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Judicial Watch • JW v FBI Strzok complaint 02682

JW v FBI Strzok complaint 02682

JW v FBI Strzok complaint 02682

Page 1: JW v FBI Strzok complaint 02682

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Number of Pages:4

Date Created:December 14, 2017

Date Uploaded to the Library:December 14, 2017

Tags:02682, Strzok, supervisor, peterson, produce, requested, complaint, justice, responsive, defendant, filed, plaintiff, request, FBI, document, records, FOIA, department, Washington


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Case 1:17-cv-02682 Document Filed 12/14/17 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
425 Third Street SW, Suite 800
Washington, 20024,
Plaintiff,
U.S. DEPARTMENT JUSTICE,
950 Pennsylvania Avenue
Washington, 20530-0001,
Defendant.
____________________________________)
Civil Action No.
COMPLAINT
Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. Department
Justice 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 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 1:17-cv-02682 Document Filed 12/14/17 Page
responses and disseminates its findings and the requested records the American public
inform them about what their government to.
Defendant U.S. Department Justice agency the United States
Government. Defendant has possession, custody, and control records which Plaintiff seeks
access. Defendant headquartered U.S. Department Justice, 950 Pennsylvania Avenue
NW, Washington, 20530-0001.
STATEMENT FACTS August 17, 2017, Plaintiff submitted FOIA request the Federal Bureau
Investigation FBI component Defendant, seeking the following:
Any and all records regarding, concerning, related the
assignment FBI Supervisor Peter Strzok the special counsel
investigation led former Director Robert Mueller.
Any and all records regarding, concerning, related the
reassignment FBI Supervisor Peter Strzok from the special
counsel investigation another position within the FBI.
This request includes, but not limited to, any and all forms SF-50
and/or SF-52, well any and all related records communication
between any official, employee, representative the FBI and any
other individual entity.
The request was submitted via certified mail and online via the FBI eFOIA system. letter dated August 22, 2017, Defendant acknowledged receiving Plaintiff
request and advised Plaintiff that the request had been assigned FOIPA Request No. 1382811000. 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
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Case 1:17-cv-02682 Document Filed 12/14/17 Page
produce withhold and the reasons for any withholdings; (iii) inform Plaintiff that may
appeal any adequately specific, adverse determination.
COUNT
(Violation FOIA, U.S.C. 552)
Plaintiff realleges paragraphs through fully stated herein.
Plaintiff being irreparably harmed reason Defendant violation FOIA,
and Plaintiff will continue irreparably harmed unless Defendant compelled comply
with FOIA.
10. trigger FOIA administrative exhaustion requirement, Defendant was
required determine whether comply with Plaintiff request within twenty (20) working
days receiving the request. Accordingly, Defendant determination was due about
September 18, 2017. minimum, Defendant was required to: (i) gather and review the
requested documents; (ii) determine and communicate Plaintiff the scope any responsive
records Defendant intended produce withhold and the reasons for any withholdings; and
(iii) inform Plaintiff that may appeal any adequately specific, adverse determination. See, e.g.,
Citizens for Responsibility and Ethics Washington Federal Election Commission, 711 F.3d
180, 188-89 (D.C. Cir. 2013).
11.
Because Defendant failed determine whether comply with Plaintiff request
within the time period required FOIA, Plaintiff deemed have exhausted its administrative
appeal remedies. U.S.C. 552(a)(6)(C)(i).
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant
conduct searches for any and all records responsive Plaintiff FOIA request and demonstrate
that employed search methods reasonably likely lead the discovery records responsive Plaintiff FOIA request; (2) order Defendant produce, date certain, any and all non-3-
Case 1:17-cv-02682 Document Filed 12/14/17 Page
exempt records responsive Plaintiff 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 Plaintiff 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: December 14, 2017
Respectfully submitted,
/s/ James Peterson
James Peterson
D.C. Bar No. 450171
JUDICIAL WATCH, INC.
425 Third Street SW, Suite 800
Washington, 20024
(202) 646-5172
Counsel for Plaintiff
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