Richardson v. United States, No. 13-1203, 2015 U.S. Dist. LEXIS 101389 (D.D.C. Aug. 4, 2015) (Huvelle, J.)

Richardson v. United States, No. 13-1203, 2015 U.S. Dist. LEXIS 101389 (D.D.C. Aug. 4, 2015) (Huvelle, J.)

Re: Request for records concerning plaintiff

Disposition: Granting defendant's motion for summary judgment

• Procedural Considerations, Adequacy of Search:  "[T]he Court is satisfied that the EOUSA conducted an adequate search."  The court relates that "[w]hen the Court [previously] denied summary judgment on this issue, there was 'uncontroverted evidence' in the record that the EOUSA had released an incomplete set of still photos."  "Now, however, defendant has provided the explanation that was previously lacking, explaining that the still photos that the EOUSA found and released were not from the surveillance video."  "Thus, there is no obvious 'gap' in the records that were located and produced."  Additionally, the court notes that "EOUSA has conducted a second search of plaintiff's file for 'anything related to a surveillance video.'"
   
• Litigation Considerations, "Reasonably Segregable" Requirements:  "Having reviewed these descriptions and the supplemental declaration, the Court is satisfied that there is no reasonably segregable non-exempt information in [the withheld] documents that the EOUSA should have released."  The court explains that "[i]n addition to . . . more detailed descriptions of documents 11 and 12 [that the court previously ordered defendant to produce], the record establishes that these documents have been reviewed for segregability."