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Judicial Watch • JW v State Soros Columbia complaint 00668

JW v State Soros Columbia complaint 00668

JW v State Soros Columbia complaint 00668

Page 1: JW v State Soros Columbia complaint 00668

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Number of Pages:4

Date Created:March 23, 2018

Date Uploaded to the Library:March 26, 2018

Tags:00668, Bullet, Case, Dept, Columbia, society, responsive, defendant, filed, State Department, plaintiff, request, document, records, FOIA, department, Washington


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Case 1:18-cv-00668 Document Filed 03/23/18 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 STATE
The Executive Office
Office the Legal Adviser, Suite 5.600
600 19th Street
Washington, 20522,
Defendant.
____________________________________)
Civil Action No.
COMPLAINT
Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. 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 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
Case 1:18-cv-00668 Document Filed 03/23/18 Page
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 State Department agency the
United States Government headquartered 2201 Street NW, Washington, 20520. The
State Department has possession, custody, and control records which Plaintiff seeks access.
STATEMENT FACTS October 23, 2017, Plaintiff submitted FOIA request the U.S. Department State DoS State seeking the following: Any and all records regarding, concerning relating any contracts, grants other allocations/disbursements funds the State Department the Open
Society Foundation OSF and/or any OSF subsidiaries/affiliates, and/or OSF
personnel operating Columbia, well the following entities: Fundacion Ideas
para Paz; Silla Vacia; DeJusticia; Corporacion Nuevo Arco Iris; Paz
Reconciliacion; Global Drug Policy Program; and news portal Las Dos Orillas. Such
records shall include, but not limited proposals, contracts, requests for funding,
payment authorizations, invoices and similar budget records, well any and all
related communications, whether e-mails, text messages, instant chat, between
State Department officials, employees representatives and officials, employees
representatives the U.S. Agency for International Development USAID Any and all records communication, whether e-mails, text messages,
instant chats, between any officials, employees representatives the State
Department Columbia, including but not limited Ambassador Kevin Whitaker,
and any officials, employees representatives the Open Society Foundation, its
subsidiaries/affiliates, and/or those entities identified Bullet Any and all assessments, evaluations, reports similar records relating the
work OSF Columbia, its subsidiaries/affiliates and/or the other entities
identified Bullet Any and all records communication transmitted via the State Department
SMART system sent from any employee the U.S. Government operating
under the authority the Chief Mission Bogota that pertains OSF, its
subsidiaries/affiliates and/or the other entities listed Bullet
The time frame the request was identified January 2015 through the present.
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Case 1:18-cv-00668 Document Filed 03/23/18 Page letter dated November 27, 2017, State confirmed that received the request October 31, 2017 and assigned the request Tracking Number F-2017-16690. 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 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 November 30, 2017 the
latest. 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; (iii) inform
Plaintiff that may appeal any adequately specific, adverse determination; and (iv) make the
records available promptly thereafter. See, e.g., Citizens for Responsibility and Ethics
Washington Federal Election Commission, 711 F.3d 180, 188-89 (D.C. Cir. 2013).
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Case 1:18-cv-00668 Document Filed 03/23/18 Page
11.
Because Defendant failed determine whether fully 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 nonexempt records 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: March 23, 2018
Respectfully submitted, Jason Aldrich
JASON ALDRICH
D.C. Bar No. 495488
JUDICIAL WATCH, INC.
425 Third Street SW, Suite 800
Washington, 20024
(202) 646-5172
Counsel for Plaintiff
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