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Obama Travel DOD Lawsuit

Obama Travel DOD Lawsuit

Page 1: Obama Travel DOD Lawsuit


Number of Pages:3

Date Created:January 14, 2014

Date Uploaded to the Library:January 30, 2014

Tags:Defense, Plaintiffs, requests, responsive, Pentagon, defendant, Obama, filed, plaintiff, request, document, records, department, Washington, district, court, EPA, IRS, ICE, CIA

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Case 1:14-cv-00047-CKK Document Filed 01/13/14 Page 1of3 THE UNITED STATES DISTRICT COURT 

425 Third Street, SW, Suite 800 
Washington, 20024, Civil Action No.: 
U.S. DEPAR1MENT DEFENSE, 1600 Defense Pentagon 
Washington, 20301-1600, Defendant. 

Plaintiff Judicial Watch, Inc. brings this action against Defendant U.S. Department Defense compel compliance with the Freedom Infonnation 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.  139l(e). 
PARTIES Plaintiff nonprofit, 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 
Case 1:14-cv-00047-CKK Document Filed 01/13/14 Page 
mission, Plaintiff regularly requests access the public records federal, state, and local government agencies, entities, and offices, and disseminates its findings the public. The U.S. Department Defense agency the United States Government and headquartered 1600 Defense Pentagon, Washington, 20301-1600. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS June 19, 2013, Plaintiff sent FOIA request the Air Force ("USAF") seeking access records concerning First Lady Michelle Obama's June 2013 trip Ireland. 
According U.S. Postal Service records, Plaintiff's June 19, 2013 request was received the USAF June 28, 2013. The USAF has never acknowledged receipt the request however. 
Pursuant U.S.C.  552(a)(6)(A)(i), the USAF was required respond Plaintiffs request within twenty (20} working days June 28, 2013, July 29, 2013. the date this Complaint, the USAF has failed produce any records responsive Plaintiffs requests demonstrate that responsive records are exempt from production. Nor have they indicated whether when any responsive records will produced. 
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 requests. U.S.C.  552(a)(6)(C). 

(Violation FOIA, U.S.C.  552) 

PlaintiffreaUeges paragraphs through iffully stated herein. 

Defendant unlawfully withholding records requested Plaintiff pursuant u.s.c.  552.

Case 1:14-cv-00047-CKK Document Filed 01/13/14 Page 
12. 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 FOIA requests and demonstrate that employed search methods reasonably likely lead the discovery records responsive Plaintiff's FOIA requests; (2) order Defendant produce, date certain, any and all non-exempt records responsive Plaintiffs FOIA requests 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 requests; (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: January 13, 2014 Respectfully submitted, 
Isl Paul Orfanedes 
D.C. Bar No. 429716 JUDICIAL WATCH, INC. 425 Third Street, SW, Suite 800 Washington, 20024 
(202) 646-5172 
Allomeys for Plaintiff