Denied. except to admit that defendant often mails postcards to inform FOIA requesters of the status of their request. Denied, except to aver that some FOIA responses occur more than 10 days after receipt of a request. This paragraph contains a conclusion of law to which no answer is required, but insofar as an answer may be deemed required, denied. Defendant incorporates by reference its answers to paragraphs 1 through 30. Defendant lacks knowledge or information sufficient to form a belief as to the truth of plaintiff's claim regarding his plans and potential harm to him.
Defendant denies the existence of any practice of silence and delay.
The remainder of plaintiff's complaint consists of plaintiff's prayer for relief to which no answer is required, but insofar as an answer may be deemed required, denied. Answering the complaint further, defendant denies each and every allegation not admitted, denied, or otherwise finalized. Wherefore, defendant prays that this action be dismissed with prejudice, and that such other relief as may be just and reasonable be given defendant.