28.  The Plaintiff incorporates by reference all of the above paragraphs as  though set forth herein in their entirety.   29.  According to 28 U.S.C. § 2201, this Court has the power to adjudicate a  dispute between the Plaintiff and the Defendants involving any issue involving federal law.    30.  The Plaintiff is aggrieved by the above-described conduct of the  Defendants.    31.  The Defendants are subject to the law established by the United States  Constitution.     33.  The Plaintiff has an expectation of privacy in the above-described private  information and electronic communciations being collected by the Defendants.     34.  The Defendants have unlawfully collected such information in violationof the  4th Amendment, without obtaining a warrant and without probable cause.     35.  As of this date, the Defendants have refused to provide any public  explanation of the legal authority that purports to authorize their intrusion into the affairs of  the Plaintiff.    36.  The Plaintiff respectfully submits that any such purported authority, when  ultimately disclosed by the Defendants, is unlawful as a violation of the 4th Amendment of  the United States Constitution.    38.  The Plaintiff incorporates by reference all of the above paragraphs as  though set forth herein in their entirety.   39.  The Defendants have invaded the privacy of the Plaintiff -- and have  intruded upon the private affairs of the Plaintiff -- in violation of Pennsylvania law.     40.  It is unclear whether monetary damages will be sufficient to compensate the  Plaintiff.     41.  The Defendants have already compromised, or caused the termination of,  all secure e-mail communication services based in the United States.  This includes the e- mail service, Lavabit, which previously sought to keep its communications safe and  private from the Defendants.    42.  Upon information and belief, the Defendants have also compromised the  security of the cloud storage service, Dropbox.       44.  The Plaintiff incorporates by reference all of the above paragraphs as  though set forth herein in their entirety.   45.  According to 28 U.S.C. § 2201, this Court has the power to adjudicate a  dispute between the Plaintiffs and the Defendants involving any issue involving federal  law.    46.  The Plaintiff is aggrieved by the above-described conduct of the  Defendants.    47.  If the Defendants are purporting to act pursuant to the Foreign Intelligence  Surveillance Act, then it appears that the Defendants are in violation of such act.     48.  According to 50 U.S.C. § 1861(b)(2)(B), the Defendants are required to  utilize “minimization procedures” with respect to information that is inadvertently obtained  concerning an “unconsenting United States person” during an investigation relating to  international terrorism or clandestine intelligence activities.   49.  On July 29, 2009, Attorney General Eric Holder adopted minimization  procedures that allowed the Defendants to retain the Plaintiff's confidential and valuable  information for a period of up to five years, and possibly longer.    50.  Such minimization procedures were kept secret from the Plaintiff until  recently.     52.  The Foreign Intelligence Surveillance Act does not contemplate, or  authorize, the retention of the Plaintiff's confidential information for a period of five years.   WHEREFORE, the Plaintiff respectfully requests that this Honorable Court enter  an order determining that the maximum duration of the minimization procedures under the  Foreign Intelligence Surveillance Act, as it applies to the Plaintiffs’ confidential  information, is substantially less than five years.      Respectfully submitted,  By: /s/ Elliott J. Schuchardt         Elliott Schuchardt  Declaratory and Injunctive Relief  Violation of the Foreign Intelligence Surveillance Act   Declaratory and Injunctive Relief  Violation of the Fourth Amendment   Injunctive Relief  Intrusion / Invasion of Privacy  