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____________________________________
CITIZENS FOR RESPONSIBILITY AND :
ETHICS IN WASHINGTON :
:
Plaintiff, :
:
v. : Civil Action No.
:
U.S. DEPARTMENT OF HOMELAND :
SECURITY :
:
Defendant. :
____________________________________:
Pursuant to Rule 65 of the Federal Rules of Civil Procedure, plaintiff Citizens for
Responsibility and Ethics in Washington (“CREW”) respectfully moves for the entry of a
(“FOIA”) request seeking records of visits by health care industry executives to the White House
and the Vice President’s Residence. The records plaintiff seeks are created and maintained by
the Secret Service, an agency component of DHS. By this motion plaintiff seeks an order
requiring DHS to immediately process plaintiff’s FOIA request and disclose the requested
The grounds for this motion are set forth in the accompanying memorandum of points
and authorities. Plaintiff also asks the Court, pursuant to Local Rule 65.1(d), to schedule a
hearing on this application for a preliminary injunction at the Court’s earliest convenience.
Respectfully submitted,
__________________________
Anne L. Weismann
(D.C. Bar No. 298190)
Melanie Sloan
(D.C. Bar No. 434584)
Citizens for Responsibility and Ethics
in Washington
1400 Eye Street, N.W., Suite 450
Washington, D. C. 20005
Telephone: 202-408-5565
Fax: 202-588-5020