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Shapiro Complaint

Shapiro Complaint

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Published by HuffPost Politics
Ryan Shapiro, a Ph.D. candidate at the Massachusetts Institute of Technology, is suing three government agencies to get answers about America's role in Nelson Mandela's infamous 1962 arrest.
Ryan Shapiro, a Ph.D. candidate at the Massachusetts Institute of Technology, is suing three government agencies to get answers about America's role in Nelson Mandela's infamous 1962 arrest.

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Published by: HuffPost Politics on Mar 25, 2014
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03/27/2014

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 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA RYAN NOAH SHAPIRO, , PLAINTIFF vs. CENTRAL INTELLIGENCE AGENCY, Washington, DC 20505, DEPARTMENT OF DEFENSE, 1400 Defense Pentagon Washington, DC 20301-1400, DEPARTMENT OF JUSTICE, 950 Pennsylvania Ave., NW Washington, DC 20530 and  NATIONAL SECURITY AGENCY, 9800 Savage Rd. Fort Meade, MD 20755 DEFENDANTS ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 1:14-cv-19
FIRST AMENDED COMPLAINT
THE PARTIES 1.
 
Plaintiff Ryan Noah Shapiro is a citizen of Massachusetts residing at , Cambridge, MA 02141. 2.
 
Plaintiff is a Ph.D. candidate in the Program in History, Anthropology, & Science, Technology, and Society (HASTS) at the Massachusetts Institute of Technology. Plaintiff is an historian of the political functioning of national security and the policing of dissent.
 
 2 3.
 
Plaintiff seeks access to certain public records to write popular news and/or scholarly articles for distribution to the academic and general public. His connections and relationships with a wide range of domestic and international media organizations will ensure that any story he drafts based on the information contained in these documents will be published and reprinted. 4.
 
Defendant Central Intelligence Agency (CIA) is an agency of the United States. 5.
 
The CIA has possession, custody and control of the records Plaintiff sought from the CIA in his FOIA request to that agency. 6.
 
Defendant Department of Defense (DOD) is an agency of the United States. 7.
 
The Defense Intelligence Agency (DIA) is a component of the DOD. 8.
 
The DIA has possession, custody and control of the records Plaintiff sought from the DIA in his FOIA request to that component. 9.
 
Defendant Department of Justice (DOJ) is an agency of the United States. 10.
 
The Federal Bureau of Investigation (FBI) is a component of the DOJ. 11.
 
The FBI has possession, custody and control of the records Plaintiff sought from the FBI in his FOIA request to that component. 12.
 
Defendant National Security Agency (NSA) is an agency of the United States. 13.
 
The NSA has possession, custody and control of the records Plaintiff sought from the NSA in his FOIA request to that agency. JURISDICTION AND VENUE 14.
 
This action arises under the Freedom of Information Act (“FOIA”)
, 5 USC § 552. 15.
 
This Court has jurisdiction over the parties and subject matter pursuant to 5 USC § 552(a)(4)(B).
 
 3 16.
 
Venue is proper in this district pursuant to 5 USC § 552(a)(4)(B). STATEMENT OF FACTS
BACKGROUND
17.
 
Plaintiff’s FOIA requests pertain to
Rolihlahla Mandela, a/k/a Nelson Mandela, a/k/a Madiba, a/k/a Tata. Mandela (July 18, 1918 to December 5, 2013) was a South African anti-apartheid revolutionary and politician who served over 27 years in prison for his activism  prior to becoming
South Africa’s first black president
 following his release from prison in 1990. Among numerous other awards, Mandela was the recipient of the Nobel Peace Prize and the U.S. Presidential Medal of Freedom. 18.
 
The CIA was reportedly involved in Mandela’s 1962 arrest that led to his
decades-long incarceration. Mandela was denounced by his critics, including numerous leading U.S. conservative politicians and pundits, as a Marxist terrorist. 19.
 
Though the U.S. intelligence community is long believed to have been involved in
Mandela’s arrest, little specific public information exists regarding this involvement.
Similarly, though the U.S. intelligence community is long understood to have routinely provided information to the South African regime regarding the anti-apartheid movement more broadly, little specific public information exists about these activities either. Further, despite now being universally hailed as a hero and freedom fighter against gross injustice, Mandela was designated a terrorist by the United States government and remained on the U.S. terror watch list until 2008. 20.
 
Plaintiff anticipates that the records to which he seeks access will begin to answer the following questions: What was the extent and purpose of the U.S.
intelligence community’s

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