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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
CAMPAIGN FOR ACCOUNTABILITY,
611 Pennsylvania Avenue SE, #337
Washington, DC 20003
Plaintiff,
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v. ) Case No.
U.S. DEPARTMENT OF
HEALTH AND HUMAN SERVICES,
200 Independence Avenue SW
Washington, DC 20201
Defendant.
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COMPLAINT
1. Plaintiff Campaign for Accountability brings this action against the U.S.
Department of Health and Human Services under the Freedom of Information Act, 5 U.S.C. § 552
(FOIA), and the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202, seeking declaratory and
injunctive relief to compel compliance with the requirements of FOIA.
JURISDICTION AND VENUE
2. This Court has jurisdiction over this action pursuant to 5 U.S.C. § 552(a)(4)(B) and
28 U.S.C. §§ 1331, 2201, and 2202.
3. Venue is proper in this district pursuant to 5 U.S.C. § 552(a)(4)(B) and 28 U.S.C.
§ 1391(e).
4. Because Defendant U.S. Department of Health and Human Services has failed to
comply with the applicable time-limit provisions of the FOIA, Campaign for Accountability is
deemed to have constructively exhausted its administrative remedies pursuant to 5 U.S.C.
20-cv-0583