Case 1:04-cv HHK Document 48 Filed 02/14/2006 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Similar documents
Case 1:17-cv TSC Document 13 Filed 09/08/17 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:17-cv RC Document 8 Filed 09/25/17 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:11-cv JDB Document 3 Filed 02/17/12 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:14-cv APM Document 24 Filed 03/10/16 Page 1 of 10 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 07/05/18 Page 1 of 5 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA. Case No.

Case 1:13-cv AT Document 18 Filed 03/03/14 Page 1 of 8 ANSWER TO FIRST AMENDED COMPLAINT

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 01/12/18 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 09/17/18 Page 1 of 12 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) )

Case 1:10-cv RMC Document 46 Filed 11/21/12 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 07/10/18 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) )

Case 1:15-cv ARR-RLM Document 1 Filed 12/11/15 Page 1 of 12 PageID #: 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

Case 1:17-cv RDB Document 17 Filed 11/13/17 Page 1 of 6. UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND Baltimore Division ANSWER

Case 3:07-cv SI Document 25 Filed 11/26/2007 Page 1 of 7

Case 1:17-cv Document 1 Filed 06/18/17 Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 04/23/18 Page 2 of Venue is proper in this district pursuant to 28 U.S.C. 1391(e) and 5 U.S.C.

Case 3:07-cv SI Document Filed 11/26/2007 Page 1 of 7

Case 1:17-cv Document 1 Filed 05/31/17 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 07/19/18 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 05/09/18 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 08/07/18 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) )

Case 1:18-cv Document 1 Filed 02/26/18 Page 1 of 9 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:12-cv Document 1 Filed 07/18/12 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA

PlainSite. Legal Document

Case4:11-cv YGR Document22 Filed02/16/12 Page1 of 5

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON AT YAKIMA

Case 2:15-cv CMR Document 6 Filed 03/28/16 Page 1 of 18 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Case 1:14-cv KMW Document 14 Entered on FLSD Docket 09/08/2014 Page 1 of 7

Case 1:18-cv Document 1 Filed 11/20/18 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA

Case4:13-cv JSW Document112 Filed05/05/14 Page1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 2:08-cv CW-DBP Document 7 Filed 11/11/08 Page 1 of 14

Case 1:12-cv CKK-BMK-JDB Document 36 Filed 04/04/12 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 02/08/18 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:18-cv Document 1 Filed 02/19/18 Page 2 of 10

CASE 0:12-cv RHK-JSM Document 9 Filed 02/01/13 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT

Case 1:17-cv Document 1 Filed 06/27/17 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) )

Case 1:18-cv Document 1 Filed 02/02/18 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO. 1:10-CV ANSWER TO PLAINTIFF S FIRST AMENDED COMPLAINT

Case 2:16-cv JHS Document 50 Filed 04/30/18 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

In The United States District Court For The Southern District of Ohio Eastern Division. Answer

Case Doc 19 Filed 06/01/16 Entered 06/01/16 14:19:45 Desc Main Document Page 1 of 13 UNITED STATES BANKRUPTCY COURT DISTRICT OF MASSACHUSETTS

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

IN THE UNITED STATES COURT OF APPEALS FOR THE FEDERAL CIRCUIT IN RE TELES AG,

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT THE PARTIES

Case 1:17-cv JEB Document 1 Filed 06/29/17 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:12-cv Document 1 Filed 07/06/12 Page 1of6

Case 1:18-cv Document 1 Filed 06/25/18 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

FILED: NEW YORK COUNTY CLERK 03/19/ :45 PM INDEX NO /2016 NYSCEF DOC. NO. 168 RECEIVED NYSCEF: 03/19/2018

Case 1:17-cv Document 1 Filed 12/06/17 Page 1 of 7

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Case 1:18-cv JKB Document 1 Filed 07/25/18 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

Case 1:16-cv-Of''l67-RDM Document 1 Filed 05/2?' 1 6 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:17-cv Document 1 Filed 06/26/17 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:16-cv JEB Document 1 Filed 01/01/16 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 1:17-cv Document 1 Filed 05/08/17 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CENTER FOR IMMIGRATION ) STUDIES, ) 1629 K Street, NW, Suite 600, ) Washington, DC 20

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

CIVIL ACTION. Defendant Jeff Carter, by and through his counsel Law Offices of Walter M. Luers, by

Case 1:13-cv KBJ Document 21 Filed 09/06/13 Page 1 of 4 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case4:08-cv JSW Document320 Filed01/28/15 Page1 of 3

Case 1:06-cv GK Document 37 Filed 09/05/2008 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

WAIVER OF APPOINTMENT OF GUARDIAN AD LITEM. I,, the Respondent in. give up my right to have this Court appoint a Guardian Ad Litem

Case 0:12-cv WJZ Document 7 Entered on FLSD Docket 12/13/2012 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case 1:13-cv RC Document 1 Filed 06/06/13 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) )

Case 1:06-cv MSK-BNB Document 33 Filed 09/08/06 USDC Colorado Page 1 of 11

ANSWER AND COUNTERCLAIM OF DEFENDANTS PINE TREE HOMES, LLC AND SANTIAGO JOHN JONES

Case 1:15-cv PKC Document 20 Filed 03/07/16 Page 1 of 10. Plaintiffs, 15 Civ (PKC) DECLARATION OF PAUL P. COLBORN

Case 1:18-cv KBJ Document 17 Filed 05/23/18 Page 1 of 10 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:16-cv Document 1 Filed 06/06/16 Page 1 of 9

Case 1:17-cv Document 1 Filed 05/17/17 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) )

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) ) ANSWER

Case 1:17-cv RMC Document 12 Filed 11/16/17 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) Plaintiff, Defendant.

PLAINTIFF AVA SMITH- THOMPSON S COMPLAINT AGAINST DEFENDANT SARA LEE CORPORATION

Case 1:10-cv RMU Document 25 Filed 07/22/11 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) )

Case 1:12-cv DJC Document 36 Filed 09/10/13 Page 1 of 16 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:10-cv RMU Document 8 Filed 04/15/10 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Security ( DHS ) officials including ICE officers in field offices, detention facilities and

Case 1:17-cv APM Document 1 Filed 07/07/17 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case: 1:12-cv Document #: 21 Filed: 03/05/12 Page 1 of 11 PageID #:30 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) )

Case 1:18-cv Document 1 Filed 04/26/18 Page 1 of 9 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA. Case No.

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

UNOPPOSED MOTION AND MEMORANDUM OF POINTS AND AUTHORITIES TO PERMIT APPEARANCE OF COUNSEL PRO HAC VICE

Case 3:16-cv PK Document 625 Filed 06/15/18 Page 1 of 5

Case 1:18-cv Document 1 Filed 04/03/18 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Transcription:

Case 1:04-cv-00814-HHK Document 48 Filed 02/14/2006 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Roger Hall, et al., ) ) Plaintiff, ) ) V. ) Civil Action 04-00814 (HHK) Central Intelligence Agency, ) ECF ) Defendant. ) ) DEFENDANT'S ANSWER Defendant responds to the allegations of the Complaint as follows: Jurisdiction 1. The allegations contained in paragraph 1 constitute a conclusion of law to which no response is required; to the extent they may be deemed allegations of fact, they are denied. Parties 2. Denies the allegations contained in paragraph 2 for lack of knowledge or information sufficient to form a belief as to their truth. 3. Denies the allegations contained in paragraph 3 for lack of knowledge or information sufficient to form a belief as to their truth. 4. Denies the allegations contained in paragraph 4 for lack of knowledge or information sufficient to form a belief as to their truth. 5. Denies the allegations contained in paragraph 5 except admits that the Central Intelligence Agency (CIA) is an agency of the Executive Branch of the United States Government.

Case 1:04-cv-00814-HHK Document 48 Filed 02/14/2006 Page 2 of 8 February 7. 2003 FOIA Request by all plaintiffs 6. Denies the allegations contained in paragraph 6 except to state that the 7. Denies the allegations contained in paragraph 7 except to state that the 8. Denies the allegations contained in paragraph 8 except to state that the 9. Denies the allegations contained in paragraph 9. 10. Denies the allegations in the first sentence of paragraph 10 except admits that by letter dated 13 March 2003, the CIA s Information and Privacy Coordinator (IPC) acknowledged receipt of the 7 February 2003 FOIA request. Denies the allegations in the second sentence of paragraph 10 except to state that the complaint speaks for itself. April 13, 2005 Court Order Denying ATM's News Media Status and Public Interest Fee Waiver 11. Denies the allegations contained in paragraph 11 except to state that the Memorandum Opinion and Order speaks for itself. April 26, 2005 FOIA Request by AIM 12. Denies the allegations contained in paragraph 12 except to state that the 13. Denies the allegations contained in paragraph 13 except to state that the 14. Denies the allegations contained in paragraph 14 except to state that the

Case 1:04-cv-00814-HHK Document 48 Filed 02/14/2006 Page 3 of 8 15. Denies the allegations contained in paragraph 15 except to state that the AIM'S Exhaustion of its Administrative Remedies 16. Denies the allegations contained paragraph 16 except to state that the letter speaks for itself. 17. Denies the allegations in the first sentence of paragraph 17 except admits that on 8 July 2005, the CIA received a letter dated 29 June 2005 and the letter speaks for itself. Denies the allegations in the second sentence of paragraph 17 except to state that the 18. The allegations contained in the first sentence of paragraph 18 constitute conclusions of law to which no response is required; to the extent they may be deemed allegations of fact, they are denied. Denies the allegations contained in the second sentence of paragraph 18. April 13, 2005 Court Order Denying Hall and SSRI News Media Status and Public Interest Fee Waiver 19. Denies the allegations contained in paragraph 19 except to state that the Memorandum Opinion and Order speaks for itself. Hall's and SSRI's Correspondence Supp1ementin& the Administrative Record, and Exhaustion of Administrative Remedies

Case 1:04-cv-00814-HHK Document 48 Filed 02/14/2006 Page 4 of 8 20. Denies the allegations contained in paragraph 20 except to state that the 21. Denies the allegations contained in paragraph 21 except to state that the 22. Denies the allegations contained in paragraph 22 except to state that the 23. Denies the allegations contained in paragraph 23 except to state that the 24. Denies the allegations contained in paragraph 24 except to state that the 25. Denies the allegations contained in paragraph 25 except to state that the 26. Denies the allegations contained in paragraph 26 except to state that the 27. Denies the allegations contained in paragraph 27 except to state that the 28. Denies the allegations contained in paragraph 28 except to state that the 29. Denies the allegations contained in paragraph 29 except to state that the 30. Denies the allegations contained in paragraph 30 except to state that the

Case 1:04-cv-00814-HHK Document 48 Filed 02/14/2006 Page 5 of 8 May 24, 2005 Request of Roger Hall and SSRI 31. Denies the allegations contained in paragraph 31. 32. Denies the allegations contained in paragraph 32. Hall & SSRI's Exhaustion of Administrative Remedies 33. Denies the allegations in the first sentence of paragraph 33 except to state that the letter dated 1 July 2005 speaks for itself. Denies the allegations in the second sentence of paragraph 33 except to state that the 33[sic]. The allegations contained in this paragraph constitute conclusions of law to which no response is required; to the extent they may be deemed allegations of fact, they are denied. Count I February 7, 2005 Isicl FOIA Request-all plaintiffs 35. Defendant restates and incorporates by reference its previous responses to paragraphs 1 through 33 [sic] as though set forth fully herein. 36. The allegations contained in paragraph 36 constitute conclusions of law to which no response is required; to the extent they may be deemed allegations of fact, they are denied. Count II April 26, 2005 FOIA Request-plaintiff AIM 37. Defendant restates and incorporates by reference its previous responses to paragraphs 1 through 36 above as though set forth fully herein. 38. The allegations contained in paragraph 38 constitute conclusions of law to which no response is required; to the extent they may be deemed allegations of fact, they are denied.

Case 1:04-cv-00814-HHK Document 48 Filed 02/14/2006 Page 6 of 8 Count III May 24, 2005 FOIA Request-plaintiffs Hall & SSRI 39. Defendant restates and incorporates by reference its previous responses to paragraphs 1 through 38 above as though set forth fully herein, 40. The allegations contained in paragraph 40 constitute conclusions of law to which no response is required; to the extent they may be deemed allegations of fact, they are denied. Count IV News Media Status-all plaintiffs 41. Defendant restates and incorporates by reference its previous responses to paragraphs 1 through 40 above as through set forth fully herein, 42. The allegations contained in paragraph 42 constitute conclusions of law to which no response is required; to the extent they may be deemed allegations of fact, they are denied. Count V Public Interest Fee Waiver-all plaintiffs 43. Defendant restates and incorporates by reference its previous responses to paragraphs 1 through 42 above as though set forth fully herein. 44. The allegations contained in paragraph 44 constitute conclusions of law to which no response is required; to the extent they may be deemed allegations of fact, they are denied. Defendant denies that plaintiffs are entitled to the relief requested in their Prayer for Relief set forth after paragraph 44 or to any relief whatsoever. Defendant Denies each and every allegation not specifically admitted. For further answer and defense, defendant states that plaintiffs' claims are barred for failure to state a claim upon which relief can be granted and for lack of subject matter

Case 1:04-cv-00814-HHK Document 48 Filed 02/14/2006 Page 7 of 8 jurisdiction. Further plaintiffs have failed to exhaust their administrative remedies. WHEREFORE, defendant respectfully requests the Court to enter judgment in favor of defendant, to dismiss the complaint, and to grant defendant such other and further relief as the Court may deem just and proper. Respectfully submitted, / s / KENNETH L. WAINSTEIN, D.C. Bar # 451058 United States Attorney / s / R. CRAIG LAWRENCE, D.C. Bar # 171538 Assistant United States Attorney / s / Of Counsel: Laura Zirkle, Esq. Office of General Counsel Litigation Division Central Intelligence Agency MERCEDEH MOMENI Assistant United States Attorney Civil Division 555 4 th Street, N.W. Washington, D.C. 20530 202-305-4851

Case 1:04-cv-00814-HHK Document 48 Filed 02/14/2006 Page 8 of 8 CERTIFICATE OF SERVICE I hereby certify that on February 14, 2006, a copy of foregoing DEFENDANT S ANSWER was electronically served on all parties by operation of the Court's electronic filing system. MERCEDEH MOMENI Assistant United States Attorney Civil Division 555 4 th Street, N.W. Washington, D.C. 20530 202-305-4851