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Judicial Watch • JW v USAF Complaint 8192011

JW v USAF Complaint 8192011

JW v USAF Complaint 8192011

Page 1: JW v USAF Complaint 8192011


Number of Pages:4

Date Created:August 19, 2011

Date Uploaded to the Library:February 20, 2014

Tags:8192011, Usaf, complaint

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425 'Third Street, S.W., Suite 800  
Washington,  20024,  
Plaintiff,  Civil Action No.  

Case: 11-cv-01496 
1000 Air Force Pentagon Assigned To: Roberts, Richard Washington, 20330-1000, Assign. Date 8/19/2011 Description: FOIA/Privacy Act 
Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Air Force 
("Air Force") compel compliance with the Freedom Information Act, U.S.C.  552 
("FOlA"). 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 S.C.  1391 (e). 
PARTIES Plaintiff non-profit, educational foundation organized under the laws the 
District Columbia and having its principal place business 425 Third Street, S.W., 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 agency the United States Government and headquartered 
1000 Air force Pentagon, Washington, 20030-1000. Defendant has possession, custody, and 
control records which Plaintiffseeks access. 
STATEMENT FACTS June 28, 2011, Plaintiff submitted FOIA request, certified mail, 
Defendant seeking access the following: 	Any and all records concerning mission taskings first Lady Michelle Obarna's June 21-27, 2011 trip South Africa and Botswana;' 	Any and all records concerning transportation costs for Mrs. 
Obama's June 21-27, 2011 trip South Afoca and Botswana; 	Any and all passenger manifests (DD-2131) for Mrs. Obama's June 21-27, 2011 trip South Africa and Botswana. 
According U.S. Postal Service records, Plaintiff's FOIA request was received email dated July 21> 2011, Defendant acknowledged receipt Plaintiffs June 
Pursuant U.S.C.  552(a)(6)(A)(i), Defendant's response Plaintiffs June 

Defendant July 2011. 
28, 2011 FOIA request and assigned tracking number 2011-05547-F. 
28, 2011 FOIA request was due within twenty working days July 2011, August 2011. the date this Complaint, Defendant has failed produce any records responsive Plaintiff's June 28, 2011 FOIA request demonstrate that responsive records are 
exempt from production. Nor has indicated whether when any responsive records will "The First Lady's Trip Africa," 

produced. fact, Defendant has failed respond Plaintiffs June 28, 2011 FOJA request 
any substantive manner. 
10. Because Defendant has failed comply with the time limit set forth U.S.C.  552(a)(6)(A)(i), Plaintiff deemed have exhausted any and all administrative remedies with respect its June 28, 2011 FOIA request. U.S.C.  552(a)(6)(C). 
(Violation FOIA, U.S.C.  552) 
Plaintiffreallcges paragraphs through fully stated herein. 

Defendant unlawfully withholding records requested Plaintiff pursuant U.S.C.  552. 
13. Plaintiff being irreparably harmed reason Defendant's unlawful 
withholding requested 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 responsive records Plaintiff's June 28, 2011 FOIA request and 
demonstrate that employed search methods reasonably likely lead the discovery records 
responsive Plaintiff's June 28, 2011 FOIA request; (2) order Defendant produce, date 
certain, any and all non-exempt records responsive Plaintiff's June 28, 2011 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 June 28, 
2011 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 reliefas the Court deems just and proper. 

Dated: August 19> 2011 Respectfully submitted> 

425 Third Street> S.W., Suite 800 
Washington> 20024 

(202) 646-5172 

Attorneys for Plaintiff