WaPo FOIA For Spending at Trump Properties

Case 1:20-cv-01487 Document 1 Filed 06/05/20 Page 1 of 17
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
WP COMPANY LLC
d/b/a THE WASHINGTON POST,
1301 K Street NW
Washington, DC 20071
Plaintiff,
v. Case No. 20-cv-1487
U.S. DEPARTMENT OF
HOMELAND SECURITY,
2707 Martin Luther King Jr. Ave. SE
Washington, DC 20528-0485
U.S. DEPARTMENT OF STATE,
2201 C Street NW
Defendants.
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
Plaintiff WP Company LLC d/b/a The Washington Post (“the Post”) brings this suit against
Defendants the U.S. Department of Homeland Security (“DHS”) and the U.S. Department of State
(the “State Department”). In support thereof, the Post states as follows:
INTRODUCTION
1. This is an action brought pursuant to the Freedom of Information Act (“FOIA”),
5 U.S.C. § 552, for declaratory, injunctive, and other appropriate relief. Through FOIA, the Post
sought from Defendants records relating to payments that the Defendants have made since
January 2017 to provide security or any other services to President Trump and his companions
during trips to certain properties owned by the Trump Organization or other corporate entities
under the control of the President or his family.

2. The requested records will let the public see “what their government [has been] up
to,” DOJ v. Reporters Comm. for Freedom of Press, 489 U.S. 749, 773 (1989), with respect to
how much businesses owned by the President or his family, including the Trump Organization,
have charged the Defendants – and thus, American taxpayers – to house the officials and agents
who accompany and protect the President when he travels.
3. DHS has improperly withheld all records responsive to a total of eleven FOIA
requests that the Post submitted over the past two years.
4. The State Department has improperly withheld all records responsive to a total of
eight FOIA requests that the Post submitted over the past three months.
PARTIES
5. Plaintiff, the Post, is a news organization based in Washington, D.C. It publishes
the leading daily newspaper, by print circulation, in the nation’s capital, as well as the website
washingtonpost.com, which typically reaches an audience of more than 80 million unique
visitors per month, according to independent auditor comScore. Since 1936, the Post has won 69
Pulitzer Prizes.
6. Defendant, DHS, is an agency within the meaning of 5 U.S.C. § 552(f)(1). Its
components include the Secret Service, which is responsible for protecting, among others, the
President and his immediate family members. 18 U.S.C. § 3056(a)(1)-(2). DHS has possession
and control of records requested by the Post.
7. Defendant, the State Department, is an agency within the meaning of 5 U.S.C.
§ 552(f)(1). The State Department has possession and control of records requested by the Post.
JURISDICTION AND VENUE
8. This action arises under FOIA. This Court has subject matter jurisdiction over this
action and personal jurisdiction over the parties pursuant to 5 U.S.C. § 552(a)(4)(B) & (a)(6)(C)(i).
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This Court also has jurisdiction over this action pursuant to 28 U.S.C. § 1331.
9. Venue is proper in this judicial district under 5 U.S.C. § 552(a)(4)(B).
FACTUAL ALLEGATIONS
I. The Post’s Reporting
10. According to the Post’s reporting, President Trump has visited properties owned
by his private company, the Trump Organization, on more than 350 days since January 2017.
David A. Fahrenthold, What President Trump’s company charges the Secret Service, The
Washington Post (Mar. 5, 2020), https://www.washingtonpost.com/graphics/2020/politics/trump-
secret-service-spending/.
11. Those properties include the Mar-a-Lago Club (“Mar-a-Lago”) in Palm Beach,
Florida, which President Trump has called the “Winter White House,” and the Trump National
Golf Club (“Trump National”) in Bedminster, New Jersey, which “people in the Trump
administration have referred to as ‘the summer White House.’” See Donald J. Trump, (Nov. 22,
2017), https://twitter.com/realDonaldTrump/status/933301876975718401; Laura M. Holson, At
the “Summer White House,” You Are Never Far From a Trump Photo, N.Y. Times (June 3,
2017), https://www.nytimes.com/2017/06/03/style/president-trump-national-golf-club-
bedminster-summer-white-house.html.
12. Trump Organization Executive Vice President Eric Trump has stated that Secret
Service agents and other government officials traveling with the President “stay at our properties
for free” – charging only for things “like housekeeping,” and that “it saves a fortune” for the
President to stay at Trump Organization properties “because if they were to go to a hotel across
the street, they’d be charging them $500 a night, whereas, you know we charge them, like $50.”
Adam Shapiro, G-7 at Trump golf resort saves the US money: Eric Trump, Yahoo Finance (Oct.
3
17, 2019), https://finance.yahoo.com/news/g-7-at-trump-golf-resort-saves-the-us-money-eric-
trump-192655739.html.
13. As the Post has reported, however, government documents previously disclosed
pursuant to FOIA requests show that the Secret Service has paid as much as $650 per night for
hotel rooms at Mar-a-Lago, and as much as $17,000 per month for use of a cottage at Trump
National. David A. Fahrenthold, et al., Secret Service has paid rates as high as $650 a night for
rooms at Trump’s properties, The Washington Post (Feb. 7, 2020),
https://www.washingtonpost.com/politics/secret-service-has-paid-rates-as-high-as-650-a-night-
for-rooms-at-trumps-properties/2020/02/06/7f27a7c6-3ec5-11ea-8872-5df698785a4e_story.html.
14. According to the Post’s reporting, government documents previously disclosed
pursuant to FOIA requests also revealed that the State Department has paid as much as $546 per
night for a hotel room at Mar-a-Lago. David A. Fahrenthold & Joshua Partlow, Trump’s
company has received at least $970,000 from U.S. taxpayers for room rentals, The Washington
Post (May 14, 2020), https://www.washingtonpost.com/politics/trumps-company-has-received-
at-least-970000-from-us-taxpayers-for-room-rentals/2020/05/14/26d27862-916d-11ea-9e23-
6914ee410a5f_story.html.
15. According to the Post’s reporting and government records previously disclosed
pursuant to FOIA requests, the State Department received a bill for $1,005.60 from Mar-a-Lago
after White House aides “asked the bartender to leave” and proceeded to serve themselves
drinks. David A. Fahrenthold, et al., When Trump visits his clubs, government agencies and
Republicans pay to be where he is, The Washington Post (June 20, 2019),
https://www.washingtonpost.com/politics/when-trump-visits-his-clubs-government-agencies-
and-republicans-pay-to-be-where-he-is/2019/06/20/a4c13c36-8ed0-11e9-adf3-
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f70f78c156e8_story.html.
16. According to the Post’s reporting and the government records previously
disclosed pursuant to FOIA requests, the Secret Service paid the Trump Organization more than
$471,000 between January 2017 and April 2018.
17. Most of the DHS records in the Post’s reporting were disclosed only after the
FOIA requesters, Judicial Watch and Property of the People, were forced to file lawsuits to
compel the agency to meet its statutory obligations under FOIA. See Joint Status Report,
Property of the People, Inc. v. DHS, No. 18-cv-1045-KBJ (D.D.C. May 3, 2019), ECF 14;
Stipulation of Dismissal, Judicial Watch, Inc. v. DHS, No. 18-cv-1851-RLJ (D.D.C. Nov. 15,
2018), ECF 12; Stipulation of Dismissal, Judicial Watch, Inc. v. DHS, No. 18-cv-161-TJK
(D.D.C. Mar. 27, 2018), ECF 7.
18. Judicial Watch sued DHS only after the agency failed to produce any records in
response to a total of 21 separate FOIA requests. See Compl., Judicial Watch, Inc. v. DHS, No.
18-cv-1851-RLJ (D.D.C. Aug. 7, 2018), ECF 1; Compl., Judicial Watch, Inc. v. DHS, No. 18-cv-
161-TJK (D.D.C. Jan. 25, 2018), ECF 1.
II. The Post’s FOIA Requests To DHS
19. The Post made eleven of the nineteen FOIA requests at issue in this matter to
DHS (the “DHS Requests”) between September 11, 2018, and March 6, 2020, seeking records
relating to payments that the Secret Service has made to the Trump Organization and related
entities. Each DHS Request was limited to specified trips or properties, as detailed below:
20. On September 11, 2018, the Post submitted a FOIA request to DHS seeking any
records detailing money spent by the Secret Service related to travel by Eric Trump to Scotland,
from January 17, 2017 to June 30, 2018. DHS assigned the request handling number 20181416.
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A true and correct copy of DHS’s acknowledgment letter in response to this request is attached
hereto as Exhibit A.
records detailing Secret Service expenditures related to a trip by Eric Trump to Scotland in July
2018. DHS assigned the request handling number 20181415. A true and correct copy of DHS’s
acknowledgment letter in response to this request is attached hereto as Exhibit B.
records detailing Secret Service expenditures related to a trip by Eric Trump to Ireland in July
2018. DHS assigned the request handling number 20181414. A true and correct copy of DHS’s
acknowledgment letter in response to this request is attached hereto as Exhibit C.
23. On February 4, 2020, the Post submitted a FOIA request to DHS seeking records
concerning the use of taxpayer funds to provide security or any other services to President
Trump and any companions during a trip to Doral, Florida on June 18, 2019 and June 19, 2019.1
DHS assigned the request handling number 20200453. A true and correct copy of this request is
attached hereto as Exhibit D.
24. On February 4, 2020, the Post submitted a FOIA request to DHS seeking records
concerning the use of taxpayer funds to provide security or any other services to President
Trump and any companions during a trip to Doral, Florida on January 23, 2020. DHS assigned
the request handling number 20200457. A true and correct copy of this request is attached
hereto as Exhibit E.
25. On February 5, 2020, the Post submitted a FOIA request to DHS seeking receipts,
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The Trump National Doral Miami is located in Doral, Florida. See
https://www.trump.com/hotels/trump-national-doral-miami.
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invoices, or other records documenting payments by the Secret Service to the Trump
International Hotel in Las Vegas, Nevada on March 3, 2017 (payment of $5,240) and March 17,
2017 (payment of $40,366). DHS assigned the request handling number 20200465. A true and
correct copy of this request is attached hereto as Exhibit F.
26. On February 5, 2020, the Post submitted a FOIA request to DHS seeking receipts,
invoices or other records documenting payments by the Secret Service’s Washington Field
Office to the Trump International Hotel in Washington, D.C. on the following dates:
(i) September 19, 2016 (payments of $1,500 and $10,850); (ii) October 10, 2016 (payment of
$4,422); (iii) October 28, 2016 (payments of $5,829 and $3,750); (iv) December 21, 2016
(payment of $2,984); (v) December 22, 2016 (payment of $5,332); (vi) March 15, 2017
(payment of $3,096); (vii) March 27, 2017 (payment of $1,976); (viii) April 17, 2017 (payments
of $1,976 and $1,884); (ix) May 26, 2017 (payments of $2,052 and $1,580); (x) June 13, 2017
(payment of $14,900); (xi) June 19, 2017 (payments of $3,160 and $1,100); (xii) June 28, 2017
(Payments of $33,638 and $1,863); (xiii) July 17, 2017 (Payment of $11,475); (xiv) July 21,
2017 (Payment of $1,635); (xv) August 4, 2017 (Payment of $4,932); (xvi) September 7, 2017
(Payment of $2,666); (xvii) September 8, 2017 (Payment of $640); (xviii) September 18, 2017
(Payment of $9,272); (xix) October 30, 2017 (Payment of $2,500); (xx) December 8, 2017
(Payments of $2,973 and $402); (xxi) December 13, 2017 (Payments of $8,118 and $3,888); and
(xxii) January 31, 2018 (Payments of $3,006 and $7,418). DHS assigned the request handling
number 20200468. A true and correct copy of this request is attached hereto as Exhibit G.
27. On February 20, 2020, the Post submitted a FOIA request to DHS seeking
“Approved Travel Expense Information” forms produced since January 1, 2017, which contain
any of the following words or phrases in the “Vendor” field: (i) “Trump National Golf Club”;
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(ii) “Trump Natl Golf Club”; (iii) “Trump Intl Hotel”; (iv) “Trump International Hotel”;
(v) “Trump Hotel”; (vi) “Trump Hotel Las Vegas”; (vii) “Mar-a-Lago Club”; (viii) “Mar a
Lago”; and (ix) “MaraLago.” DHS assigned the request handling number 20200527. A true and
correct copy of this request is attached hereto as Exhibit H.
28. On February 20, 2020, the Post submitted a FOIA request to DHS seeking
invoices, receipts, or “Housing Summary” documents produced or received by the Secret Service
since January 1, 2017 that include any of the following phrases: (i) “Sarazen Cottage”;
(ii) “Serazen Cottage”; (iii) “Saracen Cottage”; and (iv) “Trump National Golf Club
Bedminster.” DHS assigned the request handling number 20200528. A true and correct copy of
this request is attached hereto as Exhibit I.
29. On February 25, 2020, the Post submitted three separate FOIA requests to DHS
seeking three categories of records: (i) invoices, receipts, “housing summary” documents, or e-
mails describing rentals of a home at 1125 South Ocean Boulevard, Palm Beach, Florida since
January 1, 2017, or otherwise referencing the home’s owner, 1125 South Ocean LLC; (ii)
invoices, receipts, “housing summary” documents, or e-mails describing rentals of a home at 124
Woodbridge Road, Palm Beach, Florida since January 1, 2017, or otherwise referencing the
home’s owner, DTW Venture LLC; and (iii) invoices, receipts, “housing summary” documents,
or e-mails describing rentals of a home at 1094 S. Ocean Boulevard, Palm Beach, Florida since
January 1, 2017, or otherwise referencing the house’s alternate address, “1094 Woodbridge,” or
the home’s owner, DT Venture l LLC. DHS combined the three requests and assigned them all
handling number 20200545. A true and correct copy of each request is attached hereto as
Exhibit J.
30. On March 6, 2020, the Post submitted a FOIA request to DHS seeking copies of
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any Secret Service “Foreign Protective Travel Cost Tracking Worksheets” that pertain to the
following foreign visits of President Trump, Donald Trump Jr., Eric Trump, Ivanka Trump, or
Tiffany Trump to Trump Organization properties or related business travel overseas:
(i) Weekend of December 2-4, 2016. Location of visit: Trump Turnberry, Scotland. Protectee:
Eric Trump; (ii) Week of January 1-7, 2017. Location of visit: Punta del Este, Uruguay.
Protectee: Eric Trump; (iii) Weekend of February 17-19, 2017. Location of visit: Dubai, United
Arab Emirates (Trump International Golf Club Dubai). Protectees: Donald Trump Jr. and Eric
Trump; (iv) Week of February 26 - March 4, 2017. Location of visit: Vancouver, Canada (Trump
International Hotel and Tower Vancouver). Protectees: Donald Trump Jr. and Eric Trump and
Tiffany Trump; (v) Week of April 9-15, 2017. Location of visit: Doonbeg, Ireland. (Trump
International Golf Links and Hotel Doonbeg). Protectee: Eric Trump; (vi) Week of April 9-15,
2017. Location of visit: Trump Turnberry, Scotland. Protectee: Eric Trump; (vii) Week of April
9-15, 2017. Location of visit: Doonbeg, Ireland (Trump International Golf Links and Hotel
Doonbeg). Protectee: Eric Trump; (viii) Week of June 25-July 1, 2017. Location of visit: Trump
Turnberry, Scotland. Protectee: Eric Trump; (ix) Week of June 25-July 1, 2017. Location of
visit: Aberdeen, Scotland. (Trump International Golf Links Scotland). Protectee: Eric Trump; (x)
Week of August 4-10, 2017. Location of visit: Doonbeg, Ireland. (Trump International Golf
Links and Hotel Doonbeg). Protectee: Eric Trump; (xi) Month of August 2017. Location of visit:
Vancouver, Canada. (Trump International Hotel and Tower Vancouver.) Protectee: Donald
Trump Jr.; (xii) Week of Oct 20, 2017. Location of visit: Aberdeen, Scotland. (Trump
International Golf Links Scotland). Protectee: Eric Trump; (xiii) Week of January 1-6, 2018.
Location of visit: Punta del Este, Uruguay. Protectee: Eric Trump; (xiv) Weekend of January 6-
8, 2018. Location of visit: Trump Turnberry, Scotland. Protectee: Eric Trump; (xv) Week of
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February 4-10, 2018. Location of visit: Aberdeen, Scotland. (Trump International Golf Links
Scotland). Protectee: Eric Trump; (xvi) Week of February 25-March 3, 2018. Location of visit:
Doonbeg, Ireland. (Trump International Golf Links and Hotel Doonbeg). Protectee: Eric Trump;
(xvii) Week of March 4-10, 2018. Location of visit: Aberdeen, Scotland. (Trump International
Golf Links Scotland). Protectee: Eric Trump; (xviii) Week of April 1-7, 2018. Location of visit:
Dubai, United Arab Emirates (Trump International Golf Club Dubai). Protectees: Donald Trump
Jr. and Eric Trump; (xix) Week of April 15-21, 2018. Location of visit: Trump Turnberry,
Scotland. Protectee: Eric Trump; (xx) Week of April 29-May 5, 2018. Location of visit:
Aberdeen, Scotland. (Trump International Golf Links Scotland.) Protectee: Eric Trump; (xxi)
Week of June 10-16, 2018. Location of visit: Aberdeen, Scotland. (Trump International Golf
Links Scotland.) Protectee: Eric Trump; (xxii) Between June 24 and July 3, 2018. Location of
visit: Doonbeg, Ireland. (Trump International Golf Links and Hotel Doonbeg). Protectee: Eric
Trump; (xxiii) July 13-15, 2018. Location of visit: Trump Turnberry. Protectee: President
Donald Trump; (xxiv) Weeks of July 8-21, 2018. Location of visit. Aberdeen, Scotland. (Trump
International Golf Links Scotland). Protectee: Eric Trump and Donald Trump Jr. Location of
visit: Trump Turnberry, Scotland. Protectee: Eric Trump and Donald Trump Jr.; (xxv) Week of
July 29-Aug 4, 2018. Location of visit: Trump Turnberry, Scotland. Protectee: Eric Trump;
(xxvi) Week of August 12-18, 2018. Location of visit: Trump Turnberry, Scotland. Protectee:
Eric Trump; (xxvii) Week of January 6-12, 2019. Location of visit: Punta del Este, Uruguay.
Protectee: Eric Trump; (xxviii) Weeks of March 3-16, 2019. Location of visit: Trump Turnberry,
Scotland. Protectee: Eric Trump; (xxix) Week of April 21-17, 2019. Location of visit: Aberdeen,
Scotland. (Trump International Golf Links Scotland). Protectee: Eric Trump; (xxx) Weeks of
May 12-25, 2019. Location of visit: Trump Turnberry, Scotland. And Aberdeen, Scotland
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(Trump International Golf Links Scotland). Protectee: Eric Trump; (xxxi) June 5-7, 2019.
Location of visit: Doonbeg, Ireland. (Trump International Golf Links and Hotel Doonbeg).
Protectee: President Donald Trump; (xxxii) Week of August 11-17, 2019. Location of visit:
Jakarta, Indonesia. Protectee: Donald Trump Jr.; (xxxiii) Week of Sept 22-28, 2019. Location of
visit: Aberdeen, Scotland. (Trump International Golf Links Scotland). Protectee: Eric Trump;
(xxxiv) Week of February 2-8, 2020. Location of visit: Trump Turnberry, Scotland. Protectee:
Eric Trump; (xxxv) Week of February 23-29, 2020. Location of visit: Trump Turnberry,
Scotland. Protectee: Eric Trump; and (xxxvi) February 15-29, 2020. Location of visit: St. Martin.
(Le Chateau des Palmiers). Protectee: Eric Trump. DHS assigned the request handling number
20200585. A true and correct copy of this request is attached hereto as Exhibit K.
31. To date, DHS has not produced a single record responsive to any of the DHS
Requests.
32. To date, DHS has not informed the Post as to the scope of the records that the
agency will produce in response to any of the DHS Requests or provided any sort of timetable
for such production.
33. To date, DHS has not informed the Post as to the scope of responsive records that
the agency will withhold pursuant to any FOIA exemption(s).
III. The Post’s FOIA Requests To The State Department
34. The Post made the other eight FOIA requests at issue in this matter to the State
Department (the “State Department Requests”) in February 2020, seeking records relating to
payments that the State Department has made to the Trump Organization or related entities.
Each State Department Request was limited to specified properties, as detailed below:
35. On February 5, 2020, the Post submitted a FOIA request to the State Department
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seeking any invoices, receipts or other documents describing payments by the State Department
related to the Trump Turnberry hotel and golf club in South Ayrshire, Scotland, from January 1,
2017 to the present. The State Department assigned the request handling number F-2020-03473.
A true and correct copy of this request is attached hereto as Exhibit L.
related to the Trump International Golf Links Doonbeg in County Clare, Ireland, from January 1,
2017 to the present. The State Department assigned the request handling number F-2020-03644.
A true and correct copy of this request is attached hereto as Exhibit M.
related to the Trump Towers Istanbul in Istanbul, Turkey, from January 1, 2017 to the present.
The State Department assigned the request handling number F-2020-03646. A true and correct
copy of this request is attached hereto as Exhibit N.
related to the Trump Tower at Century City Makati, Philippines, from January 1, 2017 to the
present. The State Department assigned the request handling number F-2020-03648. A true and
correct copy of this request is attached hereto as Exhibit O.
related to the Trump International Golf Club Dubai, United Arab Emirates, from January 1, 2017
to the present. The State Department assigned the request handling number F-2020-03650. A
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true and correct copy of this request is attached hereto as Exhibit P.
related to the Trump International Hotel and Tower Vancouver in Canada, from January 1, 2017
to the present. The State Department assigned the request handling number F-2020-03652. A
true and correct copy of this request is attached hereto as Exhibit Q.
related to Trump World Seoul in South Korea, from January 1, 2017 to the present. The State
Department assigned the request handling number F-2020-03658. A true and correct copy of
this request is attached hereto as Exhibit R.
seeking any documents from the State Department’s Regional Financial Management System –
Disbursing Voucher Information Details forms where the vendor name is a Trump Organization
foreign property or domestic property from January 1, 2017 to February 21, 2020. The State
Department assigned the request handling number F-2020-04467. A true and correct copy of
this request is attached hereto as Exhibit S.
43. To date, the State Department has not produced a single record responsive to any
of the State Department Requests.
44. To date, the State Department has not informed the Post as to the scope of the
records that the agency will produce in response to any of the State Department Requests or
provided any sort of timetable for such production.
45. To date, the State Department has not informed the Post as to the scope of
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responsive records that the agency will withhold pursuant to any FOIA exemption(s).
CLAIMS FOR RELIEF
COUNT I
Declaratory and Injunctive Relief: Violation of FOIA, 5 U.S.C. § 552
(DHS)
46. The Post realleges and incorporates by reference all previous paragraphs as if
fully set forth herein.
47. FOIA provides this Court with “jurisdiction to enjoin [DHS] from withholding
agency records and to order the production of any agency records improperly withheld from [the
Post].” 5 U.S.C. § 552(a)(4)(B).
48. The records sought by the DHS Requests are agency records within DHS’s control.
49. FOIA requires that within 20 working days of receiving a FOIA request, an agency
must notify a requester of, inter alia, the scope of the documents that the agency will produce and
the scope of the documents that the agency plans to withhold under any FOIA exemptions.
See 5 U.S.C. § 552(a)(6)(A)(i).
50. DHS received the most recent of the DHS Requests on March 6, 2020. Ex. K.
51. Pursuant to FOIA, DHS was required to respond to the most recent of the DHS
Requests by April 3, 2020. 5 U.S.C. § 552(a)(6)(A)(i).
52. To date, DHS has not made and communicated to the Post a “determination” on
any of the DHS Requests within the meaning of 5 U.S.C. § 552(a)(6)(A)(i).
53. There is no basis under FOIA to withhold, in whole or in part, the records requested
by the Post, particularly when substantially the same records covering different time periods were
produced after litigation. DHS has wrongfully withheld agency records in violation of FOIA.
54. The Post requests a declaratory judgment that DHS has violated FOIA and that the
Post is entitled to immediately receive the documents referenced above.
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55. The Post further requests that, pursuant to 5 U.S.C. § 552(a)(4)(B), the Court issue
an injunction directing DHS to produce all of the requested agency records in full and setting a
deadline for compliance.
COUNT II
Declaratory and Injunctive Relief: Violation of FOIA, 5 U.S.C. § 552
(State Department)
56. The Post realleges and incorporates by reference all previous paragraphs as if
fully set forth herein.
57. FOIA provides this Court with “jurisdiction to enjoin [the State Department] from
withholding agency records and to order the production of any agency records improperly withheld
from [the Post].” 5 U.S.C. § 552(a)(4)(B).
58. The records sought by the State Department Requests are agency records within the
State Department’s control.
59. FOIA requires that within 20 working days of receiving a FOIA request, an agency
must notify a requester of, inter alia, the scope of the documents that the agency will produce and
the scope of the documents that the agency plans to withhold under any FOIA exemptions.
See 5 U.S.C. § 552(a)(6)(A)(i).
60. The State Department received the most recent of the State Department Requests
on February 21, 2020. Ex. S.
61. Pursuant to FOIA, the State Department was required to respond to the most recent
of the State Department Requests by March 20, 2020. 5 U.S.C. § 552(a)(6)(A)(i).
62. To date, the State Department has not made and communicated to the Post a
“determination” on any of the State Department Requests within the meaning of 5 U.S.C.
§ 552(a)(6)(A)(i).
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63. There is no basis under FOIA to withhold, in whole or in part, the records requested
by the Post. The State Department has wrongfully withheld agency records in violation of FOIA.
64. The Post requests a declaratory judgment that the State Department has violated
FOIA and that the Post is entitled to immediately receive the documents referenced above.
65. The Post further requests that, pursuant to 5 U.S.C. § 552(a)(4)(B), the Court issue
an injunction directing the State Department to produce all of the requested agency records in full
and setting a deadline for compliance.
REQUEST FOR RELIEF
WHEREFORE, the Post respectfully requests that this Court:
A. Declare Defendants’ failure to provide responsive records unlawful under FOIA;
B. Enter an injunction, pursuant to 5 U.S.C. § 552(a)(4)(B), directing Defendants to
make all requested records available to the Post, unredacted, and without further
delay, and setting a deadline for compliance;
C. Provide for expeditious proceedings in this action;
D. Award the Post its costs and reasonable attorneys’ fees incurred in this action
pursuant to 5 U.S.C. § 552(a)(4)(E); and
E. Grant such other and further relief as the Court may deem just and proper.
Dated: June 5, 2020 Respectfully submitted,
BALLARD SPAHR LLP
/s/ Charles D. Tobin

Charles D. Tobin (#455593)
Maxwell S. Mishkin (#1031356)
Kristel Tupja (admission pending)
1909 K Street, NW, 12th Floor
Telephone: (202) 661-2200
Fax: (202) 661-2299
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tobinc@ballardspahr.com
mishkinm@ballardspahr.com
tupjak@ballardspahr.com
Counsel for Plaintiff WP Company LLC

d/b/a The Washington Post
17
Case 1:20-cv-01487 Document 1-1 Filed 06/05/20 Page 1 of 2
Exhibit A
DEPARTMENT OF HOMELAND SECURITY

UNITED STATES SECRET SERVICE
WASHINGTON, D.C. 20223
Freedom of Information Act Program

Communications Center
245 Murray Lane, SW, Building T-5
Washington, D.C. 20223
Date: April 21, 2020
David Fahrenthold
1301 K Street, NW
Email: david.fahrenthold@washpost.com
File Number: 20181416
Dear Requester:
Reference is made to your Freedom of Information Act (FOIA) request, originally submitted to the
United States Secret Service (Secret Service) on September 11, 2018, for information pertaining to
any records detailing money spent by the Secret Service related to travel by Eric Trump to Scotland,
from January 17, 2017 to June 30, 2018.
In response to your FOIA request, the U.S. Secret Service FOIA Office has conducted a reasonable
search for all potentially responsive documents. The U.S. Secret Service FOIA Office searched all
Program Offices and computer systems that were likely to contain potentially responsive records,
and records were located.
We are processing the responsive records identified in connection with that search. They will be
processed in accordance with the Freedom of Information Act, 5 U.S.C. § 552 and mailed to you
upon completion.
As referenced in our initial response, due to the increasing number of FOIA requests received by
this office, we may encounter some delay in processing your request. However, we are processing
your request as expeditiously as possible.
Your request has been assigned FOIA File No. 20181416. If you have any questions, would like to
discuss this matter, or check the status of your request, please contact this office at (202) 406-6370.
Please refer to the file number indicated above in all correspondence with this office.
Thank you,
Freedom of Information Act Program

United States Secret Service
Phone: (202) 406-6370
Fax: (202) 406-5586
Email: FOIA@USSS.DHS.GOV
Exhibit B

Freedom of Information Act and Privacy Act Program

Date: July 1, 2019
David Fahrenthold
1301 K Street, NW
Dear Requester:
any records detailing Secret Service expenditures related to a trip by Eric Trump to Scotland in July
2018.
In response to your request, the Secret Service has conducted a reasonable search for responsive
documents. The Secret Service searched its main indices, and any responsive records identified in
connection with that search have been located and forwarded to this office for review and a
disclosure determination. They will be processed in accordance with the Freedom of Information
Act, 5 U.S.C. § 552, and mailed to you upon completion.
As referenced in our initial response, dated November 29, 2018, due to the increasing number of
FOIA requests received by this office, we may encounter some delay in processing your request.
However, we are processing your request as expeditiously as possible.
Thank you,
Freedom of Information Act & Privacy Act Program

Phone: (202) 406-6370
Fax: (202) 406-5586
Exhibit C

Freedom of Information Act and Privacy Act Program

Date: July 1, 2019
David Fahrenthold
1301 K Street, NW
Dear Requester:
any records detailing Secret Service expenditures related to a trip by Eric Trump to Ireland in July
2018.
In response to your request, the Secret Service has conducted a reasonable search for responsive
documents. The Secret Service searched its main indices, and any responsive records identified in
connection with that search have been located and forwarded to this office for review and a
disclosure determination. They will be processed in accordance with the Freedom of Information
Act, 5 U.S.C. § 552, and mailed to you upon completion.
As referenced in our initial response, dated November 29, 2018, due to the increasing number of
FOIA requests received by this office, we may encounter some delay in processing your request.
However, we are processing your request as expeditiously as possible.
Thank you,
Freedom of Information Act & Privacy Act Program

Phone: (202) 406-6370
Fax: (202) 406-5586
Exhibit D
1301 K STREET, N.W.

WASHINGTON, D.C. 20071-7403
(202) 334-6000
February 4, 2020
U.S. Secret Service
FOIA Officer
Fax: 202.406.5586
Email: FOIA@usss.dhs.gov
Re: EXPEDITED FOIA Request for U.S. Secret Service expenditures on
travel to Doral, Fla.
Dear Information Officer:
I am a representative of the Washington Post, a news media organization
primarily engaged in the dissemination of information that is urgently
needed to inform the public of actual or alleged Federal Government
activity. Because this request will show recent payments from the U.S.
government to a sitting president’s business – a government activity of
intense public interest -- it qualifies for expedited processing. I certify
that this information is true and correct to the best of my knowledge. (See
Al-Fayed v. C.I.A., 254 F.3d 300, 310 (D.C. Cir. 2001); Bloomberg, L.P. v.
U.S. Food & Drug Admin., 500 F.Supp.2d 371, 378 (S.D.N.Y. 2007).
Pursuant to the Freedom of Information Act (FOIA), I hereby request the
following:
Any and all records concerning the use of U.S. Government funds to
provide security and/or any other services to President Trump and any
companions on during a trips to Doral, Fla. on the following dates:
1.) June 18, 2019 to June 19, 2019.
Please note that this request is identical to previous requests made by

Judicial Watch about President Trump’s travel to Bedminster, N.J.
(including FOIAs #2017361, #20180081, #20172122), which the Secret
Service provided documents. The only difference is that this request seems
the same documents from later trips).
If you regard these documents as potentially exempt from the FOIA’s

disclosure requirements, I request that you nonetheless exercise your
discretion to disclose them. As the FOIA requires, please release all
segregable, non-exempt portions of documents. To permit me to reach an
intelligent and informed decision whether to file an administrative appeal of

any denied material, please describe any withheld records (or portions
thereof) and explain the basis for your exemption claims.
As required by the statute, please review whether there is any foreseeable
harm from disclosing the requested records, or if any potential harm would
be limited in comparison to the public interest in disclosure. As required by
the statute, please release all such information, even if it technically may fall
under a FOIA exemption.
As a representative of the news media, The Washington Post qualifies for
news media fee status under 5 U.S.C. § 552(a)(4)(A)(ii)(II) and, therefore,
may not be charged search and review fees. (See National Security Archive
v. U.S. Department of Defense, 880 F.2d 1381 (D.C. Cir. 1989), cert denied,
110 S Ct. 1478 (1990)). This request is made as part of a scholarly and news
research project that is intended for publication and is not for commercial
use. For details on the Post’s news reporting activities please see our
website at www.washingtonpost.com.
As you know, the FOIA prohibits agencies from charging news media
organizations duplication fees if the agency does not meet its twenty
working day time limit (thirty working days for “unusual” requests).
Additionally, because this information will be used by the Washington Post
for the preparation of news articles that will be broadly disseminated to the
general public, it will contribute significantly to public understanding of the
operations or activities of the government and is not primarily in the Post’s
commercial interest. As such, please grant a fee waiver for any remaining
fees incurred.
Please notify me before incurring any cost over $100.
To expedite the release of the requested documents, please disclose them on
an interim basis in electronic format as they become available to you,
without waiting until all the documents have been processed. If you have
any questions regarding my request, including its scope, please contact me
at fahrenthold@washpost.com, or by phone at 202.334.7550.
Sincerely,
David Fahrenthold
Washington Post
Exhibit E
1301 K STREET, N.W.

(202) 334-6000
February 4, 2020
U.S. Secret Service
FOIA Officer
Fax: 202.406.5586
Re: EXPEDITED FOIA Request for U.S. Secret Service expenditures on
travel to Doral, Fla.
intense public interest -- it qualifies for expedited processing. I certify
following:
Any and all records concerning the use of U.S. Government funds to
provide security and/or any other services to President Trump and any
companions on during a trips to Doral, Fla. on the following dates:
1. January 23, 2020
Please note that this request is identical to previous requests made by

Judicial Watch about President Trump’s travel to Bedminster, N.J.
(including FOIAs #2017361, #20180081, #20172122), which the Secret
Service provided documents. The only difference is that this request seeks
the same documents from trips to a different destination).


fees incurred.
Sincerely,
David Fahrenthold
Washington Post
Exhibit F
1301 K STREET, N.W.

(202) 334-6000
February 5, 2020
U.S. Secret Service
FOIA Officer
Fax: 202.406.5586
Re: EXPEDITED FOIA Request for U.S. Secret Service Washington Field
Office expenditures at Trump International Hotel, Las Vegas
immediate public interest -- it qualifies for expedited processing. I certify
following:
Any and all receipts, invoices or other records documenting payments by
the Secret Service to the Trump International Hotel in Las Vegas, NV on the
following dates.
1.) March 3, 2017 (Payment of $5,240)
2.) March 17, 2017 (Payment of $40,366)
The existence of these payments has already been acknowledged by the

Secret Service in response to FOIA# 20171774, released to Property of the
People late last year. I am attaching that FOIA return with this request. I am
seeking additional documentation about these payments, of the kind already
released by the Secret Service in regard to numerous payments made to the
Mar-a-Lago Club (one example is shown on the USSS FOIA Library
Webpage, FLORIDA_TRIPS_PART_2, pages 56-59, showing invoices and
bills from the Mar-a-Lago club). The Secret Service has also released
receipts and invoices about payments to Trump National, Bedminster, for
example in response to FOIAs #20180081, #20172359, and #20172122,
showing invoices/bills from Trump Bedminster.) I have attached an

example of those documents, as well. For the instances I listed above, I ask
for the same kind of documentation that the Secret Service has already
released in those previous cases.

fees incurred.
Sincerely,
David Fahrenthold
Washington Post
Exhibit G
1301 K STREET, N.W.

(202) 334-6000
February 5, 2020
U.S. Secret Service
FOIA Officer
Fax: 202.406.5586
Re: EXPEDITED FOIA Request for U.S. Secret Service Washington Field
Office expenditures at Trump International Hotel, D.C.
intense public interest -- it qualifies for expedited processing. I certify that
this information is true and correct to the best of my knowledge. (See Al-
Fayed v. C.I.A., 254 F.3d 300, 310 (D.C. Cir. 2001); Bloomberg, L.P. v. U.S.
Food & Drug Admin., 500 F.Supp.2d 371, 378 (S.D.N.Y. 2007).
following:
Any and all receipts, invoices or other records documenting payments by the
Secret Service’s Washington Field Office (WFO) to the Trump International
Hotel in Washington on the following dates.
1.) September 19, 2016 (Payments of $1,500 and $10,850)
2.) October 10, 2016 (Payment of $4,422)
3.) October 28, 2016 (Payments of $5,829 and $3,750)
4.) December 21, 2016 (Payment of $2,984)
5.) December 22, 2016 (Payment of $5,332)
6.) March 15, 2017 (Payment of $3,096)
7.) March 27, 2017 (Payment of $1,976)
8.) April 17, 2017 (Payments of $1,976 and $1,884)
9.) May 26, 2017 (Payments of $2,052 and $1,580)
10.) June 13, 2017 (Payment of $14,900)
11.) June 19, 2017 (Payments of $3,160 and $1,100)
12.) June 28, 2017 (Payments of $33,638 and $1,863)
13.) July 17, 2017 (Payment of $11,475)
14.) July 21, 2017 (Payment of $1,635)
15.) August 4, 2017 (Payment of $4,932)

16.) September 7, 2017 (Payment of $2,666)
17.) September 8, 2017 (Payment of $640)
18.) September 18, 2017 (Payment of $9,272)
19.) October 30, 2017 (Payment of $2,500)
20.) December 8, 2017 (Payments of $2,973 and $402)
21.) December 13, 2017 (Payments of $8,118 and $3,888)
22.) January 31, 2018 (Payments of $3,006 and $7,418)
The existence of these payments has already been acknowledged by the

Secret Service in response to FOIA#20200354, released to me earlier this
year. (I am attaching that FOIA release, for your reference). I am seeking
additional documentation about these payments, of the kind already released
by the Secret Service in regard to numerous payments made to the Mar-a-
Lago Club (one example is shown on the USSS FOIA Library Webpage,
FLORIDA_TRIPS_PART_2, pages 56-59, showing invoices and bills from
the Mar-a-Lago club). The Secret Service has also released receipts and
invoices about payments to Trump National, Bedminster, for example in
response to FOIAs #20180081, #20172359, and #20172122, showing
invoices/bills from Trump Bedminster.) I am also attaching the documents
released in #20172122, where the Trump Bedminster receipt is on page 12.
In the instances I listed above, I ask for the same kind of documentation that
the Secret Service has already released in those previous cases.

use. For details on the Post’s news reporting activities please see our website
at www.washingtonpost.com.
fees incurred.
any questions regarding my request, including its scope, please contact me at
fahrenthold@washpost.com, or by phone at 202.334.7550.
Sincerely,
David Fahrenthold
Washington Post
Exhibit H
1301 K STREET, N.W.

(202) 334-6000
February 20, 2020
U.S. Secret Service
FOIA Officer
Fax: 202.406.5586
Re: EXPEDITED FOIA Request for Approved Travel Expense Information
forms mentioning Trump properties
activity. This request qualifies for expedited processing because: 1)
knowledge of government payments to President Trump’s businesses is
a matter of current exigency to the American public; 2) delay in
releasing information about government payments to President
Trump’s businesses will compromise the recognized public interest in
being informed of federal spending directed to the president’s private
company; 3) the payments are
clearly federal government activity; and 4) there are credible claims,
including by the House Oversight Committee, that aspects of the
government’s payments to Trump businesses are improper. I certify that
Fayed v. C.I.A., 254 F.3d 300, 310 (D.C. Cir. 2001); Bloomberg, L.P. v.
U.S. Food & Drug Admin., 500 F.Supp.2d 371, 378
(S.D.N.Y. 2007).
following:
Any “Approved Travel Expense Information” forms produced since
January 1, 2017 which contain any of the following words or phrases in
the “Vendor” field:
1.) Trump National Golf Club
2.) Trump Natl Golf Club
3.) Trump Intl Hotel
4.) Trump International Hotel
5.) Trump Hotel
6.) Trump Hotel Las Vegas
7.) Mar-a-Lago Club
8.) Mar a Lago

9.) MaraLago
The existence of these records has already been acknowledged by the

Secret Service in response to FOIA#20170486, which was released to
the group Public Citizen earlier this year. I am seeking additional
records of the kind already released by the Secret Service in response to
that FOIA. I am attaching several Approved Travel Expense
Information forms released in that FOIA which show payments to
“Trump National Golf Club” in the vendor field.

fees incurred.

Sincerely,
David Fahrenthold
Washington Post
Exhibit I
1301 K STREET, N.W.

(202) 334-6000
February 20, 2020
U.S. Secret Service
FOIA Officer
Fax: 202.406.5586
Re: EXPEDITED FOIA Request for documents related to the Saracen
Cottage at Trump National Golf Club, Bedminster
(S.D.N.Y. 2007).
following:
Any invoices, receipts or “Housing Summary” documents produced or
received by the Secret Service since January 1, 2017 that include any of
the following phrases:
1.) “Sarazen Cottage”
2.) “Serazen Cottage”
3.) “Saracen Cottage”
4.) Trump National Golf Club Bedminster
The existence of such records has already been acknowledged by the

Secret Service in response to FOIAs by Judicial Watch (for example, in
response to FOIA#20180081) and by Public Citizen (FOIA #20170486).
I am seeking additional records of the same kind, covering the entire

period from January 1, 2017 to the present. For your reference, I am
attaching several invoices mentioning the Sarazen Cottage that were
provided to Public Citizen.
I made a similar request for documents in FOIA # 20200302, but in that

request I gave an incorrect name for the cottage in question: I called it
the “Sarazen Villa” instead of the Sarazen Cottage. I would ask that
your staff look through the materials gathered in response to that
FOIA, to see if any of them contain references to the cottage by its
correct name.

fees incurred.

Sincerely,
David Fahrenthold
Washington Post
Exhibit J
1301 K STREET, N.W.

(202) 334-6000
February 25, 2020
U.S. Secret Service
FOIA Officer
Fax: 202.406.5586
Re: EXPEDITED FOIA Request for documents relating to 1125 S. Ocean
Boulevard
(S.D.N.Y. 2007).
following:
Any invoices, receipts, “housing summary” documents or e-mails
describing rentals of a home at 1125 South Ocean Boulevard, Palm
Beach, Fla. since January 1, 2017. I also request that you search for
mentions of the home’s owner, 1125 South Ocean LLC.

fees incurred.
Sincerely,
David Fahrenthold
Washington Post
1301 K STREET, N.W.

(202) 334-6000
February 25, 2020
U.S. Secret Service
FOIA Officer
Fax: 202.406.5586
Re: EXPEDITED FOIA Request for documents relating to 124 Woodbridge
Road, Palm Beach, Fla.
(S.D.N.Y. 2007).
following:
describing rentals of a home at 124 Woodbridge Road, Palm Beach, Fla.
since January 1, 2017. I also request that you search for mentions of the
home’s owner, DTW Venture LLC.

fees incurred.
Sincerely,
David Fahrenthold
Washington Post
1301 K STREET, N.W.

(202) 334-6000
February 25, 2020
U.S. Secret Service
FOIA Officer
Fax: 202.406.5586
Re: EXPEDITED FOIA Request for documents to 1094 S. Ocean
Boulevard
(S.D.N.Y. 2007).
following:
describing rentals of a home at 1094 S. Ocean Boulevard, Palm Beach,
Fla. since January 1, 2017. I also request that you search for mentions of
the house’s alternate address, “1094 Woodbridge,” and for mentions of
the home’s owner, DT Venture I LLC.

fees incurred.
Sincerely,
David Fahrenthold
Washington Post
Exhibit K
Exhibit L
Tupja, Kristel (Phila)
From: Fahrenthold, David <David.Fahrenthold@washpost.com>

Sent: Friday, May 29, 2020 10:01 AM
To: Mishkin, Maxwell S. (DC); Tupja, Kristel (Phila)
Subject: Initial FOIA request letter for FOIA #F-2020-03473
⚠ EXTERNAL
From: Partlow, Joshua <Joshua.Partlow@washpost.com>

Sent: Thursday, May 28, 2020 3:20 PM
To: Fahrenthold, David <David.Fahrenthold@washpost.com>
Cc: Jones, Nate <Nate.Jones@washpost.com>
Subject: FW: FOIA Request Letter
Joshua Partlow
The Washington Post
Office: +1 202-334-8385
Cell/WhatsApp/Signal: +1 202-299-4580
From: State Department FOIA <noreply@mail.foia.state.gov>

Sent: Wednesday, February 05, 2020 5:04 PM
To: Partlow, Joshua <Joshua.Partlow@washpost.com>
Subject: FOIA Request Letter
CAUTION: EXTERNAL SENDER
Thank you for filing your FOIA request online on 2/5/2020. Here is a review of your request.
The records I request can be described as follows:
I request any invoices, receipts or other documents describing payments by the State Department to the Trump
Turnberry hotel and golf club in South Ayrshire, Scotland from January 1, 2017 to the present.
The time period of my request is from 01/01/2017 to 02/05/2020
I am a representative of the news media seeking information as part of a news gathering effort and not for commercial
use.
Additional documentation or comments will be required.
I represent Washington Post
I am willing to pay $25 for my request.

1
I request a waiver of all fees for this request.

Reason: Additionally, because this information will be used by the Washington Post for the preparation of news articles
that will be broadly disseminated to the general public, it will contribute significantly to public understanding of the
operations or activities of the government and is not primarily in the Post’s commercial interest. As such, please grant a
fee waiver for any remaining fees incurred.
I have a compelling need for expeditious handling:

- An urgency to inform the public concerning actual or alleged Federal Government activity exists.
This option available for ONLY PERSONS PRIMARILY ENGAGED IN DISSEMINATING INFORMATION.
- I am a representative of the Washington Post, a news media organization primarily engaged in the dissemination of
information that is urgently needed to inform the public of actual or alleged Federal Government activity. Because this
request may show payments from the federal government to a sitting president's business, it qualifies for expedited
processing. I certify that this information is true and correct to the best of my knowledge. (See Al-Fayed v. C.I.A., 254
F.3d 300, 310 (D.C. Cir. 2001); Bloomberg, L.P. v. U.S. Food & Drug Admin., 500 F.Supp.2d 371, 378 (S.D.N.Y. 2007). If you
regard these documents as potentially exempt from the FOIA’s disclosure requirements, I request that you nonetheless
exercise your discretion to disclose them. As the FOIA requires, please release all segregable, non-exempt portions of
documents. To permit me to reach an intelligent and informed decision whether to file an administrative appeal of any
denied material, please describe any withheld records (or portions thereof) and explain the basis for your exemption
claims. As required by the statute, please review whether there is any foreseeable harm from disclosing the requested
records, or if any potential harm would be limited in comparison to the public interest in disclosure. As required by the
statute, please release all such information, even if it technically may fall under a FOIA exemption. As a representative of
the news media, The Washington Post qualifies for news media fee status under 5 U.S.C. § 552(a)(4)(A)(ii)(II) and,
therefore, may not be charged search and review fees. (See National Security Archive v. U.S. Department of Defense,
880 F.2d 1381 (D.C. Cir. 1989), cert denied, 110 S Ct. 1478 (1990)). This request is made as part of a scholarly and news
research project that is intended for publication and is not for commercial use. For details on the Post’s news reporting
activities please see our website at www.washingtonpost.com. As you know, the FOIA prohibits agencies from charging
news media organizations duplication fees if the agency does not meet its twenty working day time limit (thirty working
days for “unusual” requests). Additionally, because this information will be used by the Washington Post for the
preparation of news articles that will be broadly disseminated to the general public, it will contribute significantly to
public understanding of the operations or activities of the government and is not primarily in the Post’s commercial
interest. As such, please grant a fee waiver for any remaining fees incurred. Please notify me before incurring any cost
over $100. To expedite the release of the requested documents, please disclose them on an interim basis in electronic
format as they become available to you, without waiting until all the documents have been processed. If you have any
questions regarding my request, including its scope, please contact me at joshua.partlow@washpost.com or 202-334-
8385 (office) or 202-299-4580 (cell).
My additional comments are as follows:
N/A
Contact Information
Mr. Joshua F Partlow
1301 K Street NW
Washington, District of Columbia 20071
P: 202-299-4580
F: N/A
joshua.partlow@washpost.com
2
Exhibit M

Sent: Monday, February 17, 2020 2:43 PM
International Golf Links and Hotel Doonbeg in County Clare, Ireland between Jan 1, 2017 and the present.
use.
I represent The Washington Post

1

Reason: s a representative of the news media, The Washington Post qualifies for news media fee status under 5 U.S.C. §
552(a)(4)(A)(ii)(II) and, therefore, may not be charged search and review fees. (See National Security Archive v. U.S.
Department of Defense, 880 F.2d 1381 (D.C. Cir. 1989), cert denied, 110 S Ct. 1478 (1990)). This request is made as part
of a scholarly and news research project that is intended for publication and is not for commercial use. For details on the
Post’s news reporting activities please see our website at www.washingtonpost.com. As you know, the FOIA prohibits
agencies from charging news media organizations duplication fees if the agency does not meet its twenty working day
time limit (thirty working days for “unusual” requests). Additionally, because this information will be used by the
Washington Post for the preparation of news articles that will be broadly disseminated to the general public, it will
contribute significantly to public understanding of the operations or activities of the government and is not primarily in
the Post’s commercial interest. As such, please grant a fee waiver for any remaining fees incurred. Please notify me
before incurring any cost over $100.

F.3d 300, 310 (D.C. Cir. 2001); Bloomberg, L.P. v. U.S. Food & Drug Admin., 500 F.Supp.2d 371, 378 (S.D.N.Y. 2007).
If you regard these documents as potentially exempt from the FOIA’s disclosure requirements, I request that you
nonetheless exercise your discretion to disclose them. As the FOIA requires, please release all segregable, non-exempt
portions of documents. To permit me to reach an intelligent and informed decision whether to file an administrative
appeal of any denied material, please describe any withheld records (or portions thereof) and explain the basis for your
exemption claims. As required by the statute, please review whether there is any foreseeable harm from disclosing the
requested records, or if any potential harm would be limited in comparison to the public interest in disclosure. As
required by the statute, please release all such information, even if it technically may fall under a FOIA exemption.
Contact Information
1301 K Street NW
P: 202-299-4580
F: N/A
2
Exhibit N

Any invoices, receipts or other documents describing payments by the State Department to the Trump Towers Istanbul
in Istanbul, Turkey between January 1, 2017 to the present.
use.

1

Reason: As a representative of the news media, The Washington Post qualifies for news media fee status under 5 U.S.C.
§ 552(a)(4)(A)(ii)(II) and, therefore, may not be charged search and review fees. (See National Security Archive v. U.S.
before incurring any cost over $100. To expedite the release of the requested documents, please disclose them on an
interim basis in electronic format as they become available to you, without waiting until all the documents have been
processed. If you have any questions regarding my request, including its scope, please contact me at
joshua.partlow@washpost.com or 202-334-8385 (office) or 202-299-4580 (cell).

Contact Information
1301 K Street NW
Washington , District of Columbia 20071
P: 202-299-4580
F: N/A
2
Exhibit O

I request any invoices, receipts or other documents describing payments by the State Department to the Trump Tower
at Century City Makati, Philippines between January 1, 2017 to the present.
I am affiliated with an educational or noncommercial scientific institution seeking information for a scholarly or scientific
purpose and not for commercial use.
Additional documentation will be required.
1

Contact Information
1301 K Street NW
P: 202-299-4580
F: N/A
2
Exhibit P

International Golf Club Dubai, United Arab Emirates, between January 1, 2017 to the present.
use.

1


Contact Information
1301 K Street NW
P: 202-299-4580
F: N/A
2
Exhibit Q

International Hotel and Tower Vancouver in Canada between January 1, 2017 to the present.
use.

1


Contact Information
1301 K Street NW
P: 202-299-4580
F: N/A
2
Exhibit R

I request any invoices, receipts or other documents describing payments by the State Department to Trump World Seoul
in South Korea between January 1, 2017 to the present.
use.

1


Contact Information
1301 K Street NW
Washington , District of Columbia 20071
P: 202-299-4580
F: N/A
2
Exhibit S
1301 K STREET, N.W.

(202) 334-6000
February 21, 2020
U. S. Department of State
Office of Information Programs and Services
2201 C Street N.W., Suite B266
Washington, D.C. 20520-0000
Re: EXPEDITED FOIA Request for spending records at Trump Turnberry
I am a representative of The Washington Post, a news media organization primarily

engaged in the dissemination of information that is urgently needed to inform the public
of actual or alleged Federal Government activity. This request qualifies for expedited
processing because: 1) knowledge of U.S. government spending at a sitting president’s
business is a matter of current exigency to the American public; 2) delay in releasing
information about such spending will compromise the recognized public interest in being
informed of the use of taxpayer funds; 3) State Department travel spending is clearly
federal government activity; and 4) there are credible claims, including in our previous
reporting, that aspects of the government’s activity, such as charging U.S. agencies at
elevated rates (i.e. charging the U.S. Secret Service $650 per night per room at Mar-a-
Lago, see: https://www.washingtonpost.com/politics/secret-service-has-paid-rates-as-
high-as-650-a-night-for-rooms-at-trumps-properties/2020/02/06/7f27a7c6-3ec5-11ea-
8872-5df698785a4e_story.html) is improper. I certify that this information is true and
correct to the best of my knowledge. (See Al-Fayed v. C.I.A., 254 F.3d 300, 310 (D.C.
Cir. 2001); Bloomberg, L.P. v. U.S. Food & Drug Admin., 500 F.Supp.2d 371, 378
(S.D.N.Y. 2007).
Pursuant to the Freedom of Information Act (FOIA), I hereby request the following:
I request copies of any documents from the State Department’s Regional Financial
Management System – Disbursing Voucher Information Details forms where the
vendor name is any of the following Trump Organization foreign properties:
1) Trump International Golf Links & Hotel Doonbeg (Ireland)

2) Trump Turnberry (Scotland)
3) Trump International Golf Links Scotland (Scotland)
4) Trump International Hotel & Tower Vancouver (Canada)
5) Trump Towers Istanbul (Turkey)
6) Trump International Golf Club Dubai (United Arab Emirates)
7) Trump Tower at Century City (Philippines)
8) Trump World Seoul (South Korea)
9) Trump Towers Delhi NCR (India)
10) Trump Tower Kolkata (India)
11) Trump Towers Pune (India)
12) Trump Tower Mumbai (India)

13) Trump International Hotel & Tower Panama (Panama)
Or domestic properties:
1) Trump International Hotel Washington (Washington DC)

2) Trump International Hotel and Tower New York (New York City)
3) Mar-a-Lago (Florida)
4) Trump National Golf Club Bedminster (New Jersey)
5) Trump National Golf Club Washington (Virginia)
6) Trump National Doral (Miami)
7) Trump International Hotel Las Vegas (Nevada)
8) Trump Winery/Albemarle Estate (Charlottesville, Va.)
9) Trump International Hotel & Tower Chicago (Illinois)
10) Trump International Hotel Waikiki (Hawaii)
11) Trump National Golf Club Los Angeles (California)
12) Trump Golf Links at Ferry Point (New York)
13) Trump National Golf Club Jupiter (Florida)
14) Trump International Golf Club West Palm Beach (Florida)
15) Trump National Golf Club Westchester (New York)
The timeline for this request is January 1, 2017 to February 21, 2020.
The State Department has already released some of these same forms for prior
FOIA requests, including a January 29, 2018 form where the vendor was Trump
International Golf Links & Hotel Doonbeg. A copy of that document is attached.
If you regard these documents as potentially exempt from the FOIA’s disclosure
requirements, I request that you nonetheless exercise your discretion to disclose them.
As the FOIA requires, please release all segregable, non-exempt portions of documents.
To permit me to reach an intelligent and informed decision whether to file an
administrative appeal of any denied material, please describe any withheld records (or
portions thereof) and explain the basis for your exemption claims.
As required by the statute, please review whether there is any foreseeable harm from
disclosing the requested records, or if any potential harm would be limited in comparison
to the public interest in disclosure. As required by the statute, please release all such
information, even if it technically may fall under a FOIA exemption.
As a representative of the news media, The Washington Post qualifies for news media fee
status under 5 U.S.C. § 552(a)(4)(A)(ii)(II) and, therefore, may not be charged search and
review fees. (See National Security Archive v. U.S. Department of Defense, 880 F.2d
1381 (D.C. Cir. 1989), cert denied, 110 S Ct. 1478 (1990)). This request is made as part
of a scholarly and news research project that is intended for publication and is not for
commercial use. For details on the Post’s news reporting activities please see our website
As you know, the FOIA prohibits agencies from charging news media organizations
duplication fees if the agency does not meet its twenty working day time limit (thirty
working days for “unusual” requests).
Additionally, because this information will be used by the Washington Post for the
preparation of news articles that will be broadly disseminated to the general public, it will
contribute significantly to public understanding of the operations or activities of the
government and is not primarily in the Post’s commercial interest. As such, please grant
a fee waiver for any remaining fees incurred.
To expedite the release of the requested documents, please disclose them on an interim
basis in electronic format as they become available to you, without waiting until all the
documents have been processed. If you have any questions regarding my request,
including its scope, please contact me at Joshua.partlow@washpost.com or +1 202 334
8385 (office) or +1 202 299 4580 (cell).
Sincerely,
Joshua Partlow
The Washington Post

1301 K Street NW
Washington DC 20071

WaPo FOIA For Spending at Trump Properties

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WaPo FOIA For Spending at Trump Properties

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Case 1:20-cv-01487 Document 1 Filed 06/05/20 Page 1 of 17

IN THE UNITED STATES DISTRICT COURT

v. Case No. 20-cv-1487

U.S. DEPARTMENT OF STATE,

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

(the “State Department”). In support thereof, the Post states as follows:

1. This is an action brought pursuant to the Freedom of Information Act (“FOIA”),

under the control of the President or his family.

who accompany and protect the President when he travels.

5. Plaintiff, the Post, is a news organization based in Washington, D.C. It publishes

washingtonpost.com, which typically reaches an audience of more than 80 million unique

6. Defendant, DHS, is an agency within the meaning of 5 U.S.C. § 552(f)(1). Its

and control of records requested by the Post.

7. Defendant, the State Department, is an agency within the meaning of 5 U.S.C.

JURISDICTION AND VENUE

9. Venue is proper in this judicial district under 5 U.S.C. § 552(a)(4)(B).

I. The Post’s Reporting

Washington Post (Mar. 5, 2020), https://www.washingtonpost.com/graphics/2020/politics/trump-

2017), https://twitter.com/realDonaldTrump/status/933301876975718401; Laura M. Holson, At

17, 2019), https://finance.yahoo.com/news/g-7-at-trump-golf-resort-saves-the-us-money-eric-

rooms at Trump’s properties, The Washington Post (Feb. 7, 2020),

14. According to the Post’s reporting, government documents previously disclosed

Post (May 14, 2020), https://www.washingtonpost.com/politics/trumps-company-has-received-

$471,000 between January 2017 and April 2018.

(D.D.C. Mar. 27, 2018), ECF 7.

161-TJK (D.D.C. Jan. 25, 2018), ECF 1.

II. The Post’s FOIA Requests To DHS

acknowledgment letter in response to this request is attached hereto as Exhibit B.

acknowledgment letter in response to this request is attached hereto as Exhibit C.

attached hereto as Exhibit D.

correct copy of this request is attached hereto as Exhibit F.

correct copy of this request is attached hereto as Exhibit H.

this request is attached hereto as Exhibit I.

Tiffany Trump to Trump Organization properties or related business travel overseas:

for such production.

the agency will withhold pursuant to any FOIA exemption(s).

III. The Post’s FOIA Requests To The State Department

A true and correct copy of this request is attached hereto as Exhibit L.

A true and correct copy of this request is attached hereto as Exhibit M.

copy of this request is attached hereto as Exhibit N.

correct copy of this request is attached hereto as Exhibit O.

true and correct copy of this request is attached hereto as Exhibit P.

true and correct copy of this request is attached hereto as Exhibit Q.

this request is attached hereto as Exhibit R.

this request is attached hereto as Exhibit S.

of the State Department Requests.

provided any sort of timetable for such production.

CLAIMS FOR RELIEF

fully set forth herein.

Post].” 5 U.S.C. § 552(a)(4)(B).

See 5 U.S.C. § 552(a)(6)(A)(i).

Requests by April 3, 2020. 5 U.S.C. § 552(a)(6)(A)(i).

any of the DHS Requests within the meaning of 5 U.S.C. § 552(a)(6)(A)(i).

Post is entitled to immediately receive the documents referenced above.

deadline for compliance.

fully set forth herein.

from [the Post].” 5 U.S.C. § 552(a)(4)(B).

State Department’s control.

See 5 U.S.C. § 552(a)(6)(A)(i).

on February 21, 2020. Ex. S.

of the State Department Requests by March 20, 2020. 5 U.S.C. § 552(a)(6)(A)(i).

and setting a deadline for compliance.

REQUEST FOR RELIEF