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Judicial Watch • JW v Secret Service STAMPED Complaint

JW v Secret Service STAMPED Complaint

JW v Secret Service STAMPED Complaint

Page 1: JW v Secret Service STAMPED Complaint


Number of Pages:4

Date Created:September 20, 2012

Date Uploaded to the Library:February 20, 2014

Tags:Murray, Pursuant, SECRET, service, government, watch, defendant, Obama, plaintiff, judicial, request, records, Washington, court, EPA, ICE, CIA

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425 Third Street, SW, Suite 800 
Washington, D.C. 20024, 
Plaintiff, Civil Action No.  
245 Murray Drive, Building 410 
Washington, 20223, 
 Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. Secret Service 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. (Plaintiff) non-profit, educational foundation organized under the laws the District Columbia and having its principal place business 425 Third Street, SW, 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 U.S. Secret Service (Secret Service) agency the U.S. Government and headquartered 245 Murray Drive, Building 410, Washington, 20223.  The Secret Service has possession, custody, and control certain public records which Plaintiff seeks access. 
STATEMENT FACTS March 29, 2012, Plaintiff submitted FOIA request the Secret Service, certified mail, seeking access the following public records: 
Any and all records regarding, concerning, related the expenditure U.S. Government funds provide security and/or any other services for Malia Obama and any companions during her March 2012 visit Mexico. According U.S. Postal Service receipt, the Secret Service received Plaintiffs request April 2012. letter dated May 18, 2012, the Secret Service acknowledged receipt the request and assigned File Number 20120618. Pursuant U.S.C.  552(a)(6)(A)(i), the Secret Service was required determine whether comply with Plaintiffs request within twenty (20) working days its receipt the request April 2012 and notify Plaintiff immediately its determination, the reasons therefor, and the right appeal any adverse determination.  Accordingly, the Secret Services determination was due May 2012 the latest. the date this Complaint, Defendant Secret Service has failed to:  (i) determine whether comply with Plaintiffs requests; (ii) notify Plaintiff any such determination the reasons therefor; (iii) advise Plaintiff the right appeal any adverse 
determination; (iv) produce the requested records otherwise demonstrate that the requested records are exempt from production. 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 requests, pursuant U.S.C. 552(a)(6)(C).  
(Violation FOIA, U.S.C.  552) 
 10. Plaintiff realleges paragraphs through fully stated herein. 
 11. Defendant unlawfully withholding public records requested Plaintiff pursuant U.S.C.  552.   
 12. Plaintiff being irreparably harmed reason Defendants unlawful withholding the requested public 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 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 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:  September 20, 2012    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