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Central Intelligence Agency
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8
(^Attorney Advisor
mended Complaint
Thanks for the letter. Could you just drophen you get confirmation lhat the letter has, in fact, been mailed" Thanks.
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f 11
UNCLASSIFIED
OVfci; ton KtLfcRSL DATE: 6
irNTTED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
ARIANNA HUFFINGTON
K
JR)
OF STATE *
-
OF JUSTICE *
BUREAU Or INVESTIGATION *
INTELLIGENCE AGENCY
OF ARMY
COMELAINJ: I. This is an action under the Freedom of Information Acts amended, for injunctive and otliei appropriate relief and the disclosure of agency records improperly withheld from plaintiff by defendants Department of State
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epartment ofederal Bureau ofentral Intelligencend the Department ofrmy").
JITRISDICTION AND VENtfE
Court Ins both subject matter jurisdiction over this action andover the defendants pursuantaX4XB) This Coonjurisdiction over this action pursuant loenue Iks2 (aX4XB).
PARTIES
Arianna Hullingtonationally syndicated columnist whose articles appear in newspapers throughout the United Slates, includings Angeles Times, the Chicago Sun Times and New York Post.
Then agency within tbe meaning0 and is in possession and/oi control of the records requested by Ms. Huffington which are the subject of this action.
The DOJ is an agency within the meaningQ and is in possession and/or control of the records requested by Ms. Huffington which are the subject of this action
G. The FBI is an agency within the meaning2 (f) and is in possession and/or control of the records requested by Ms Huffingion which arc ihe subject of this action.
The CIA is an agency within the rneahing0 and is in possession and/or control of the records requested by Ms Huffingion which arc the subject of this action
The Army is an agency within the meaningf) and is in possession and/or control of the records requested by Ms. Huffingion which aresubject of this action.
OSZST, O^ri DIM. vfl/TI/WH
Innyalifornian businessman, was confirmed by Ihe United Stales Senate,ie in the Senate Judiciary Committee, to serve as the United Stales Ambassador to Switzerland. Soon thereafter. Sheila Lawrence, tlie Ambassador's wife, was appoinied by Picstdent William Clinton to serve as. Special Representative to the World Conservation Union
From3 lo, Christina Marietate Department employee, served as Ihe Special Assistant to the Ambassador and his wife. Ms. Alexandre resigned in protest on5 and simultaneously requested the Stale Department's Office of Inspector General to investigate Ambassador and Miawrence for mismanagement, waste of government money and fraud
The Slate Department's Office of Inspector Generalriminal probe regaidbig Ms. Alexandre's allegations which was closed on6 due to Ambassador Lawrence's death. Upon information and belief, ihe State Department received complaints, other than fiom Ms. Alexandre, against Ambassador and/or Mrs lawtence lhal were being investigated or under consideration for investigation at the time of Ambassador's Lawrence's death.
Upon information and belief, duringrences' tenure in Switzerland, Ihe State Department expressly autlvorizcd the Lawrences to raise fundsrivate Lawrence foundation for tbe purposes of refurbishing the Ambassador's residence in Bern, Switzerland.esult, funds were solicited directly from Swiss companies and/or individuals who conduct buMnest with the United States and American companies that have business in Switzeiland. Kerns purchased through this effort were considered property of the United Stales. However, after tbe Ambassador's death, Mis. Lawrence took with her many of the items obtained through the refurbishment for her personal use
FoOowing the Ambassador's death, Mrs. lawrenceaiver for his burial in Arlington National Cemetery on Ihe pretext the Ambassador had served in the Merchant
P
ail
Marines during World War Two. Upon informaiion and belief. Mrs. Uwrence also actively lobbied the Clinton Administration to obtain an Ambassadorship Tor herself
a series of newspaper articlea that appeared nationally inlaintiff Arianna Huffingion exposed Ambassador LnmhN'las having been fabricated.esult, the Ambassador's remains were
infon nation and belief, following the revelations that Ambassadorfabricated his military record,. Department of Justicerobe intoof files related lo the Ambassador's nominal km and/or appointment
CHHffl-QNE tf01ARF.OlfF.ST-DOS)s Huffington repeats and realleges the allegations contained inhrough IS above, inclusive.
By letter datedarch IV9S. Ms. Huffington. by and uuougli counsel,OIA request lo lire DOS for all documents pertaining to Ambassador Maurice Larry Lawrence andrence.
By letter datedOS assigned Ms. Huflingion's request reference.
No substantive responses have been received from DOS.
DOS has failed to comply with the requisite statutory periods which govern compliance under the FOIA Therefore, the DOS has wrongfully withheld documents from Ms Huffington.
s DOS has failed lo respond lo Ms. Huffingtoo's FOIA request, Ms. Huffington is not required to exhaust administrative remedies.
s. Huffingionegal right under the FOIA to obtain lhe information she seeks, and there is no legal basis for lhe denial by the DOS of said right.
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Ms Huflington repeats and realleges the allegations contained inhroughbove, inclusive.
By letter dateds Huflington. by and through counsel,equest to the DOJ for all documents penanung to Ambassador Maurice Larry Lawrence and Shclia Davis Lawrence.
y letterOJ referred the request to the Federal Bureau of Investigations, the Office of the Inspector General and ibc Executive Office. Attorneys for direct response!.
By letterhe Office of the Inspector General indicated it had no responsive records pertaining to request
By letter dateds Hufhngton notified DOJ that responsive records may be located within the (Hikes of the Attorney General, Deputy Attorney General, Associate Attorney General, Office of Legal Counsel. Office of Legislative Affairs and Office of Public Affairs and requested that the appropriate searches be conducted.
By letter datedOJ's Executive Office for United States Attorney indicated it would neither confirm nor deny whether records pertaining to Sheilawrence existed.
By letter datedOJ notified Ms. Huflington that it had referred hei request to those offices indicated in her letter dated
By letterOJ's Office of Information and Privacy indicated that it will be responding to Ms. Ilultingion's request on behalf of the Offices of the Attorney General, Deputy Attorney General. Deputy Attorney. Associate Attorney General, Legislative Affairs and Public Affairs. DOJ noted that it could not comply with either theay working time limit, or thedditional days provided by the statute.
No further responses have been received from DOJ
s
IVA KO'tt IHU 0
DOJ lus failed to comply with the requisite statutory periods which govern compliance under the FOIA. Therefore, lhe DOJ lias wrongfully withheld documents from Ms. Huffingion,
As DOJ has failed lo respond lo Ms. Huffington's FOIA request, Ms. Huffington is not required lo exhaust administrative remedies, except with respect to the Office of Inspector General.
Ms. Huffingtonegal right under Ihe FOIA lo obtain Ihe information she seeks, and there is no legal basis for ihc denial by the DOJ of said right.
COHNTTHREFi {FOIA REQIffiST -Ms, Huffington repeats and realleges Ihe allegations contained inbove,
By letter dateds. Huffington, by and through counsel,OIA request to the DOJ for allining to Ambassador Maurice Larry Lawrence and Shelia Davis Lawrence.
By letter datedBI irtformed Ms. Huffington that no records were located concerning Ambassador Maurice Larry Lawrence.
By letter datedBI requested additional information concerning Shelia Davis Lawrence.
By letter dateds. Huffington provided FBI the mformation it requested concerning Shelia Davis Lawrence
By letter datedBI notified Ms. Huffington that the additional information had been received and the request, which was assigned FOIPAas being processed.
By letter dateds. Huffington appealed the FBI's determination that no records existed regarding Ambassador Lawrence.
No further response has been received from FBI concerning Shelia Davis
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66
yiBI notified Ms. Huflington that records pertaining to Ambassador Lawrence did exist andages were substantially released.
BI has failed to comply with the requisite statutory periods which govern compliance under Ihe FOIA Therefore, the FBI has wrongfully withheld documents from M* HumngtOfl.
As FBI has failed to respond to Ms. Huflington's FOIA request regarding Mrs. Lawrence, Ms. Huflington is not required to exhaust administrative remedies
Ms. HuRingtonegal right under the FOIA io obtain the Information she seeks, and there ii no legal basil for ths denial by the FBI of said right.
f fuRington repeats and realleges the allegations contained inhroughbove, inclusive
By letter diteds. Huflington. by and ihroughOIA request to the CIA for all documents pertaining to Ambassador Maurice Larry Lawrence and Shclia Davis Ijwrcnce
By letterIA notified Ms. Huftingtun that it had assignednumber6 to her request and needed more specific Information regarding Mrs. Lawrence prior lo processing the request
By letters, Huflington provided CIA with ihe requested Information regarding Mrs. Lawrence.
o substantive responses have been received Horn CIA.
IA has foiled to comply with the requisite statuioiy periods which govern compliance under the FOIA. Therefore, the CIA has wrongfully wiibhcld documents from Ms. Huflington
s CIA has failed to respond to Ms. Huflington's FOIA request, Ms.kiI required to exhaust adrniiuiirativa remedies
o"
Huffingionegal right under the FOIA lo obtain the informationand there is no legal basis for ihe denial by the CIA of said right.
mi INT FIVE IFOIARMY!
Ms Huffington lepeats and realleges the allegations contained inhroughbove, inclusive
By letter dateds. Huffingion. by and through counsel,OIA request to the Army for all documents pertaining to Ambassador Maurice Larry Lawrence and Shelia Davis Lawrence.
No icsponsQ has been received from Army, although, upon Information and belief, the request has been assigned
Army has failed to comply with the requisite statutory periods which govern compliance under the FOIA. Therefoie, the Army has wrongfully withheld documents from Ms. Huffington
As Army has failed to respond to Ms. Huffingtons FOIA request, Ms Huffington is not required to exhaust administrative remedies.
Ms. Huffingtonegal tight under the FOIA to obtain the information she seeks, and there is no legal basis for the denial by the Army of said right
COUNT SIX fFOlAOSI
Ms. Huffingion repeats and realleges the allegations contained inhroughbove, inclusive.
By letter dateds. Huffingion, by and through counsel,OIA request to DOS) All records pertaining to the refurbishment of the US Ambassador's residence in Bern, Switzerland. This request includes all records pertaining to the expenditure of funds to purchase or replace Hems for Ibe residence Your search should include, bul not be limited lo. all relevant file systems atepartment of State and. Embassy in Bern, Switzerland. You may restrict your search to all documents created after MarchAll records pertaining lo any
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r. iva tivn nn.r.
fund-raising efforts conducted by. Government or Ambassador and/or Mrs. Ltwrencc through, bul not limited to, the Lawrence Foundation lo refurbish lhe Ambassador's residence in Bern, Switzerland. Your search should include, but not be limited lo. all relevant file systems at the US Department of State and. Embassy in Bern. Switzerland. You may restrict your search lo all documents created after March"
By letter datedOS assigned Ms. Huffington's request reference.
No substantive responses have been received from DOS.
DOS has failed lo comply with Ihe requisite statutory periods which govern compliance under the FOIA. Therefore, Ihc DOS has wrongfully withheld documents from Ms. Huffington.
s DOS has failed lo respond to Ms lluffingion's FOIA request, Ms Huffingion is not required to cxhausi administrative remedies.
s. Huffingtonegal right under lhe FOIA to obtain tlie information she seeks, and there is no legal basis for the deniul by lhe DOS of said right.
WHEREFORE, plaintitTprays lhal this Court;
order the DOS. DOJ, FBI, CIA and Army disclose lhe requested records in their entireties and make copies promptly available to it.
expedite this action in every way pursuant to7
award plaintiff reasonable costs and attorney's fees as providedaX^XE) and/or2nd
grant such other relief as lhe Court may deem just and proper. Date: June8
HIil ilHl 0
aid. DC. Bar5
Washington.1
Counsel for PlainiiiT
CFiCI1 HEREBY CERTIFY thai on this 4th day ofopy of the foiegoing Plaintiffs First Amended Complain! was delivered via facsimile and mail, first class, postage pre-paid, to:
homas.. Department of Justice Judiciaryourthashinglon,
iiolR
OtIS MS IM IVdII1
Original document.
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