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Judicial Watch • USSS Filed Stamped Complaint 01732 BAH

USSS Filed Stamped Complaint 01732 BAH

USSS Filed Stamped Complaint 01732 BAH

Page 1: USSS Filed Stamped Complaint 01732 BAH


Number of Pages:4

Date Created:October 17, 2014

Date Uploaded to the Library:December 30, 2014

Tags:USSS, BAH, Fedeli, Secret Service, Denver, colorado, Obama, FOIA

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425 Third Street, SW, Suite 800 
Washington, D.C. 20024, 
Plaintiff, Civil Action No. 
245 Murray Drive, Building 410 Washington, D.C. 20223, 

Plaintiff Judicial Watch, Inc. brings this action against Defendant United States Secret Service compel compliance with the Freedom oflnformation Act, U.S.C.  552 ("FOIA"). grounds therefor, Plaintiff alleges follows: 
The Court has jurisdiction over this action pursuant U.S.C.  552 (a)(4)(B) 
Venue proper this district pursuant U.S.C.  1391(e). 

and U.S.C.  1331. 
PARTIES 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, D.C. 20024. Plaintiff seeks promote transparency, integrity, and accountability 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 United States Secret Service agency the United States 
Government and headquartered 245 Murray Lane, Building T-5, Washington, D.C. 20223. Defendant has possession, custody, and control records which Plaintiff seeks access. 
STATEMENT FACTS July 2014, Plaintiff submitted FOIA request Defendant, certified 
mail, seeking access the following public records: 
All records concerning use U.S. Government funds provide security and/or any other services President Obama and any companions their July 2014 trip Denver, Colorado. 
The time frame for this request runs from July 2014 the present. letter dated July 28, 2014, Defendant acknowledged receiving Plaintiffs 
FOIA request July 11, 2014 and assigned the request File Number 20140803. 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 and notification Plaintiff was due later than 
August 2014. the date this Complaint, Defendant has failed to: (i) determine whether 
comply with the request; (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 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 ofFOIA, U.S.C.  552 

Plaintiff realleges paragraphs through fully stated herein. 

Defendant unlawfully withholding records requested Plaintiff under FOIA. 

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: (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 nonexempt records responsive Plaintiff's 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; grant Plaintiff award attorneys' fees and other litigation costs reasonably incurred this action pursuant U.S.C.  S52(a)( 4)(E); and (5) grant Plaintiff such other relief the Court deems just and proper. 
Dated: October 16, 2014 
Respectfully submitted, Chris-Fedeli 
Chris Fedeli Bar No. 472919 

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