District Court Decisions
Ray v. BOP, No. 06-1673, 2009 WL 4643485 (D.D.C. Dec. 8, 2009) (Roberts, J.). The court finds on the basis of BOP's affidavit "it is impossible to definitively conclude that the documents that the defendant determined to be non-responsive were, in fact, non-responsive." Additionally, BOP's conclusory statement asserting that it "searched all files and areas likely to contain responsive records/documents/materials" is inadequate. The court holds that "BOP must provide a more transparent and explanatory description of its search before summary judgment may be granted."