LEOPOLD et al v. CENTRAL INTELLIGENCE AGENCY

Filing 1

COMPLAINT against CENTRAL INTELLIGENCE AGENCY ( Filing fee $ 400 receipt number 0090-5167307) filed by JASON LEOPOLD, BUZZFEED, INC.. (Attachments: # 1 Civil Cover Sheet, # 2 Summons)(Light, Jeffrey)

Case 1:17-cv-02176-RC Document 1 Filed 10/19/17 Page 1 of 4

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

JASON LEOPOLD,
6824 Lexington Avenue
Los Angeles, CA 90038,
and
BUZZFEED, INC.,
111 E. 18th St.
New York, NY 10003,
PLAINTIFFS
vs.
CENTRAL INTELLIGENCE AGENCY,
Washington, DC 20505
DEFENDANT.

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) Judge _____________
) Civil Action No. ____________
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COMPLAINT

THE PARTIES
1.

Plaintiff Jason Leopold is a Senior Investigative Reporter for Buzzfeed News

covering a wide range of issues.
2.

Plaintiff Buzzfeed, Inc. (BuzzFeed) is a social news and entertainment company.

3.

Defendant Central Intelligence Agency (CIA) is an agency of the United States.

4.

CIA has possession, custody and control of the records Plaintiffs seek.

JURISDICTION AND VENUE
5.

This action arises under the Freedom of Information Act (“FOIA”), 5 USC § 552.

Case 1:17-cv-02176-RC Document 1 Filed 10/19/17 Page 2 of 4

6.

This Court has jurisdiction over the parties and subject matter pursuant to 5 USC

§ 552(a)(4)(B).
7.

Venue is proper in this district pursuant to 5 USC § 552(a)(4)(B).

STATEMENT OF FACTS

8.

On July 24, 2017, President Donald Trump tweeted, “The Amazon Washington

Post fabricated the facts on my ending massive, dangerous, and wasteful payments to Syrian
rebels fighting Assad.....”
9.

President Trump’s tweet constitutes official acknowledged that the United States

had been making payments to Syrian rebels fighting Assad.
10.

On September 12, 2017, Plaintiffs submitted a FOIA request to CIA for:
a) Any and all CIA studies, memos, assessments, and intelligence products,
mentioning or referring to CIA payments to Syrian rebels fighting Assad;
b) Any and all emails mentioning or referring to CIA payments to Syrian rebels
fighting Assad;
c) Any and all correspondence to or from a member of Congress or a
Congressional Committee mentioning or referring to CIA payments to Syrian
rebels fighting Assad;
d) Any and all records that mentions or refers to the July 24, 2017 by President
Donald Trump:
https://twitter.com/realDonaldTrump/status/889672374458646528. The tweet
states: “The Amazon Washington Post fabricated the facts on my ending

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Case 1:17-cv-02176-RC Document 1 Filed 10/19/17 Page 3 of 4

massive, dangerous, and wasteful payments to Syrian rebels fighting
Assad.....”;
e) Any and all records mentioning or referring to the ending of the CIA’s
payments to Syrian rebels fighting Assad; and
f) Any and all records authorizing the CIA to make payments to Syrian rebels
fighting Assad. This request includes, but is not limited to, the “FINDING”
authorized by President Barack Obama.
11.

The request sought a waiver of fees and status as a representative of the news

media for fee purposes.
12.

In a letter dated September 25, 2017, CIA acknowledged receiving Plaintiffs’

request on September 14, 2017 and assigned the request tracking number F-2017-02526. The
letter further indicated that Plaintiffs’ request for a waiver of fees had been granted.
13.

As of the filing of this Complaint, Plaintiffs have not received a final decision

from the CIA as to whether or not it will comply with the FOIA request.

COUNT I:
VIOLATION OF FOIA
14.

This Count realleges and incorporates by reference all of the preceding

paragraphs. All documents referenced in this Complaint are incorporated by reference as if set
forth fully herein.
15.

Plaintiffs are deemed to have exhausted their administrative remedies with respect

to F-2017-02526 because over 20 business days have elapsed without a final determination as to
whether CIA will comply with Plaintiffs’ FOIA request.

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Case 1:17-cv-02176-RC Document 1 Filed 10/19/17 Page 4 of 4

PRAYER FOR RELIEF
WHEREFORE, Plaintiffs respectfully request that this Court:
(1) Declare Defendant’s failure to comply with FOIA to be unlawful;
(2) Order Defendant to immediately process Plaintiffs’ FOIA request and produce any nonexempt, responsive records;
(3) Grant Plaintiffs an award of attorney fees and other litigation costs reasonably incurred in
this action pursuant to 5 USC § 552(a)(4)(E)(i);
(4) Grant Plaintiffs such other and further relief which the Court deems proper.

Respectfully Submitted,
__/s/ Jeffrey Light_______________
Jeffrey L. Light
D.C. Bar #485360
1712 Eye St., NW
Suite 915
Washington, DC 20006
[phone]
[e-mail]
Counsel for Plaintiffs

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