CAMPAIGN FOR ACCOUNTABILITY v. U.S. ENVIRONMENTAL PROTECTION AGENCY

Filing 1

COMPLAINT against U.S. ENVIRONMENTAL PROTECTION AGENCY ( Filing fee $ 400 receipt number 0090-5407146) filed by CAMPAIGN FOR ACCOUNTABILITY. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Civil Cover Sheet, # 5 Summons for USAO, # 6 Summons for AG, # 7 Summons for EPA)(Creighton, Sara)

ATTACHMENT E

CIVIL COVER SHEET

.15-44 (Rev. 3116 DC)

I. (a) PLAINTIFFS

DEFENDANTS

Campaign for Accountability

U.S. Environmental Protection Agency

1 1001

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
(EXCEPT IN U.S. PLAINTIFF CASES)

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT
(IN U.S. PLAINTIFF CASES ONLY)

NOTE IN LAN]) CONBELOSKHON CASES. USE HIS LOCATION OF TI It TRACT OF LAND INVOLVED

(c) A1TORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)

ATfORNEYS (IF KNOWN)

Sara Creighton
American Oversight, 1030 15th Street NW, B255
Washington, DC 20005
202.869.5245
II. BASIS OF JURISDICTION

III. CITIZENSHIP OF PRINCIPAL PARTIES

(PLACE AN x IN ONE BOX FOR
PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!

(PLACE AN x IN ONE BOX ONLY)

Q
0

Q

I U.S. Government
Plaintiff

Q

2 U.S. Government
Defendant

3 Federal Question
(U.S. Government NoI a Party)
4 Diversity
(Indicate Citizenship of
Parties in item ifi)

Citizen of this State
Cilizen of Anolher Stale
Citizen or Subject ofa
Foreign Country

PTF

DFI’

02

0’
03

01

03

I

PTF
04

DFT

Incorporated and Principal Place
of Business in Another Slate

05

05

Foreign Nation

06

06

Incorporated or Principal Place
of Business in This State

04

IV. CASE ASSIGNMENT AND NATURE OF SUIT
(Place an X in one category, A-N, that best represents your Cause of Action and
in a corresponding Nature of Suit)

0

A. Antitrust

C410 Antitrust

0

0

B. Persona! Injury!

fl310
[:J315
[:J320
[:3330
l~] 340

Malpractice
Airplane
Airplane Product Liability
Assault, Libel & Slander
Federal Employers Liability
Marine

C. Administrative Agency

Review
151 Medicare Act
Social Security
C 861 HIA (1395~
862 Black Lung (923)

L1134~ Marine Product Liability

TEl 863 DRVC/DIWW (405(gD
864 SSID Title XVI
C 865 RSI (405(g))

[:3 360 Other Personal Injury
[:11 362 Medical Malpractice

0.

Temporary Restraining
Order/Preliminary
Injunction

Any nature of suit from any category
maybe selected for this category of case
assignment.

Other Statutes
891 Agricultural Acts
893 Environmental Matters
EEl 890 Administrative Agency is(If
Other Statutory Actions

~ 350 Motor Veluele
~ 355 Motor Vehicle Product Liability

[)365 Product Liability
[:1367 Health Care/Pharmaceutical
Personal Injury Product Liability
C368 Asbestos Product Liability

o E.

0

OR

General Civil (Other.)

Real Property
[:J21O Land Condemnation
13220 Foreclosure
[:3230 Rent, Lease & Ejeetment
[El 240 Torts to Land
[:3245 Tort Product Liability
E:3290 All Other Real Property
Personal Property
[:3370 Other Fraud
C371 Truth in Lending
C380 Other Personal Property
Damage
C 385 Property Damage
Product Liability

*(If Antitrust, then A governs)*

Involved)

0

Bankruptcy
[: 422 Appeal 27 USC 158
TE3423 Withdrawal 28 USC 157
Prisoner Petitions
C 535 Death Penalty
C 540 Mandamus & Other
C 550 Civil Rights
C 555 Prison Conditions
El 560 Civil Detainee— Conditions
of Confinement
PropertvRiehts
C 820 Copyrights
C 830 Patent
C 840 Trademark
Federal Tax Suits

C870 Taxes (US plaintiff or
defendant)

C 871 IRS-Third_Party 26 USC 7609

F. Pro Se General Civil
Forfeiture/Penalty
~ 625 Drug Related Seizure of
Property 21 USC 881
[:1690 Other

Other Statutes
~ False Claims Act
[:3376 Qui Tam (31 USC
3729(a))
C400 State Reapportionment
C430 Banks & Banking
C450 Commerce/ICC
Rates/etc.
[:3460 Deportation
C462 Naturalization
Application
C 465 Other Immigration
Actions

E:1470 Racketeer Influenced
& Corrupt Organization
[:11480 Consumer Credit
[:3490 Cable/Satellite TV
[11850 Securities/Commodities/
Exchange
~J896 Arbitration
[:3899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
C950 Constitutionality of State
Statutes
C 890 Other Statutory Actions
(if not administrative agency
review or Privacy Act)

0

C. Habeas Corpus/
2255

0 H.

Employment
Discrimination
442 Civil Rights Employment
(critei1a race, gender/sex,
national origin,
discrimination, disability, age,
religion, retaliation)

E:]53o Habeas Corpus General
rz:~ 510 Motion/Vacate Sentence
r:J463 Habeas Corpus

Alien

Detainee

0 I.

[~] 895 Freedom of Information Act

K. Labor/ERISA

(if Privacy Act)

*(lfpro Se, select this deck)*

0 L.

0

(non-employment)
~J7l0
cJ720
0740
C]751

Fair labor Standards Act
Labor/Mgmt Relations
Labor Railway Act
Family and Medical
Leave Act
11J790 Other Labor Litigation
0791 EmpI Ret. Inc. Security Act

Student Loan

152 Recovery of Defaulted
Student Loan
(excluding veterans)

~ 890 Other Statutory Actions

(Ifpro Se, select this deck)*

0

0 J.

FOJA/Privacy Act

Other Civil Rights
(non-employment)

C]441 Voting (if not Voting Rights
Act)
[]443 Housing)Accommodations
0440 Other Civil Rights
c:]445 Americans w/Disabilities —
Employment
[11446 Americans w/Disabilities —
Other
[1)448 Education

M.

0

Contract

cJ ItO Insurance
[II 120 Marine
f•J 130 Miller Act
C] 140 Negotiable Instrument

Three-Judge
Court
N.

441 Civil Rights Voting
(if Voting Rights Act)

0150 Recovery of Overpayment
& Eaforcement of
Judgment
[11153 Recovery of Overpayment
of Veteran’s Benefits
0160 Stockholder’s Suits
L:Jl900therContnca
0195 Contract Product Liability
0196 Franchise

V. ORIGIN

0

i originai
Proceeding

0 2 Removed

from State
Court

0

3 Remanded from
Appellate Court

04 Reinstated or 0
Reopened

5 Transferred from
another district
(speci~r)

0

6 Multi-district
Litigation

07 Appeal to

District Judge
from Mag. Judge

VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)
5

U.S.C. 552. Defendant has failed to provide responsive records to

VII. REQUESTED IN
COMPLAINT

CHECK IF THIS ISA CLASS
ACTION UNDER F,R.CP. 23
(Sec instruction)

YES

requests.

DEMAND $

VIII. RELATED CASE(S)

FOIA

DATE:

ANY

4/5/2018

~RY DEMAND:
NO

Check YES only if demanded in complaint
YES
NO
X
If yes, please complete related case form

SIGNATURE OF AnORNEY OF RECORD _______________________________________
INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS.44
Authority for Civil Cover Sheet

The JS-44 civil cover sheet and the information contained herein neiiher replaces nor supplements the filings and services of pleadings or other papers as required
by law, excepi as provided by local rules of coon This form, approved by the Judicial Conference of the United States in September 1974 is required for the use of the
Clerk of Court for the purpose of initialing the civil docket sheet Consequently a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed
Listed below are tips for completing the civil cover sheet, These tips coincide with the Roman Numerals on the cover sheet.
I.

COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence Use 11001 to indicate plainiiff if resident
of Washington, DC, 88888 if plaintiff is resident of United States but not Washington. DC, and 99999 if plaintiff is outside the nited States

Ill.

CITIZENSHIP OF PRINCIPAL PARTIES: This section is cumpleied Qniy if diversity of citizenship was selected as the Basis of Jurisdiction
under Section II.

IV.

CASE ASSIGNMENT AND NATURE OF SUIT The assignment ofajudge to your case will depend on the category you select that best
represents the nrin,an’ cause of action found in your complaint You may select only mi~ category You mst~t also select ens corresponding
nature of suit found under the category of the case

VI.

CAUSE OF ACTION: Cite the U.S. Civil Statuie under which you are filing and wnie a bnef statement of the pnmary cause

VIII.

RELATED CASE(S), IF ANY’ If you indicated that there is a related case, you musi complete a related case form, which may be obtained from
the Clerk’s Office

Because of the need for accurate and complete information, you should ensure the accuracy of the information provided pnor to signing the form