Sartori v. Dep't of Army, No. 17-679, 2019 WL 1116781 (N.D. Fla. Mar. 9, 2019) (Rodgers, J.)
Re: Request for emails concerning plaintiff
Disposition: Granting plaintiff's objection to Magistrate Judge's denial of motion to compel more detailed Vaughn Index; denying defendant's motion for summary judgment
- Litigation Considerations, Vaughn Index/Declaration: The court holds that "U.S Army is directed to produce a more detailed Vaughn index that addresses the aforementioned deficiencies." The court finds "two instances where U.S. Army failed to provide an explanation for withholding information . . . ." "In addition, U.S. Army's Vaughn index, even when considered with its declarations, does not provide the Court with an adequate factual basis to determine whether many of the other exemptions claimed . . . were properly invoked." "The index is also insufficient because U.S. Army, despite claiming that multiple exemptions apply to individual index entries, does not specify which portions of the relevant documents each exemption applies to or whether a claimed exemption applies to the entire document." "Without this information, the Court cannot adequately determine whether all reasonably segregable non-exempt information has been disclosed."