COMPLAINT, IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION, AARON RAYMOND BABBITT, Personal Representative of the Estate of Ashli Elizabeth Babbitt 4849 Cape May Avenue San Diego, California 92107 Plaintiff, v. DISTRICT OF COLUMBIA John A Wilson Building 1350 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Defendant,

 

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IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION
AARON RAYMOND BABBITT, Personal Representative of the Estate of Ashli Elizabeth Babbitt 4849 Cape May Avenue San Diego, California 92107 Plaintiff,
v.
DISTRICT OF COLUMBIA John A Wilson Building 1350 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Defendant,
Civil Action No.:
COMPLAINT

COUNT 1

(Violation of FOIA)

WHEREFORE, Plaintiff respectfully requests that the Court: (i) order Defendant to conduct searches for any and all records responsive to Plaintiffs FOIA requests and demonstrate that it employed search methods reasonably likely to lead to the discovery of records responsive to the requests; (ii) order Defendant to produce, by a date certain, any and all non-exempt records responsive to the Plaintiffs FOIA requests and Vaughan indices of any responsive records withheld under claim of exemption; (iii) enjoin Defendant from continuing to withhold any and all non-exempt records responsive to the FOIA requests; (iv) grant Plaintiff an award of attorney's fees and other litigation costs reasonably incurred in this action pursuant to DC Code Sec. 2-537 (c); (v) consolidate this action with the FOIA action filed by Judicial Watch, Inc.; and (vi) and grant Plaintiff such relief as the Court deems just and proper.

Terrell N. Roberts, III (D.C. Bar No. 965830)
ROBERTS & WOOD
Attorney for Plaintiff

Filed
D.C. Superior Court
06/01/2021 13:03PM
Clerk of the Court