This section contains the nature of the case and procedural background.

Ps filed the complaint initiating the present action. Ps filed an amended complaint adding more plaintiffs (M.D.E., R.B., Grace Tilden, Vivian Green, and George D. Mitford). Ps filed a proposed second amended complaint adding (J.T., J.B., C.B., P.C., P.C.1., C. Lynn, Nathan (P), Elaine Livingston (P), and Betty E. Yales (P)). First, Fourth, Fifth, and Ninth Amendments of the United States Constitution, the Privacy Act, and Title VII. D's invocation of a September 4, 1998 notice has allegedly resulted in a denial of Ps' access to CIA documents, policies, procedures, and regulations, thereby preventing counsel from effectively advising Ps of their rights. Ps claim that D has 'willfully and intentionally failed to maintain accurate, timely, and complete records pertaining to Ps in their personnel, security, and medical files so as to ensure fairness to Ps, thus failing to comply with 5 U.S.C. § 552a(e)(5) [of the Privacy Act].'

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