UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

____________________________________
CITIZENS FOR RESPONSIBILITY AND :
ETHICS IN WASHINGTON :
:
Plaintiff, :
:
v. : Civil Action No.
:
U.S. DEPARTMENT OF HOMELAND :
SECURITY :
:
Defendant. :
____________________________________:

PLAINTIFF’S MOTION FOR A PRELIMINARY INJUNCTION

Pursuant to Rule 65 of the Federal Rules of Civil Procedure, plaintiff Citizens for

Responsibility and Ethics in Washington (“CREW”) respectfully moves for the entry of a

preliminary injunction to enjoin defendant U.S. Department of Homeland Security’s (“DHS”)

unlawful refusal to process on an expedited basis CREW’s Freedom of Information Act

(“FOIA”) request seeking records of visits by health care industry executives to the White House

and the Vice President’s Residence. The records plaintiff seeks are created and maintained by

the Secret Service, an agency component of DHS. By this motion plaintiff seeks an order

requiring DHS to immediately process plaintiff’s FOIA request and disclose the requested

records within 10 days.

The grounds for this motion are set forth in the accompanying memorandum of points

and authorities. Plaintiff also asks the Court, pursuant to Local Rule 65.1(d), to schedule a

hearing on this application for a preliminary injunction at the Court’s earliest convenience.

Respectfully submitted,
 __________________________
Anne L. Weismann
(D.C. Bar No. 298190)
Melanie Sloan
(D.C. Bar No. 434584)
Citizens for Responsibility and Ethics
in Washington
1400 Eye Street, N.W., Suite 450
Washington, D. C. 20005
Telephone: 202-408-5565
Fax: 202-588-5020

July 22, 2009 Attorneys for Plaintiff