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Aero Nox, Plaintiff
v.
Ministry of Urban Development, Defendant
v.
Ministry of Urban Development, Defendant
Complaint
The Ministry of Urban Development has been willfully negligent in its duty to respond to a lawful freedom of information (FOI) request.Parties:
- Plaintiff: Aero Nox
- Defendant: Ministry of Urban Development
Factual Allegations:
(All dates and time are in Eastern Daylight Time, which is UTC-4.)1. On April 26, 2026, Plaintiff opened an FOI request with the Ministry of Urban Development. (Exhibit P-001)
2. The FOI request asked two simple questions, limited in scope to the month of April 2026.
a) How many industrial property owners have been charged by MUD?
b) How many industrial property owners have been fined by MUD?
3. The Minister of Urban Development, Octavian Russel, classified the information as Public Information. (Exhibit P-001)
4. Minister Octavian Russel then provided incorrect answers to both questions. (Exhibit P-001)
5. When confronted with this fact, Minister Russel failed to provide correct the record and instead, simply closed the ticket. (Exhibit P-001)
Legal Claims:
I. Violation of the Freedom of Information Act (FOIA)A. The Responding Office closed the ticket on April 26, 2026 without producing complete and accurate answers, and without explaining any lawful basis for withholding as required by the FOIA Petition Process (FOIA §§4(b)–(d)).
Prayer for Relief:
1. A court order compelling the Ministry of Urban Development to accurately and fully answer the questions presented in Plaintiff's FOI request;
2. Award damages under FOIA §6(a) in an amount to be determined at trial (up to $10,000) or statutory damages for untimely response (up to $1,000);
3. Award costs, reasonable attorneys’ fees, and such further relief as the Court deems just and proper.
Verification:
I, Aero Nox, hereby affirm that the allegations in the complaint AND all subsequent statements made in court are true and correct to the best of the plaintiff's knowledge, information, and belief and that any falsehoods may bring the penalty of perjury.Evidence
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