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Peak v. DOJ, No. 18-3043, 2020 WL 5865232 (D.D.C. Oct. 1, 2020) (Chutkan, J.)


Peak v. DOJ, No. 18-3043, 2020 WL 5865232 (D.D.C. Oct. 1, 2020) (Chutkan, J.)

Re:  Request for records concerning plaintiff's criminal case

Disposition:  Granting defendants' motion for summary judgment; denying plaintiff's cross-motion for summary judgment

  • Litigation Considerations, Adequacy of Search:  "The court finds that Defendants have fully complied with FOIA by conducting reasonably adequate searches."  The court explains that "Defendants' declarant provides a comprehensive description of the FBI's vast Central Records System (CRS) . . . ."  "The declarant adequately describes the search methodology . . . and plausibly explains why and how the search terms (variations of Plaintiff's name) were utilized . . . ."  "In addition to the CRS, the FBI searched 'its manual indices for the Louisville Field Office using the same search terms' . . . ."  "The declarant avers that 'all systems and locations likely to contain responsive records' were searched and 'there are no other systems or locations likely to contain' responsive records."  In response to plaintiff's arguments concerning a non-FBI system, the court makes note of "DOJ's 'decentralized system for responding to FOIA requests,' and finds that "[defendant's] procedures impose no duty on one DOJ component to search the files of another component for responsive records."
Court Decision Topic(s)
District Court opinions
Litigation Considerations, Adequacy of Search
Updated November 9, 2021