16.
Venue is proper in this district pursuant to 5 USC § 552(a)(4)(B).
STATEMENT OF FACTS BACKGROUND
17.
Plaintiff’s FOIA requests pertain to Rolihlahla Mandela, a/k/a Nelson Mandela,
a/k/a Madiba, a/k/a Tata. Mandela (July 18, 1918 to December 5, 2013) was a South African anti-apartheid revolutionary and politician who served over 27 years in prison for his activism prior to becoming South Africa’s first black president following his release from prison in 1990. Among numerous other awards, Mandela was the recipient of the Nobel Peace Prize and the U.S. Presidential Medal of Freedom. 18.
The CIA was reportedly involved in Mandela’s 1962 arrest that led to his
decades-long incarceration. Mandela was denounced by his critics, including numerous leading U.S. conservative politicians and pundits, as a Marxist terrorist. 19.
Though the U.S. intelligence community is long believed to have been involved in
Mandela’s arrest, little specific public information exists regarding this involvement. Similarly, though the U.S. intelligence community is long understood to have routinely provided information to the South African regime regarding the anti-apartheid movement more broadly, little specific public information exists about these activities either. Further, despite now being universally hailed as a hero and freedom fighter against gross injustice, Mandela was designated a terrorist by the United States government and remained on the U.S. terror watch list until 2008. 20.
Plaintiff anticipates that the records to which he seeks access will begin to answer
the following questions: What was the extent and purpose of the U.S. intelligence community’s 3