Case 1:17-cv-03956-PGG Document1 Filed 05/25/17 Page 3 of 3 preferential treatment from authorities due to his wealth, connections, and political leverage. 11. The FBI has provided no response to Mr. Robertson’s request, nor even assigned it a tracking number. By failing to provide - or formally deny - documents within twenty working days, the FBI has constructively denied the request under 5 U.S. Code § 552(a)(6)(A)(i1). CAUSE OF ACTION Violation of the Freedom of Information Act for Wrongful Withholding of Agency Records 12. Plaintiff repeats and realleges paragraphs 1-11. 13. Defendant FBI has wrongfully withheld agency records requested by Plaintiff. 14. Plaintiff has exhausted all administrative remedies. REQUESTED RELIEF WHEREFORE, Plaintiff requests this Court: (A) Order defendant to provide access to the requested documents in their entirety; (B) Expedite this proceeding as provided for in 28 U.S.C. § 1657; (C) Award plaintiff costs and reasonable attorney fees in this action, as provided in 5 U.S.C. § 552(a)(4)(E); and (D) Grant such other and further relief as may deem just and proper. Dated: May 25, 2017 N on LV awa By Daniel Novack NY BAR ID: 5010863 Law Office of Daniel R. Novack 4 New York Plaza (2"¢ Floor) New York, NY 10004 Phone: (201) 213-1425 Email: [email protected] Counsel for Plaintiff 3 HOUSE_OVERSIGHT_029418