Whether a requester is entitled to compel a district court to enjoin an agency from withholding records and order production of improperly withheld records

QUESTIONS PRESENTED The following questions are presented for decision to the Court: | 1. Whether, pursuant to S.Ct.R. 11, see also 28 U.S. C. § 2101(e)!, upon | application for prejudgment relief, in “a case pending in a United | States court of appeals, before judgment is entered in that court”, a | requester, “deemed to have exhausted his administrative remedies | with respect to such request if the agency fails to comply with the | applicable time limit provisions,” in accordance with 5 U.S.C. § | 552(c)(i), is entitled, pursuant to 5 U.S.C. § 552(a)(4)(B), on complaint ) to “the district court of the United States in the district in which the | complainant resides” to compel that Court “to enjoin the agency from : withholding agency records and to order the production of any agency ! records improperly withheld from the complainant”, so as to remedy : a derogation of his rights to equal protection and due process, as well | as a right to redress of grievances, substantive right, irreparably : harmed. 2. Whether, pursuant to S.Ct.R. 11, see also 28 U.S. C. § 2101(e), “upon application for prejudgment relief, in “a case pending in a United | | States court of appeals, before judgment is entered in that court”, | : where, in accordance with Fed.R.Civ.Pro. 56(a), “there is no genuine , dispute as to any material fact and the movant is entitled to judgment | as a matter of law,” summary judgement may be granted, where, | under 18 U.S.C. § 248(a)(2), under the direction of the President, a private party, “by force or threat of force or by physical obstruction, intentionally injure[d], intimidate[d] or interfere[d] with or : attempt[ed] to injure, intimidate or interfere with any person lawfully . exercising or seeking to exercise the First Amendment right of religious freedom at a place of religious worship”, and “subject to the penalties provided in subsection (b) and the civil remedies provided in subsection (c)”, so as to remedy a derogation of his rights to equal protection and due process, as well as rights to free exercise, substantive rights, constituting an irreparable harm. Il. PARTIES AND