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Judicial Watch • JW v. Justice Dept. DOJ Ohr complaint 00507

JW v. Justice Dept. DOJ Ohr complaint 00507

JW v. Justice Dept. DOJ Ohr complaint 00507

Page 1: JW v. Justice Dept. DOJ Ohr complaint 00507

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Number of Pages:4

Date Created:March 4, 2019

Date Uploaded to the Library:March 04, 2019

Tags:00507, Ohr, justice, DOJ, FOIA


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Case 1:19-cv-00507 Document Filed 02/27/19 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
JUDICIAL WATCH, INC.,
425 Third Street, S.W., Suite 800
Washington, 20024,
Plaintiff,
U.S. DEPARTMENT JUSTICE,
950 Pennsylvania Avenue, N.W.
Washington, 20530-0001,
Defendant.
Civil Action No.
COMPLAINT
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:
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 1:19-cv-00507 Document Filed 02/27/19 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 18, 2018, Plaintiff submitted FOIA request Defendant, via
e-mail, seeking access the following records:
Any and all records regarding, concerning, related the proposed
declassification certain Department Justice records ordered
President Trump September 17, 2018. This request includes, but not
limited to, any and all related records communication sent addressed any official, employee, representative the Department Justice.
Any and all e-mails other records communication sent addressed DOJ official Bruce Ohr between September 16, 2018 and September 18,
2018. letter dated November 2018, Office oflnformation Policy acknowledged
receipt Plaintiffs request October 10, 2018. With respect part Plaintiffs request,
OIP responded behalf the Office the Attorney General and the Office the Deputy
Attorney General. With respect the Office the Attorney General, OIP assigned the request
FOIA Request Number DOJ-2019-000154. With respect the Office the Deputy Attorney
General, OIP assigned the request FOIA Request Number DOJ-2019-000595. the same letter, OIP also informed Plaintiff that had routed part the
request the Criminal Division, the National Security Division, and the Office Legal
Counsel. letter dated November 2018, the Criminal Division acknowledged receipt
Plaintiffs request October 10, 2018 and assigned Request Number CRM-300684095.
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Case 1:19-cv-00507 Document Filed 02/27/19 Page
Neither the National Security Division nor the Office Legal Counsel has
acknowledged receipt Plaintiffs FOIA request.
10. 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.
COUNT!
(Violation ofFOIA, U.S.C. 552)
11.
Plaintiff realleges paragraphs through fully stated herein.
12.
Plaintiff being irreparably harmed Defendants violation IA, and
Plaintiff will continue irreparably harmed unless Defendant compelled comply with it.
13. 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 15, 2018.
14.
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
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Case 1:19-cv-00507 Document Filed 02/27/19 Page
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: February 27, 2019
Respectfully submitted,
Isl Jason Aldrich
JASON ALDRICH
D.C. Bar No. 495488
JUDICIAL WATCH, INC.
Counsel for Plaintiff
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