Case 1:24-cv-00982 Document 1 Filed 04/05/24 Page 1 of 6

7) Defendant’s failure to respond in any meaningful way, whatsoever, to Plaintiff’s request, despite the passage of nearly three months, has constructively exhausted all of Plaintiff’s administrative remedies, leaving Plaintiff no choice but to file this lawsuit to compel the DIA to comply with the law regarding release of agency records and the making of a determination. [...] 10) Defendant DIA is a federal “agency” within the meaning of the Freedom of Information Act and is a constituent component of the Department of Defense. [...] Within that deadline, the agency must also “determine and communicate the scope of the documents it intends to produce and withhold, and the reasons for withholding any documents,” and “inform the requester that it can appeal whatever portion of the agency’s “determination” is adverse to the requestor. [...] 28) Plaintiff asks the Court to enter an injunction ordering Defendant to search for and produce to Plaintiff, within 10 business days of the date of the order, the requested records sought in Plaintiff's FOIA request described above, and any attachments thereto. [...] 5 Case 1:24-cv-00982 Document 1 Filed 04/05/24 Page 6 of 6 29) Plaintiff asks the Court to order the parties to consult regarding withheld documents and to file a status report to the Court within 30 days after Plaintiff receives the last of the produced documents, addressing Defendant's preparation of a Vaughn log and a briefing schedule for resolution of remaining issues associated with Plaintif.