UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
CITIZENS FOR RESPONSIBILITY AND
ETHICS IN WASHINGTON
1400 Eye Street, N.W., Suite 450
Washington, DC 20005
Case No. 1:07CV00620-RMC
CENTRAL INTELLIGENCE AGENCY
Washington, DC 20505
Defendant the Central Intelligence Agency (“Defendant”), by and through undersigned
counsel, hereby answers Plaintiff’s Complaint as follows:
1. Paragraph 1 contains Plaintiff’s characterization of its lawsuit and legal conclusions to
which no response is required. To the extent a response is required, Defendant denies the
allegations in Paragraph 1 except to admit that Plaintiff has filed a lawsuit pursuant to the
Freedom of Information Act (“FOIA”), 5 U.S.C. § 552.
2. Paragraph 2 contains Plaintiff’s characterization of the relief sought in this lawsuit,
and thus no response is required. To the extent a response is required, Defendant admits that
Plaintiff is seeking declaratory and injunctive relief in this action but denies that Plaintiff is
entitled to such relief.
JURISDICTION AND VENUE
3. Paragraph 3 contains conclusions of law, not allegations of fact, and thus no response
is required. Defendant denies any characterization of the cited statutory provisions, which speak
Case 1:07-cv-00620-RMC Document 3 Filed 05/04/2007 Page 1 of 7
CITIZENS FOR RESPONSIBILITY AND ETHICS IN WASHINGTON v. CENTRAL INTELLIGENCE AGENCY
for themselves, and respectfully refers the Court to 5 U.S.C. § 552(a)(4)(B) and 28 U.S.C. § 1331
for a complete and accurate statement of their contents. To the extent a response is required,
Defendant admits that this Court is a proper venue for this action pursuant to FOIA, only to the
extent that this Court has jurisdiction over this action under that statute.
4. Defendant lacks sufficient knowledge or information to form a belief as to the truth of
the allegations in Paragraph 4.
5. Defendant l