Yonemoto v. VA, No. 06-0378, 2009 WL 5033597 (D. Haw. Dec. 22, 2009) (Kurren, Mag.). The court dismisses plaintiff’s contention that disclosure of the requested records is required by President’s Memorandum on the FOIA as well as by the FOIA guidelines issued by the Attorney General and Office of Information Policy. First, the court notes that the President’s memorandum "does not create any right or benefit . . . by any party against the United States." Second, the court observes that VA specifically states that it considered the FOIA guidelines when making its disclosure determinations.