JIANG ZEMIN
PRESIDENT AND LAME DUCK OF CHINA

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DOCUMENTS WITHHELD BY THE CLINTON WHITE HOUSE

UNITED STATES DISTRICT COURT
FOR THE COMMONWEALTH OF VIRGINIA


CHARLES R. SMITH           
      
                           
         Plaintiff         
                           
         V.                
                           
Serve For                  
                           
GENERAL COUNSEL            
ROOM 5898-C                
DEPARTMENT OF COMMERCE     
14TH & CONSTITUTION AVE.   
WASHINGTON, D.C.  20230    
                           
         Defendant         

ATTORNEY GENERAL OF THE          
UNITED STATES                    
MAIN JUSTICE BUILDING            
10TH & CONSTITUTION AVE., N.W.   
WASHINGTON, D.C.  20530          
                                 
UNITED STATES ATTORNEY FOR THE   
EASTERN DISTRICT OF VIRGINIA     
MAIN STREET CENTRE, 18TH FLOOR   
600 EAST MAIN STREET,            
RICHMOND, VA  23219              
                                 

COMPLAINT FOR DECLARATORY AND INJUCTIVE RELIEF

Comes now Plaintiff, Charles R. Smith, and hereby files a
complaint for compliance with the Freedom of Information Act
("FOIA"), 5 U.S.C., § 552 as amended, Charles R. Smith
respectfully alleges as follows:

1.  This is an action brought under FOIA to order the production
of documents and records of the Department of Commerce ("DOC").

2.  This court has jurisdiction over this action pursuant to 5
U.S.C. sec § 552 (a) (4) (B).

3.  Plaintiff Charles R. Smith is a journalist and the owner of
a Virginia based information security company whose principle
place of business is 7707 Whirlaway Drive, Midlothian, Virginia.
Plaintiff, the requester of the withheld documents, is a
recognized independent journalist, as per written documentation
provided by the Central Intelligence Agency and the Department
of Commerce, and is dedicated to the dissemination of accurate
information, protecting the lives, property and privacy of all
citizens.  In pursuit of those principles, Plaintiff is
empowered to take legal and other corrective actions that will
serve the public interest.

4.  Defendant Department of Commerce ("DOC") is an agency of the
United States government, established by statute and charged
with the responsibility of international and domestic commerce.
It's principle place of business, and the offices responsible
for the purposes of legal, FOIA and public affairs is located
inside the District of Columbia.  The Defendant agency has
possession of the documents and records to which Plaintiff seeks
access.

5.  Plaintiff filed with the Defendant on January 21, 1998 via
mail two FOIA requests in the form of letters to the FOIA
officer, requesting access to records within the agency under 5
U.S.C.  § 552, FOIA, see Exhibit-1 and Exhibit-2.  Access was
requested for all information with regards to Sanford R.
Robertson, Chairman of Robertson & Stephens Company, and Bernard
L. Schwartz, Chairman of the Loral Aerospace Corporation.

6.  By letters dated May 4, 1998, Defendant ("DOC") responded
with materials applicable to the two FOIA requests, see Exhibit
3 and Exhibit 4.  Defendant responded that an additional 22
documents responsive to the Plaintiff's FOIA requests were also
discovered but were being withheld for consultation with "other
agencies".  Please see Exhibit-3 and Exhibit-4.

7.  By letter dated, May 18 1998, Defendant ("DOC") responded
with a single document applicable to the two FOIA requests, see
Exhibit-5 and Exhibit-6.  The document in question is from the
White House.  Furthermore, phone conversations with the
Defendant's FOIA officer, Bobbie Parsons, revealed that many of
the remaining 21 documents currently withheld by the Defendant
are also from the White House.

8.  Plaintiff begs the Court to accept Exhibit-7, a letter from
the legal Counsel for the Vice President, which asserts under 5
U.S.C. § 552, the White House is NOT an agency.  This letter was
obtained in response to a 1997 FOIA request by the Plaintiff
against the Office of the Vice President.  The legal Counsel for
the Vice President clearly notes that the White House is not an
agency as per the Freedom of Information Act (FOIA) 5 U.S.C. §
552.

9.  Defendant's claim that White House documents are being
withheld for consultation with "other agencies" is false and
invalid because the White House is not an agency as per the
Freedom of Information Act (FOIA) 5 U.S.C. § 552.

10.  Plaintiff appealed the withholding of these documents to
the Defendant in a letter dated June 1, 1998, see Exhibit-8.

11.  The Plaintiff has given over 60 days for the Defendant to
respond to the appeal, and has complied with all Defendant
requests to provide further  documents, including copies of the
Defendant's records, see Exhibit-9 Defendant letter dated June
16, 1998.  The Plantiff is in compliance with all provisions
under the Freedom of Information Act (FOIA) 5 U.S.C. § 552.

12.  As of August 18, 1998, the Defendant has failed to comply
within the time limit and the Plaintiff shall be deemed to have
exhausted its administrative remedies with respect to this
request, pursuant to 5 U.S.C. § 552 (a) (6) (C).

13.  Plaintiff has a right of access to the documents and
records refused, pursuant to 5 U.S.C., § 552 (a) (3), and
Defendant has no legal basis for refusing to disclose these
documents and records to the Plaintiff.

WHEREFORE, Plaintiff prays that this Court:

         (1)  Declare that Defendant's refusal to disclose
              records requested by Plaintiff is unlawful;

         (2)  Order Defendant to make the requested records
              available to the Plaintiff,

         (3)  Award Plaintiff its costs and reasonable
              attorney's fees in this action and

         (4)  Grant such other and further relief as the Court
              may deem just and proper.


                           Respectfully submitted,


                           __________________________________
                           
                           Charles R. Smith

                           Plaintiff

August 18, 1998
                           





JIANG Zemin
(Phonetic: jeeyahng)
(3068/3419/3046)

 President (since March 1993); General
 Secretary, Chinese Communist Party
 (CCP); Member, Standing Committee,
 Politburo, CCP; Chairman, Military
 Affairs Commission (MAC), CCP
 (since 1989)

Addressed as Mr. President:

Jiang Zemin formally heads the three major sectors of the
Chinese political system: the government, the military, and the
CCP. Hong Kong media reports indicate that, although he has in
the past acted largely as a spokesman for other policymakers he
has recently taken on more substantive responsibilities and has
improved his status among his colleagues.  According to the
press, Jiang has ties to senior party leaders, including Deng
Xiaoping and economic planner Chen Yun.

Jiang has endorsed the ruling elder's views on political dissent
and pushed for greater political indoctrination and tougher
social controls.  He has long fought political opposition and
was among the first leaders to support Deng's editorial calling
for a crackdown on student protesters in 1989.  More recently,
he has played a prominent role in an ongoing campaign to
identify and punish corrupt government and party officials.

Although Jiang has backed Deng's open-door policy and has
actively courted Western investors, he is generally not regarded
as an ardent market reformer and has not pushed specific
economic initiatives.  Since Deng began his latest reform drive
in January 1992, Jiang has publicly expressed his backing for
the reform agenda.

Jiang has spent most of his career in China's heavy industry
sector.  He earned a degree in electrical engineering in 1947
from Shanghai Jiaotong University.  Chinese press reports
indicate that he held factory posts in China during 1950-54.  In
1955 he began a year of training at the Stalin Automobile
Factory in Moscow.  Jiang held a series of engineering posts
after returning to China.  By 1964 he was a vice manager of the
Shanghai Electrical Apparatus Company.  In the 1970s Jiang moved
to the central government bureaucracy.  From 1971 until 1979 he
served in the First Ministry of Machine Building, which was
responsible for developing heavy industry.  During 1980-82 he was
a vice minister of the State Council's Foreign Investment
Control and Import-Export Commissions. Jiang joined the Ministry
of Electronics Industry as a vice minister in 1982; he became
Minister a year later.  During 1985-86 he was a deputy head of the
Electronics Industry Invigoration Leading Group.  A member of the
CCP Central Committee since 1982, he was elected to the
Politburo in 1987.  Jiang served in Shanghai as party secretary
from 1985 until 1989; he was mayor from 1985 until 1988.

Jiang was born on 10 July 1926. He joined the CCP at 20 to
oppose Chiang Kai-shek.  Jiang speaks English and Russian and can
read French, Japanese, and Romanian.  He is fond of literature and
of Western classical music.  He has visited the United States
three limes, most recently in 1987. Married, he has two sons.

7 October 1993



LI Peng
(Phonetic: lee)
(2621/7720)

Premier State Council (since 1988);
Member Standing Committee, Politburo,
Chinese Communist Parry (CCP)
(since 1987)

Addressed as: Mr. Premier


Widely considered one of the most powerful members of his generation 
of leaders, Li Peng began a second term as Premier in March 1993. 
He dropped from public view shortly after that, and although official 
Chinese press statements attributed his absence to a cold, Li later 
publicly stared that he had suffered from a heart ailment. He resumed 
a normal schedule of meetings and public appearances in late August 
1993, noting that he had fully recovered.

Although Li has long been identified with hardline economic policies, 
he has publicly expressed support for paramount leader Deng Xiaoping’s 
latest reform drive, which began in early 1992. He has claimed credit 
for the success of that renewed reform effort and endorsed price and 
tax reform and the creation of Shanghai’s Pudong development zone. 
Nonetheless, Li has publicly stressed China’s continued adherence 
to socialism, stating that a multiparty system would be inappropriate
for China. In the months before his Illness, Li published several 
speeches castigating Hong Kong Governor Chris Panen’s proposed reforms,
which he characterized as a threat to Chinese sovereignty and 
stability.

Li was born on 2O October 1928. In 1931 his father, an early Communist
leader, was killed by the Kaomintang, and Li came under the protection
of Zhou Enlai, who became Premier under Mao Zedong. At 18, Li joined 
an elite group of Chinese students studying in the Soviet Union, where 
he remained for seven years. He worked with Soviet advisers during the
early part of his 26-year career in the electric power industry. 
Because he was under Zhou’s protection, he was not purged during the 
Cultural Revolution. Li launched his national career as a vice minister
of electric power in 1980 and became Minister the following year. In 
1983 he leapfrogged several more senior leaders to become a vice
premier.

Li’s wife, Zhu Lin, graduated from the Harbin Foreign Language College
and has spent her career in the electrical sector; she now heads the
Beijing office overseeing the Daya Bay nuclear power plant near Hong 
Kong. The couple has a daughter, two sons, and three grandchildren.


26 November 1993



ZHU Rongji
(Phonetic: joo)
(2612/6954/1015)

Member, Standing Committee, Politburo,
Chinese Communist Party (CCP)
(since 1992); Vice Premier (since 1991);
Governor, People's Bank of China
(since July 1993)


Addressed as Mr. Vice Premier

A supporter of paramout leader Deng Xiaoping's economic reform
program, Zhu Rongji is the principal official responsible for
overseeing China's economic, financial and trade affairs.
Concerned that the economy would overheat - he launched a
mini-austerity program in mid-1993.  As Governor of the People's
Bank of China -- the country's quasi-central bank -- Zhu has
promoted sweeping reforms in banking and government finance.  He
meets frequently with foreign businessmen and economic officials
as well as other with visiting dignitaries.

Zhu was born on 1 October 1928.  A student activist, he joined
the CCP in 1949.  After graduating from Qinghua University in
1951 with a degree in electrical engineering.  He worked
successively in the Fuel and Power Bureau, General Affairs
Bureau, and Mechanical Bureau of the State Planning Commission.
In 1958 Zhu was labeled a rightist and spent the next 20 years
in an obscure position in the economic planning bureaucracy.
After his rehabilitation in 1979, he was to the State Economic
Commission.  He was appointed director of the SEC's Technology
Transformation Bureau in 1982 and served as Vice Minister of the
SEC from 1983 until 1988, when he was named mayor of Shanghai.
He held a concurrent assignment as dean of Qinghua Univenity.
Zhu was elected an alternate member of the Central Committee in
1987 and became secretary of the Shanghai CCP committee in 1989.
He is now a full Central Committee member.  In July 1991 Zhu
became director of the State Council Prodution Office.  During
1992-93 he headed the Economic and Trade Office, which absorbed
the Production Office.

In 1990 Zhu led a delegation of mayors to the United States.  He
has also visited Australia, New Zealand, and several European
nations.  Zhu speaks some English.  He enjoys reading Chinese
literature, watching Peking opera, and playing the huqin, a
two-stringed instrument.  He and his wife play tennis.  The
couple has a son.

14 January 1994



ZOU Jiahua
(Phonetic: dzoe)
(6760/1367/5478)

Member, Politburo, Chinese Communist
Parry (CCP) (since October 1992);
Vice Premier (since 1991)


Addressed as: Mr. Vice Premier

Zou Jiahua, who retained his vice-premiership at the National
People's Congress in March 1993, is an advocate of economic
retrenchment.  As one of three vice premiers who oversee the
economy, Zou focuses primarily on long-term economic planning;
for example, he helped draft the current five-year plan.  Widely
considered a strong proponent of central planning, Zou told the
press in 1991 that "market mechanisms must take a backseat to
economic planning."  Since early 1992, however, he has publicly
echoed Deng Xiaoping's efforts to revive reform.  In a speech in
May 1992 he praised Guangdong Province's accomplishments in
economic reform and condoned growth rates as high as 20 percent
as long as other economic indicators remain balanced.

Zou, an experienced and widely traveled negotiator, is one of
China's point men in dealing with the West.  Since becoming Vicce
Premier, he has visited Japan, the United Kingdom, Italy,
Spain, Netherlands, and Germany; he traveled to the United
States in 1986.  He played an important role in China's early
efforts to acquire foreign military technology.  During the
mid-1980s, Zou served on the board of directors of China's
Northern Industrial Corporation.

Zou was born in October 1927.  His career, like those of many of
his generation in the government has centered around
industry.  After graduating from a Chinese university, he
studied at an industrial university in the Soviet Union in the
late 1940s and early 1950s.  A machine tool specialist, Zou held
a series of positions in the defense industry: 

- Director, Beijing Machine Tool Research Institute, First
Ministry of Machine Building (1965-72).

- Deputy director, National Defense Industry Office under the
State Council (1972-82).

- Vice Ministry, National Defense Science, Technology, and
Industry Commission (1984-85).

Zou was appointed Minister of Ordnance in 1985; when his
Ministry was merged with the Ministry of Machine-Building
Industry in 1986 to form the State Machine-Building Industry
Commission, he was named minister of the new organization.  Zou
has been a member of the CCP Central Committee since 1985.  He
was Minister of Machine-Building and Electronics Industry from
1988 until 1989, when he was named Minister of the State
Planning Commission.  He gave up that post in March 1993.  Zou
also serves as director of the National Safety Production
Committee.  In October 1991 he was chosen to head the Job
Allocation System Reform Commission.

Zou speaks fluent Russian and some English. He enjoys driving
cars and is a talented calligrapher, according to the Chinese
press.  He is married to Ye Chumei and has a daughter.

15 April 1993





HU Qili
(Phonetic: hoo)

Minister of Electronics Industry
(since March 1993)


Addressed as: Mr. Hu

As head of the newly created Electronics Ministry, which the
Chinese press has hailed as a major step toward modernizing
China's National economy and defense, Hu Qili has emphasized
that electronics will serve as a pillar of industry as China
accelerates its economic development.  He stresses that this
streamlined Ministry - - both personnel and departments have been
trimmed - - should strive to keep the electronic industry's annual
growth rate higher than that of the national economy; this
expansion will provide advanced electronics equipment and
systems to help develop other industries such as energy,
transportation and communications.  Arguing that military
electronics are a key technology necessary for winning modern
warfare, Hu has claimed that the Ministry will need to develop new
technologies and new products, improve product mix, and
broaden the market for electronics goods.  One of Hu's primary
goals is to computerize information on the national economy
through three new programs:

- Creating a public data and information network.  

- Developing an automated teller machine system that will use
  credit cards.

- Establishing a foreign trade and economic information network 
  that will promote electronic data interchange and end paper
  trading.

Hu has regained much of his former prominence with his
appointment to the Electronics Ministry, according to the Hong
Kong press.  Sidelined after he supported former Premier Zhao
Ziyang during the 1989 Tiananmen crisis, Hu had been partially
rehabilitated in 1991 when he was named a Vice Minister of
Machine Building and Electronics.

Hu was born in 1929.  He studied mechanical engineering at
Beijing University.  At 19, he joined the Chinese Communist
Party (CCP) and started working in youth and student affairs,
eventually becoming a core member of the Chinese Communist Youth
movement.  He worked as president of the All-China Students
Federation from 1955 until 1964.  In 1966 Hu served as alternate
secretary of the Communist Youth League under then CYL First Secretary
Hu Yaobang.  Purged in early 1967, Hu was rehabilitated in 1972 and
sent to Ningxia Province, where he gained experience in party
work at the local level while serving as deputy secretary of
Ningxia Hui Autonomous Region Party Committee.  In 1977 he returned
to Beijing to work with the CYL and shortly thereafter was
appointed its secretary.  He became chairman of the All-China
Youth Federation in May 1979.  Hu served as vice president of
Qinghua University in Beijing during 1978-82.  Appointed mayor of
Tianjin Municipality in June 1980, Hu subsequently became
secretary of the Tianjin Municipal CCP Committee.  He was called
back to Beijing in May 1982 to serve as director of the CCP
General Office and in September was appointed to the CCP Central
Committee. In September 1985 Hu was elected a member of the
Politburo and in 1987 became a standing committee member.

Hu has made several trips to foreign countries.  He is married.
He speaks fluent English.

13 October 1993




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