The White House maintained Plaintiffs' FBI files as part of a system of records. The White House was not relevant or necessary to accomplish any purpose required to be accomplished by statute or executive order of the President, and, therefore, was in violation of 5 U.S.C. Sec. Plaintiffs repeat and reallege the allegations contained in paragraphs I through 37, inclusive. The actions of Defendants Rodham Clinton, Nussbaum, Livingstone and Marceca, in willfully and intentionally obtaining confidential information concerning Plaintiffs, namely Plaintiffs' FBI files, without Plaintiffs' consent or any lawful justification, constituted highly offensive intrusions into Plaintiffs' private and secret concerns. In addition, Plaintiffs respectfully request an injunction restraining Defendants from a continuing course of conduct such that Plaintiffs will be permanently and irreparably damaged by such conduct.
Plaintiffs request trial by jury.