In the United States District Court for the District of Columbia
Case 1:18-cv-00479 Document 1 Filed 02/28/18 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA DEMOCRACY FORWARD FOUNDATION, 1333 H St. NW Washington, DC 20005, Plaintiff, Case No. v. UNITED STATES DEPARTMENT OF STATE, 2201 C St. NW Washington, D.C. 20520, UNITED STATES DEPARTMENT OF HOMELAND SECURITY, 245 Murray Lane, S.W. Washington, D.C. 20528, and UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES, 111 Massachusetts Ave., NW MS 2260 Washington, DC 20529, Defendants. COMPLAINT FOR INJUNCTIVE RELIEF 1. Plaintiff Democracy Forward Foundation brings this action under the Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”), against Defendants, U.S. Department of State (“DOS”), U.S. Department of Homeland Security (“DHS”), and U.S. Citizenship and Immigration Services (“USCIS”), to compel Defendants to produce documents in compliance with FOIA. Case 1:18-cv-00479 Document 1 Filed 02/28/18 Page 2 of 11 JURISDICTION AND VENUE 2. This Court has jurisdiction over this action pursuant to 5 U.S.C. § 552(a)(4)(B) and 28 U.S.C. § 1331. 3. Venue is proper under 5 U.S.C. § 552(a)(4)(B) and 28 U.S.C. § 1391(e). 4. Because Defendants have failed to comply with the applicable time limit provisions in FOIA, Plaintiff is deemed to have exhausted its administrative remedies pursuant to 5 U.S.C. § 552(a)(6)(C)(i). PARTIES 5. Plaintiff Democracy Forward Foundation is a not-for-profit organization incorporated under the laws of the District of Columbia, and based in Washington, D.C.
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