herein.
Plaintiff being irreparably harmed Defendants violation IA, and
Plaintiff will continue irreparably harmed unless Defendant compelled comply with it.
Case 1:19-cv-00481 Document Filed 02/26/19 Page
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 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 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
Dated: February 26, 2019
Respectfully submitted, Chris Fedeli
Chris Fedeli Bar No. 472919