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Judicial Watch • JW v DOS – Hillary Ethics Compliance Complaint 00772

JW v DOS – Hillary Ethics Compliance Complaint 00772

JW v DOS – Hillary Ethics Compliance Complaint 00772

Page 1: JW v DOS – Hillary Ethics Compliance Complaint 00772


Number of Pages:4

Date Created:May 28, 2013

Date Uploaded to the Library:July 28, 2014

Tags:DOS, ClintonArchive2015, 00772, Clinton Inc, Ethics, hillary, State Department

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425 Third Street, S.W., Suite 800  
Washington,  20024, 
Plaintiff, Civil Action No. 
2201 Street, N.W. 
Washington, 20520, 
 Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Department State compel compliance with the Freedom Information Act, U.S.C.  552 (FOIA). 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 non-profit, educational foundation organized under the laws the District Columbia and having its principal place business 425 Third Street, S.W., Suite 800, Washington, 20024.  Plaintiff seeks promote integrity, transparency, and accountability government and fidelity the rule law. furtherance its public interest 
mission, Plaintiff regularly requests access the public records federal, state, and local government agencies, entities, and offices, and disseminates its findings the public. Defendant agency the United States Government and headquartered 2201 Street, N.W., Washington, 20520.  Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS May 2011, Plaintiff sent FOIA request Defendant certified mail, return receipt requested, seeking access the following: 
--Any and all SF-50s for Mrs. [Hillary Rodham] Clinton; 
  --Any and all SF-85s and/or 85Ps for Mrs. Clinton; 
  --Any and all SF-86s for Mrs. Clinton; 
  --Any and all SF-450s for Mrs. Clinton; 
  --Any and all certificates divestiture for Mrs. Clinton; 
--Any and all individual waivers issues for Mrs. Clinton pursuant U.S.C.  208 (b)(1) and C.F.R. 2640.301 any other applicable ethics statues, regulations, guidelines agreements; 
--Any and all communications and records communications  including but not limited phone logs  related Mr. Clintons speech schedule; and, 
--Any and all communications and records communications  including but not limited e-mails, fax reports, and phone logs  related former Mr. Clintons personal charitable financial relationships with foreign leaders and governments. According the United States Postal Services return receipt, Defendant received Plaintiffs FOIA request May 10, 2011. letter dated May 17, 2011, Defendant acknowledged receipt Plaintiffs request and assigned the request Case Control Number 201103401. Defendant was required determine whether comply with Plaintiffs request within days, excepting Saturdays, Sundays, and legal public holidays, pursuant U.S.C.  552(a)(6)(A).  Pursuant this same provision, Defendant also was required notify Plaintiff immediately the determination, the reasons therefor, and the right appeal any adverse determination the head the agency.  Excluding weekends and the intervening Memorial Day (May 30, 2011) holiday, Defendant was required make its determination and provide Plaintiff with the requisite notifications June 2011 the latest. the date this Complaint, Defendant has failed make determination about whether will comply with Plaintiffs request, notify Plaintiff any determination, notify Plaintiff his right appeal any adverse determination the head the agency.  Nor has Defendant produced any records responsive the request, indicated when any responsive records will produced, demonstrated that responsive records are exempt from production.      
 10. Because Defendant failed comply with the time limit set forth U.S.C.  552(a)(6)(A), Plaintiff deemed have exhausted any and all administrative remedies with respect its FOIA request, pursuant U.S.C.  552(a)(6)(C). 
(Violation FOIA, U.S.C.  552) 
 11. Plaintiff realleges paragraphs through fully stated herein. 
 12. Defendant unlawfully withholding records requested Plaintiff pursuant U.S.C.  552.   
 13. Plaintiff being irreparably harmed reason Defendants unlawful withholding requested records, and Plaintiff will continue irreparably harmed unless Defendant compelled conform its conduct the requirements the law. 
 WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant conduct search for any and all responsive records Plaintiffs FOIA request and demonstrate that employed search methods reasonably likely lead the discovery records responsive Plaintiff's FOIA request; (2) order Defendant produce, date certain, any and all non-exempt 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: May 28, 2013      Respectfully submitted, 
        /S/ Paul Orfanedes   
        D.C. Bar No. 429716 
        425 Third Street, S.W., Suite 800 
        Washington, 20024 
        (202) 646-5172 
        Attorneys for Plaintiff