12345678910111213141516171819202122232425262728TONY WESTAssistant Attorney GeneralELIZABETH J. SHAPIRODeputy Branch Director BRIGHAM J. BOWEN (DC Bar No. 981555)Trial AttorneyUnited States Department of JusticeCivil Division, Federal Programs BranchPost Office Box 883Washington, D.C. 20044Tel: (202) 514-6289Fax: (202) 307-0449 email@example.comUNITED STATES DISTRICT COURTDISTRICT OF ARIZONAKENNETH ALLEN,Plaintiff,v.DEPARTMENT OF HOMELANDSECURITY and U.S. DEPARTMENT OFSTATE,
MEMORANDUM IN SUPPORT OFDEFENDANTS’ PARTIAL MOTIONTO DISMISS PLAINTIFF’SAMENDED COMPLAINT
By this Freedom of Information Act (“FOIA”) action,
Plaintiff Kenneth Allenseeks private passport, travel, and other records relating to President Barack Obama, hismother, Stanley Ann Dunham, and his mother’s former husband, Lolo Soetoro, from the U.S.Department of State (“DOS”) and the U.S. Citizenship and Immigration Service (“USCIS”).
In submitting these requests, Plaintiff has failed to comply with agency regulations promulgated to protect the personal privacy of U.S. citizens and residents. Defendantstherefore move the Court to dismiss Plaintiff’s Amended Complaint [Dkt. #11-1] withrespect to records concerning President Obama.USCIS is a component of the U.S. Department of Homeland Security (“DHS”), and
is the agency to which Allen has directed his FOIA requests.
Case 4:09-cv-00373-FRZ Document 15 Filed 10/05/09 Page 3 of 10