Elliott v. GSA, No. 17-1022, 2018 WL 534322 (D.D.C. Jan. 24, 2018) (Kollar Kotelly, J.)

Elliott v. GSA, No. 17-1022, 2018 WL 534322 (D.D.C. Jan. 24, 2018) (Kollar Kotelly, J.)

Re:  Request for "'records . . . demonstrating jurisdiction over [particular building]'"

Disposition:  Granting defendant's motion for summary judgment

• Litigation Considerations, Adequacy of Search:  The court holds that "GSA demonstrates that it has complied with its obligations under the FOIA."  The court finds that "GSA's supporting declaration is short on details, but it need not 'set forth with meticulous documentation the details of an epic search for the requested records.'"  "It sufficiently explains why GSA's staff forwarded plaintiff's request to the Real Estate Division and why GSA had no responsive records: GSA neither owns nor leases [the building]."  The court finds that "[t]he results, or lack of results, of the search do not undermine its adequacy."  Additionally, the court finds that plaintiff's opposition does not contain "any legal argument or reference to any materials in the record to show that a genuine issue of material fact exists as to the adequacy of the GSA's search or its compliance with the FOIA."