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Judicial Watch • JW v State 00003 US Qatar Bergdahl

JW v State 00003 US Qatar Bergdahl

JW v State 00003 US Qatar Bergdahl

Page 1: JW v State 00003 US Qatar Bergdahl


Number of Pages:4

Date Created:January 2, 2015

Date Uploaded to the Library:January 27, 2015

Tags:00003, Qatar, Bergdahl

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425 Third Street, S.W., Suite 800 
Washington. 20024, 
Plaintiff, Civil Action No. 
The Executive Office 
Office the Legal Adviser, Room 5519 
2201 Street, Washington, D.C. 20520, 
and U.S.C.  1331. 
Plaintiff Judicial Watch, Inc. not-for-profit, educational organization 

incorporated under the laws the District Columbia and headquartered 425 Third Street 
S.W., Suite 800, Washington, 20024. Plaintiff seeks promote tn1sparency, 
accountability, and integrity government and fidelity the rule law. part its mission, 

Plaintiff regularly requests records from federal agencies pursuant FOIA. Plaintiff analyzes 
the responses and disseminates its findings and the requested records the American public 
inform them about ''what their government to." Defendant U.S. Department State agency the United States 
Government and headquartered 2201 Street NW, Washington, D.C. 20520. Defendant 
has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS June 2014, Plaintiff submitted FOIA request Defendant, facsimile 
and certified mail, seeking access the following: 
The bilateral memorandum understanding between the United States and 
Qatar relating the release from U.S. custody five detainees held the U.S. 
Naval Station Guantanamo Bay, Cuba exchange for the return U.S. 
Anny Sgt. Bowe Bergdahl. letter dated June 2014, Defendant acknowledged receipt the request and 
assigned the request Case Control Number F-2014-0950. Pursuant U.S.C.  552(a)(6)(A)(i), Defendant was required determine 
whether comply with the request within twenty (20) working days and notify Plaintiff 
immediately its determination, the reasons therefor, and the right appeal any adverse 
determination. Defendant's determination was due July 2014 the latest. the date this complaint, Defendant has failed to: (i) determine whether 
comply with the request; (ii) notify Plaintiff any such detennination 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 has failed comply with the time limit set forth U.S.C.  
552(a)(6)(A), Plaintiff deemed have exhausted any and all administrative remedies pursuant U.S.C.  552(a)(6)(C). 
(Violation FOIA, U.S.C.  552) 
Plaintiff rea1leges paragraphs through fully stated herein. 

Defendant unlawfully withholding records requested Plaintiff pursuant 

u.s.c.  552. 
12. Plaintiff being irreparably harmed reason Defendant's unlawful 
withholding records responsive Plaintiff's FOIA request, and Plaintiff will continue 
irreparably harmed unless Defendant compelled conform its conduct the requirements 
the law. 
WHEREFORE, Plaintiff respectfully requests that the Court: 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 Plaintiff's 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's 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. 

Dted; January 2015 
Respectfully submitted, 

425 Third Street, S.W., Suite 800 
Washington, 20024 
Tel: (202) 646-5172 

Counselfor Plaintf/f