Case 1:10-cv-00755-RLW Document 1 Filed 05/11/10 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ELECTRONIC FRONTIER FOUNDATION 1818 N Street, N.W. Suite 410 Washington, DC 20036,
Plaintiff,
v.
DEPARTMENT OF JUSTICE 950 Pennsylvania Avenue, N.W. Washington DC 20530,
Defendant.

) ) ) ) ) ) ) ) C. A. No. _____________ ) ) ) ) ) ) )

COMPLAINT FOR INJUNCTIVE RELIEF

1. This is an action under the Freedom of Information Act (“FOIA”), 5 U.S.C. §

552. Plaintiff Electronic Frontier Foundation seeks injunctive and other appropriate relief

for the processing and release of agency records requested by plaintiff from defendant

Department of Justice’s component, the Federal Bureau of Investigation. Specifically,

plaintiff seeks disclosure of records concerning three provisions of the Foreign

Intelligence Surveillance Act (“FISA”) that initially were scheduled to expire on

December 31, 2009, and which Congress has reauthorized until February 28, 2011.

Jurisdiction and Venue

2. This Court has both subject matter jurisdiction over this action and personal

jurisdiction over the parties pursuant to 5 U.S.C. § 552(a)(4)(B). This Court also has

jurisdiction over this action pursuant to 28 U.S.C. § 1331. Venue lies in this district

under 5 U.S.C. § 552(a)(4)(B).

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Parties 3. Plaintiff Electronic Frontier Foundation (“EFF”) is a not-for-profit corporation established under the laws of the State of California, with offices in San Francisco, California and Washington, DC. EFF is a donor-supported membership organization that works to inform policymakers and the general public about civil liberties issues related to technology, and to act as a defender of those liberties. In support of its mission, EFF uses the FOIA to obtain and disseminate information concerning the activities of federal agencies. 4. Defendant Department of Justice (“DOJ”) is a Department of the Executive Branch of the United States Government. DOJ’s components include the Federal Bureau of Investigation (“FBI”). DOJ is an “agency” within the meaning of 5 U.S.C. § 552(f).
The Expiring Provisions of FISA and Congress’ Pending Consideration of Their Reauthorization
5. In a letter to Senate Judiciary Committee Chairman Patrick J. Leahy dated September 14, 2009, Assistant Attorney General Ronald Weich conveyed defendant DOJ’s “recommendations on the three provisions of the Foreign Intelligence Surveillance Act (‘FISA’) currently scheduled to expire on December 31, 2009.” Mr. Weich indicated that the Department sought the reauthorization of the three provisions, specifically: Roving Wiretaps (USA PATRIOT Act Section 206); “Business Records” (USA PATRIOT Act Section 215); and “Lone Wolf” (Intelligence Reform and Terrorism Prevention Act of 2004 Section 6001) (hereinafter, “the three provisions”).
6. The reauthorization of the three provisions was the subject of substantial public debate through the Fall of 2009 and Winter of 2010, reflected by substantial media coverage and multiple hearings held by the relevant Congressional committees to debate
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the effectiveness and potential abuse of the three provisions, and to weigh possible civil reforms to those provisions and other provisions of the USA PATRIOT Act to better provide oversight and protect civil liberties. See, e.g., Charlie Savage, Battle Looms Over the Patriot Act, N.Y. TIMES, Sept. 19, 2009, available at http://www.nytimes.com/ 2009/09/20/us/politics/20patriot.html (describing controversy over the USA PATRIOT Act and previewing the House and Senate committee hearings on the matter). Numerous bills reflecting a variety of positions on the three provisions were introduced in both the House and Senate. Compare, e.g., The Judicious Use of Surveillance Tools in Counterterrorism Efforts (“JUSTICE” Act), S. 1686, introduced Sept. 17, 2009 (renewing PATRIOT Sections 206 and 215 but not IRTPA Section 6001, and adding substantial new procedural protections against abuse of the reauthorized sections) and The USA PATRIOT Reauthorization Act of 2009, S. 2336, introduced Oct. 29, 2009 (renewing all three provisions until 2013 without substantial modification).
7. In late 2009, both the House and Senate Judiciary Committees recommended bills (H.R. 3845 and S. 1692) that would reauthorize the three provisions subject to various reforms, but not in time for the House and Senate leadership to be able to negotiate the differences between the bills and reauthorize the three provisions prior to the December 31st deadline. Congress therefore passed a temporary extension reauthorizing the three provisions without any modifications for an additional three months, until Feb. 28, 2010, See Pub.L. 111-118, Div. B, § 1004(a), Dec. 19, 2009, 123 Stat. 3470. When it became clear that the debate over health care and other pressing issues would prevent the House and Senate from agreeing on what PATRIOT reforms should be included in a final reauthorization bill before that new deadline, the three
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provisions were reauthorized for an additional year, until Feb. 28, 2011. See Pub.L. 111141, §1(a), Feb. 27, 2010, 124 Stat. 27. Therefore, the debate over reauthorization and reform of the three provisions is not yet over but rather will soon be coming up again in Congress, and this suit seeks disclosure of records related to the three provisions that may help inform that debate.
Plaintiff’s FOIA Request and the FBI’s Failure to Timely Respond 8. By letter sent by facsimile to the FBI on September 25, 2009, plaintiff requested under the FOIA the following FBI records created since January 20, 2009: 1) all records (including but not limited to FBI communications with other Justice Department components) discussing or reflecting the Bureau’s assessment of the effectiveness of the three provisions; and 2) all records discussing or reflecting any instances in which the use of the authorities granted in the three provisions were deemed to be possibly unlawful or contrary to Executive order or Presidential directive, including but not limited to matters that were considered for referral to the Intelligence Oversight Board. 9. In its letter to the FBI referenced in ¶ 8, plaintiff requested “expedited processing” of its FOIA request pursuant to 28 C.F.R. § 16.5(d)(1)(ii) on the ground that the request “pertains to information about which there is ‘(a)n urgency to inform the public about an actual or alleged federal government activity,’ and it is ‘made by a person primarily engaged in disseminating information.’” 10. On information and belief, the FBI received plaintiff’s letter described in ¶ 8 on September 25, 2009. 11. By two letters to plaintiff dated October 21, 2009, the FBI acknowledged receipt of plaintiff’s FOIA request and informed plaintiff that its “request for expedition has been approved.”
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12. By letter to plaintiff dated January 19, 2010, the FBI stated, inter alia, that “[t]he purpose of this letter is to advise you of the status of your pending [FOIA] request . . . .” The letter further stated that “the FBI is searching for, retrieving, scanning, and evaluating files that may be responsive to your request,” and that “[o]nce your files have been evaluated as potentially responsive, your request will be forwarded to the ‘perfected backlog,’ where your request will wait for assignment to an analyst.”
13. By letter to plaintiff dated April 22, 2010, the FBI provided to plaintiff what appears to be a form “status” report on plaintiff’s pending FOIA request which is identical in its content to the FBI’s letter dated January 19, 2010, which is described in ¶ 12.
14. To date, the FBI has not disclosed agency records responsive to plaintiff’s FOIA request.
15. Notwithstanding its representation that it “approved” plaintiff’s request for “expedited processing” more than six months ago, the FBI has violated the applicable 20 working day statutory time limit for the processing of routine, non-expedited FOIA requests.
16. Plaintiff has exhausted the applicable administrative remedies. 17. Defendant DOJ and its component the FBI have wrongfully withheld the requested records from plaintiff.
CAUSE OF ACTION Violation of the Freedom of Information Act for
Wrongful Withholding of Agency Records 18. Plaintiff repeats and realleges paragraphs 1-17.
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19. Defendant DOJ and its component the FBI have wrongfully withheld agency records requested by plaintiff by failing to comply with the statutory time limit for the processing of FOIA requests.
20. Plaintiff has exhausted the applicable administrative remedies with respect to the wrongful withholding of the requested records by defendant DOJ and its component the FBI.
21. Plaintiff is entitled to injunctive relief with respect to the release and disclosure of the requested records.
Requested Relief WHEREFORE, plaintiff prays that this Court:
A. order defendant DOJ and its component the FBI to process immediately the requested records in their entirety; B. order defendant DOJ and its component the FBI, upon completion of such processing, to disclose the requested records in their entirety and make copies available to plaintiff; C. provide for expeditious proceedings in this action; D. award plaintiff its costs and reasonable attorneys fees incurred in this action; and E. grant such other relief as the Court may deem just and proper.
Respectfully submitted,
/s/ David L. Sobel DAVID L. SOBEL D.C. Bar No. 360418
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Case 1:10-cv-00755-RLW Document 1 Filed 05/11/10 Page 7 of 7 Electronic Frontier Foundation 1818 N Street, N.W. Suite 410 Washington, DC 20036 (202) 797-9009 MARCIA HOFMANN D.C. Bar No. 484136 Electronic Frontier Foundation 454 Shotwell Street San Francisco, CA 94110 (415) 436-9333 Counsel for Plaintiff
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 Case 1:10-cv-00755-RLW Document 24 Filed 06/16/11 Page 1 of 4

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ELECTRONIC FRONTIER FOUNDATION )

)

Plaintiff,

)

)

v.

)

)

DEPARTMENT OF JUSTICE

)

)

Defendant.

)

Civil Action No. 1:10-cv-00755 (RLW)

SETTLEMENT AGREEMENT AND RELEASE The Electronic Frontier Foundation and the Department of Justice, through their undersigned counsel, enter into this Settlement Agreement and Release for the sole purpose of satisfying Plaintiff’s attorney’s fees, expenses, and costs generated in connection with the abovereferenced litigation. The parties agree as follows: 1. Defendant will pay to Plaintiff the amount of $4,000.00 to cover attorney’s fees, expenses, and costs of all counsel in the above-captioned matter. This payment is full and final payment for all attorney’s fees, expenses, and costs. This figure is inclusive of any interest. 2. Contingent upon receipt of payment pursuant to Paragraph 1 above, Plaintiff hereby releases Defendant and its successors, the United States of America, and any department, agency, or establishment of the United States, and any officers, employees, agents, successors, or assigns of such department, agency, or establishment, from any and all past, present, or future claims for attorney’s fees, expenses, or costs in connection with the above-captioned litigation.

Case 1:10-cv-00755-RLW Document 24 Filed 06/16/11 Page 2 of 4

3. In consideration of such payment, Plaintiff hereby releases and forever discharges

Defendant, and its successors, the United States of America, and any department, agency, or

establishment of the United States, and any officers, employees, agents, successors, or assigns of

such department, agency, or establishment, from any and all claims and causes of action that

Plaintiff asserts or could have asserted in this litigation, or which hereinafter could be asserted by

reason of, or with respect to, or in connection with, or which arise out of, the Freedom of

Information Act request on which this action is based or any other matter alleged in the

Complaint.

4. In making this payment, no party is making an admission of liability or fault to any other party, and this Agreement shall not be construed as an admission of liability or fault. This Settlement Agreement and Release will not be used in any manner to establish liability for fees, amounts, or hourly rates, in any other case or proceeding.

5. Concurrent with the execution of this Settlement Agreement and Release, Plaintiff’s

counsel shall seek the dismissal of this case with prejudice pursuant to Fed. R. Civ. P.

41(a)(1)(A)(ii) by filing a Stipulation of Dismissal With Prejudice.

6.

The below-signed counsel are authorized to enter into this Agreement on behalf of

their respective clients.

7. This Settlement Agreement may be executed in counterparts, and is effective on

the date by which both parties have executed the Agreement.

// //

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// // //

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Dated: June 14, 2011

/s/ David L. Sobel

.

David L. Sobel

D.C. Bar No. 360418

Electronic Frontier Foundation

1818 N Street, N.W., Suite 410

Washington, DC 20036

(202) 797-9009

Attorney for Plaintiff

Respectfully submitted,
TONY WEST Assistant Attorney General
JOHN R. TYLER Assistant Director, Federal Programs Branch
_/s/Thomas D. Zimpleman THOMAS D. ZIMPLEMAN IL Bar No. 6298040 Trial Attorney United States Department of Justice Civil Division, Federal Programs Branch P.O. Box 883 Washington, D.C. 20044 Tel: (202) 514-3346
Attorneys for Defendant

 
 Case: 1:10-cv-755 As of: 06/24/2015 07:38 PM EDT 1 of 4
CLOSED,TYPE−I
U.S. District Court District of Columbia (Washington, DC) CIVIL DOCKET FOR CASE #: 1:10−cv−00755−RLW

ELECTRONIC FRONTIER FOUNDATION v. DEPARTMENT OF JUSTICE Assigned to: Judge Robert L. Wilkins Cause: 05:552 Freedom of Information Act
Plaintiff ELECTRONIC FRONTIER FOUNDATION

Date Filed: 05/11/2010 Date Terminated: 06/17/2011 Jury Demand: None Nature of Suit: 895 Freedom of Information Act Jurisdiction: U.S. Government Defendant
represented by David L. Sobel LAW OFFICE OF ERIK B. RYBERG PO BOX 541 Etna, CA 96027 (202) 246−6180 Fax: (415) 436−9993 Email: sobel@att.net ATTORNEY TO BE NOTICED

V. Defendant DEPARTMENT OF JUSTICE

represented by Kyle Renee Freeny U.S. DEPARTMENT OF JUSTICE Federal Programs Branch 20 Massachusetts Avenue, NW Washington, DC 20530 (202) 514−5108 Fax: (202) 616−8470 Email: kyle.freeny@usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Thomas David Zimpleman U.S. DEPARTMENT OF JUSTICE P.O. Box 883 Washington, DC 20044 (202) 514−3346 Fax: (202) 616−8470 Email: thomas.d.zimpleman@usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Marina Utgoff Braswell U.S. ATTORNEY'S OFFICE Civil Division Room E4822 555 Fourth Street, NW Washington, DC 20530 (202) 252−2561 Fax: (202) 252−2599 Email: Marina.Braswell@usdoj.gov TERMINATED: 06/09/2010

Date Filed 05/11/2010

# Docket Text
1 COMPLAINT against DEPARTMENT OF JUSTICE ( Filing fee $ 350, receipt number 4616029607) filed by ELECTRONIC FRONTIER FOUNDATION.

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05/11/2010 05/11/2010 05/14/2010 05/19/2010 05/20/2010 06/09/2010 06/10/2010 06/10/2010 06/14/2010
06/28/2010 06/30/2010
11/30/2010 12/02/2010
12/02/2010
01/20/2011

(Attachments: # 1 Civil Cover Sheet)(td, ) (Entered: 05/12/2010)
SUMMONS (3) Issued as to DEPARTMENT OF JUSTICE, U.S. Attorney and U.S. Attorney General (td, ) (Entered: 05/12/2010)
2 LCvR 7.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by ELECTRONIC FRONTIER FOUNDATION identifying Corporate Parent NONE for ELECTRONIC FRONTIER FOUNDATION. (td, ) (Entered: 05/12/2010)
3 Case randomly reassigned to Judge Colleen Kollar−Kotelly. Judge Paul L. Friedman no longer assigned to the case. (gt, ) (Entered: 05/14/2010)
4 ORDER Establishing Procedures for Electronic Filing for Cases Assigned to Judge Colleen Kollar−Kotelly, signed on May 19, 2010. (SM) (Entered: 05/19/2010)
5 NOTICE of Appearance by Marina Utgoff Braswell on behalf of DEPARTMENT OF JUSTICE (Braswell, Marina) (Entered: 05/20/2010)
6 NOTICE OF WITHDRAWAL OF APPEARANCE as to DEPARTMENT OF JUSTICE. Attorney Marina Utgoff Braswell terminated. (Braswell, Marina) (Entered: 06/09/2010)
7 NOTICE of Appearance by Kyle Renee Freeny on behalf of DEPARTMENT OF JUSTICE (Freeny, Kyle) (Entered: 06/10/2010)
8 ANSWER to 1 Complaint by DEPARTMENT OF JUSTICE.(Freeny, Kyle) (Entered: 06/10/2010)
9 ORDER. The parties shall confer and propose a schedule for proceeding in this matter. The schedule should address the status of Plaintiff's FOIA request, the anticipated number of documents responsive to Plaintiff's FOIA request, the anticipated date(s) for release of the documents requested by Plaintiff, whether a motion for an Open America stay is likely in this case, whether a Vaughn index will be required in this case, etc. The parties shall file the schedule not later than June 28, 2010. Signed by Judge Colleen Kollar−Kotelly on June 14, 2010. (lcckk1) (Entered: 06/14/2010)
10 STATUS REPORT (Joint) by DEPARTMENT OF JUSTICE. (Freeny, Kyle) (Entered: 06/28/2010)
MINUTE ORDER (paperless). The parties have filed a 10 Joint Status Report and Schedule indicating that Defendant will complete processing of Plaintiffs FOIA request on or before November 15, 2010. Following the completion of processing, the parties shall confer in an effort to narrow any disputed issues and submit a further Joint Status Report with a proposed schedule for proceeding by no later than November 30, 2010. Signed by Judge Colleen Kollar−Kotelly on June 30, 2010.(lcckk1) (Entered: 06/30/2010)
11 STATUS REPORT and Proposed Schedule (Joint) by DEPARTMENT OF JUSTICE. (Freeny, Kyle) (Entered: 11/30/2010)
12 ORDER: Pursuant to the Joint Status Report and Proposed Schedule filed by the parties on November 30, 2010, the Court approves the proposed schedule which is adopted and incorporated in the attached Scheduling Order. Accordingly, Defendant's motion for summary judgment shall be due on or before February 28, 2011; Plaintiff's opposition and cross−motion for summary judgment shall be due on or before March 30, 2011; Defendant's reply and opposition brief shall be due on or before April 19, 2011; and Plaintiff's reply brief shall be due on or before May 9, 2010. Signed by Judge Colleen Kollar−Kotelly on December 2, 2010. (SM, ) (Entered: 12/02/2010)
Set/Reset Deadlines: Plaintiff's Cross Motions due by 3/30/2011. Response to Cross Motions due by 4/19/2011. Reply to Cross Motions due by 5/9/2011. Defendant's Summary Judgment motions due by 2/28/2011. Response to Motion for Summary Judgment due by 3/30/2011. Reply to Motion for Summary Judgment due by 4/19/2011. (dot ) (Entered: 12/18/2010)
Case reassigned to U.S. District Judge Robert L. Wilkins. Judge Colleen Kollar−Kotelly no longer assigned to the case. (ds) (Entered: 01/20/2011)

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02/18/2011 02/23/2011
03/04/2011
04/05/2011 04/05/2011 04/22/2011 04/22/2011 05/11/2011 05/11/2011 05/12/2011 06/07/2011 06/08/2011

13 Unopposed MOTION for Extension of Time to File Summary Judgment Motion by DEPARTMENT OF JUSTICE (Attachments: # 1 Text of Proposed Order)(Freeny, Kyle) (Entered: 02/18/2011)
MINUTE ORDER granting 13 Unopposed Motion for Extension of Time. Accordingly, the deadlines set in the briefing schedule on December 2, 2010, have been extended as follows: Defendant shall have until March 4, 2011, to file its Motion for Summary Judgment; Plaintiff shall have until April 5, 2011, to file its Opposition to Defendant's Motion for Summary Judgment and Cross Motion for Summary Judgment; Defendant shall have until April 25, 2011, to file its Reply in support of its Motion for Summary Judgment and Opposition to Plaintiff's Cross Motion for Summary Judgment; and Plaintiff shall have until May 13, 2011, to file its Reply in support of its Cross Motion for Summary Judgment. Set/Reset Deadlines: Motion for Summary Judgment due by 3/4/2011; Response to Motion for Summary Judgment due by 4/5/2011; Reply to Motion for Summary Judgment due by 4/25/2011. Cross Motion for Summary Judgment due by 4/5/2011; Response to Cross Motion due by 4/25/2011; Reply to Cross Motion due by 5/13/2011. Signed by Judge Colleen Kollar−Kotelly on February 23, 2011, on behalf of newly appointed Judge Wilkins. (SM) (Entered: 02/23/2011)
14 MOTION for Summary Judgment by DEPARTMENT OF JUSTICE (Attachments: # 1 Statement of Facts, # 2 Affidavit Declaration of David M. Hardy, # 3 Exhibit Exhibits to Declaration (Pt. 1), # 4 Exhibit Exhibits to Declaration (Pt. 2), # 5 Exhibit Exhibits to Declaration (Pt. 3), # 6 Errata Exhibits to Declaration (Pt. 4), # 7 Exhibit Exhibits to Declaration (Pt. 5), # 8 Exhibit Exhibits to Declaration (Pt. 6), # 9 Exhibit Exhibits to Declaration (Pt. 7), # 10 Exhibit Exhibits to Declaration (Pt. 8), # 11 Exhibit Exhibits to Declaration (Pt. 9), # 12 Exhibit Exhibits to Declaration (Pt. 10), # 13 Text of Proposed Order)(Freeny, Kyle) (Entered: 03/04/2011)
15 Memorandum in opposition to re 14 MOTION for Summary Judgment (Partial) filed by ELECTRONIC FRONTIER FOUNDATION. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Statement of Facts, # 4 Text of Proposed Order)(Sobel, David) (Entered: 04/05/2011)
16 Cross MOTION for Partial Summary Judgment by ELECTRONIC FRONTIER FOUNDATION (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Statement of Facts, # 4 Text of Proposed Order)(Sobel, David) (Entered: 04/05/2011)
17 REPLY to opposition to motion re 14 MOTION for Summary Judgment filed by DEPARTMENT OF JUSTICE. (Attachments: # 1 Exhibit 1 (Declaration of Dennis J. Argall), # 2 Exhibit 2)(Freeny, Kyle) (Entered: 04/22/2011)
18 Memorandum in opposition to re 16 Cross MOTION for Partial Summary Judgment filed by DEPARTMENT OF JUSTICE. (Attachments: # 1 Exhibit 1 (Declaration of Dennis J. Argall), # 2 Exhibit 2)(Freeny, Kyle) (Entered: 04/22/2011)
19 NOTICE of Appearance by Thomas David Zimpleman on behalf of DEPARTMENT OF JUSTICE (Zimpleman, Thomas) (Entered: 05/11/2011)
20 Consent MOTION for Extension of Time to File Reply by ELECTRONIC FRONTIER FOUNDATION (Attachments: # 1 Text of Proposed Order)(Sobel, David) (Entered: 05/11/2011)
21 ORDER granting 20 Consent MOTION for Extension of Time to File Reply; it is further ordered that plaintiff shall have until June 7,2011, to file its reply in support of plaintiffs cross−motion for partial summary judgment. Signed by Judge Robert L. Wilkins on 5/12/2011. (tcb) (Entered: 05/12/2011)
22 Consent MOTION for Extension of Time to File Reply by ELECTRONIC FRONTIER FOUNDATION (Attachments: # 1 Text of Proposed Order)(Sobel, David) (Entered: 06/07/2011)
23 ORDER granting 22 Consent MOTION for Extension of Time to File Reply; and plaintiff shall have until June 28,2011, to file its reply in support of plaintiffs cross−motion for partial summary judgment. Signed by Judge Robert L. Wilkins on 6/8/2011. (tcb) (Entered: 06/08/2011)

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06/16/2011 06/16/2011

24 NOTICE of Settlement Agreement and Release by ELECTRONIC FRONTIER FOUNDATION (Sobel, David) (Entered: 06/16/2011)
25 STIPULATION of Dismissal by ELECTRONIC FRONTIER FOUNDATION. (Sobel, David) (Entered: 06/16/2011)