COMPLAINT TO COMPEL THE UNITED STATES SPECIAL OPERATIONS COMMAND TO RELEASE ALL DOCUMENTS RELATED TO THE INVESTIGATION OF PLAINTIFF AND TO PROTECT THE PLAINTIFF IN ACCORDANCE WITH THE WHISTLEBLOWER PROTECTION ACT
INTRODUCTION
1. This is an action under the Freedom of Information Act (FOIA), 5 U.S.C. § 552, challenging the United States Special Operations Command’s (USSOCOM), MacDill Air Force Base, Florida failure to respond to a request for public records by the Plaintiff. The records requested by Plaintiff involve USSOCOM’s Inspector General Report on the investigation of Colonel (Ret) Thomas F. Spellissy and his company Strategic Defense International, Inc. to include:
The interviews of Steven Featherman, Brad Mohr, LTC Wil Riggins, Captain Rowland Huss, Dr. Dale Uhler, LTC Donald Heilig and other interviewees not known.
A copy of the Inspector General Report on the investigation of LTC Donald Heilig, United States Army.
A copy of the Inspector General Report on the investigation of Captain Rowland Huss, United States Navy.
Plaintiff’s FOIA request seeks a copy of all internal agency documents related to the investigation of Plaintiff.
Plaintiff is conducting an investigation into War Profiteering by general officers assigned and formally assigned to the United States Special Operations Command. A war profiteer is any person or organization that improperly profits from warfare or by selling weapons and other goods to parties at war. General profiteering may also occur in peace time. The public can be deprived of its proper use of tax dollars when government officials knowingly profiteer with private contractors. Plaintiff also needs to be protected by the Whistleblower Protection Act to prevent any further adverse actions to be taken by the Defendant. The Whistleblower Protection Act (WPA) provides statutory protections for federal employees who engage in "whistleblowing," that is, making a disclosure evidencing illegal or improper government activities.
JURISDICTION
2.
This Court has jurisdiction over this action pursuant to 5 U.S.C. § 552 (a)(4)(B) (FOIA) and 28 U.S.C. § 1331 (federal question jurisdiction). This court also has jurisdiction for actions over 10 U.S.C. § 1034 and 31 U.S.C. § 3730(h).
3. Venue is properly before this District Court pursuant to 5 U.S.C. § 552 (a)(4)(B), 28 U.S.C. § 1391(e), 10 U.S.C. § 1034 and 31 U.S.C. § 3730(h).
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