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Ramcharan v. DEA, No. 18-2759, 2020 WL 5366473 (D.D.C. Sept. 8, 2020) (Sullivan, J.)


Ramcharan v. DEA, No. 18-2759, 2020 WL 5366473 (D.D.C. Sept. 8, 2020) (Sullivan, J.)

Re:  Request for records concerning plaintiff's criminal trial

Disposition:  Granting defendant's motion for summary judgment

  • Litigation Considerations, Adequacy of Search:  The court holds that, "[b]y his silence, plaintiff concedes that he 'submitted 3 modifications to his initial FOIA request,' . . . and that his 'narrowed' request for 'the file associated with his criminal trial,' is the subject of this lawsuit . . . ."  "In addition, plaintiff concedes [defendant's] statements demonstrating the adequacy of DEA's search."
  • Exemptions 5, 6, 7(C), 7(D), 7(E) & 7(F):  The court finds that "DEA has explained its withholdings in sufficient detail, and its justifications are consistent with D.C. Circuit law."
  • Litigation Considerations, "Reasonable Segregable" Requirement:  The court finds that "DEA has shown that '[a]ll responsive information was examined to determine whether any reasonably segregable information could be released,' . . . and that all reasonably segregable information indeed was released."
Court Decision Topic(s)
District Court opinions
Exemption 5
Exemption 6
Exemption 7(C)
Exemption 7(D)
Exemption 7(E)
Exemption 7(F)
Litigation Considerations, Adequacy of Search
Litigation Considerations, “Reasonably Segregable” Requirements
Updated October 20, 2020