Thursday, March 28, 2019
Cochran v. DHS, No. 18-201, 2019 WL 1433014 (D. Md. Mar. 28, 2019) (Hollander, J.)
Re: Request for "'all documents pertaining to [plaintiff's] security clearance'"
Disposition: Granting defendant's motion for summary judgment
- Litigation Considerations, Adequacy of Search: The court holds that "[t]he exhibits describe the searches, identify search terms, the specific locations that were searched, and indicate that all files likely to contain responsive materials were searched." The court also finds that "[plaintiff] provided no support for her assertion that FEMA 'must' have the document in its possession." "'A mere deductive inference that a record "must" exist, without proof, does not raise a material issue of fact regarding the adequacy of an agency's search.'
Adequacy of Search
Updated April 11, 2019