Case 1:17-cv-03956-PGG Document1 Filed 05/25/17 Page 3of3
preferential treatment from authorities due to his wealth, connections, and political leverage. 11. The FBI has provided no response to Mr. Robertson’s request, nor even assigned it a tracking number. By failing to provide - or formally deny - documents within twenty working days, the FBI has constructively denied the request under 5 U.S. Code § 552(a)(6)(A)(i1). CAUSE OF ACTION
Violation of the Freedom of Information Act for Wrongful Withholding of Agency Records
12. Plaintiff repeats and realleges paragraphs 1-11. 13. Defendant FBI has wrongfully withheld agency records requested by Plaintiff. 14. Plaintiff has exhausted all administrative remedies. REQUESTED RELIEF WHEREFORE, Plaintiff requests this Court: (A) Order defendant to provide access to the requested documents in their entirety; (B) Expedite this proceeding as provided for in 28 U.S.C. § 1657; (C) Award plaintiff costs and reasonable attorney fees in this action, as provided in 5 U.S.C. § 552(a)(4)(E); and (D) Grant such other and further relief as may deem just and proper.
Dated: May 25, 2017 N on WV wack y:
B
Daniel Novack
NY BAR ID: 5010863
Law Office of Daniel R. Novack
4 New York Plaza (2"¢ Floor)
New York, NY 10004
Phone: (201) 213-1425
Email: Dan@NovackMediaLaw.com Counsel for Plaintiff
HOUSE_OVERSIGHT_029418