IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN HISTORICAL ASSOCIATION, )
400
A
Street,
S.E.
)
Washington, D.C. 20003-3889, )
)
HUGH
DAVIS
GRAHAM,
)
305
E.
Islay
Street
)
Santa Barbara, CA 93101, )
)
STANLEY
I.
KUTLER,
)
4112
Keewatin
Trail
)
Verona,
WI
53593,
)
)
THE NATIONAL SECURITY ARCHIVE, )
The George Washington University )
Gelman Library, Suite 701 )
2130 H Street, NW )
Washington,
D.C.
20037,
)
)
ORGANIZATION OF AMERICAN )
HISTORIANS,
SNIPPETS:
IN THE UNITED STATES DISTRICT COURT
Washington,
COMPLAINT FOR DECLARATORY, INJUNCTIVE AND MANDAMUS RELIEF
Plaintiffs, the American Historical Association, Hugh Davis Graham, Stanley I.
Kutler, the Organization of American Historians, the National Security Archive, Public
Administrative Procedure Act, 5 U.S.C. §§ 701 et seq., under their nonstatutory right to
judicial review of unlawful executive action, and under the Presidential Records Act,
44 U.S.C. §§ 2201 et seq., to obtain a declaratory judgment that the Archivist of the United
States and the National Archives and Records Administration must administer the
Presidential Records Act without regard to the terms of Executive Order No. 13,233 (the "Bush
and to compel the release of presidential materials of former President Ronald Reagan
held by NARA, including the records of former President Reagan and former Vice President
he has custody and control under the PRA of all the presidential materials of former President
After expiration of the 12-year restriction period,
"constitutionally based" right or privilege that prevents public release.
the 12-year limit on the restriction of confidential communications (id.
to seek judicial review.
by the incumbent president, presidential materials otherwise subject to public access under
As defendant Carlin has acknowledged in an article entitled "Presidential Papers
to notify the White House and former President Reagan of its intention to open these formerly
The Bush Order, entitled "Further Implementation of the Presidential Records
Constitution bars release.
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