Freedom Watch, Inc. v. Dep't of State, No. 14-1832, 2015 WL 109837 (D.D.C. Jan. 8, 2015) (Boasberg, J.)

Freedom Watch, Inc. v. Dep't of State, No. 14-1832, 2015 WL 109837 (D.D.C. Jan. 8, 2015) (Boasberg, J.)

Re: Request for records concerning waivers granted to countries doing business with Iran

Disposition: Granting defendant's motion to dismiss

• Litigation Considerations, Adequacy of Search:  "[T]he Court believes that State has easily cleared the bar for an adequate search."  The court finds that defendant's "declaration narrates in considerable detail the steps each of eleven State components took to locate responsive records."  Additionally, "[t]he second declaration supplements this narrative by describing how [defendant] 'sought and obtained advice from subject matter experts in offices working on sanctions against Iran' 'to ensure that it had used the appropriate search terms in its search of the Central File.'"  Regarding plaintiff's attempt to expand the scope of its request during this litigation, the court finds that plaintiff argues that "State was somehow supposed to divine that a FOIA request for documents about waivers pursuant to a specific statute should also have been construed as seeking documents relating to an entirely different statute."  "This is not a serious argument."
   
• Litigation Considerations, Discovery:  The court denies plaintiff's request for discovery because the court finds that "'[d]iscovery is generally inappropriate in a FOIA case'" and, "[m]ore important, Plaintiff here has offered no valid reason to question the good faith or efficacy of State's search."