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1
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COMPLAINT
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EXTRACTED KEY WORDS
REQUEST AMNESTY UNITED STATES AGENCY DEFENDANT COURT COLOMBIA PABLO ESCOBAR ATTORNEY/CLIENT PURSUANT CIA DISTRICT CENTRAL INTELLIGENCE AGENCY DECLARATORY RELIEF PEPES PERSEGUIDOS POR PABLO WITHHELD PRISONERS PROMPT POLICY REPORTS FEES RESPONSE FOIA CONTROL PRIVACY COORDINATOR EXHIBIT NOTWITHSTANDING |
CONFIDENTIAL -- THIS DOCUMENT CONTAINS ATTORNEY/CLIENT
ADVICE AND ATTORNEY WORK PRODUCT. IT MUST BE HELD
CLOSELY TO PRESERVE PRIVILEGES.
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMNESTY INTERNATIONAL USA )
600 Pennsylvania Avenue, NE )
Washington, D.C. 20003 )
Plaintiff, ))
v. ) CASE NO.
))
CENTRAL INTELLIGENCE AGENCY )
Washington, D.C. 20505 )
Defendant. ))
_________________________________ )
COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF
1. This is an action under the Freedom of Information Act ("FOIA"), 5 U.S.C. §552,
et. seq., as amended, to order the production of agency records consisting of all records
which mention or relate to the Colombian organization known as the "PEPES," or the
Perseguidos por Pablo Escobar, People Persecuted by Pablo Escobar, which the
defendant has improperly withheld from the plaintiff.
2. This Court has jurisdiction over this action pursuant to 5 U.S.C. § 552 (a)(4)(B).
3. Plaintiff Amnesty International USA ("Amnesty"), recipient of the 1977 Nobel
Peace prize, is a nonprofit tax-exempt organization and the requester of the records in this
matter. Amnesty works impartially to free prisoners of conscience, for fair and prompt
trials for all political prisoners, and to abolish torture and executions under any
circumstances. Amnesty seeks to enrich public policy debate by publishing and making
widely available reports concerning human rights issues. With the information from this
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