American Center for Law and Justice v. Nat’l Security Agency, 474 F.Supp.3d 109 (D.D.C. Jul. 24, 2020)

FOIA request for USP unmasking requests. Court held (1) statements made by officials after leaving office do not constitute “official disclosures” necessary to overcome Glomar; (2) Grennell memo naming UN Ambassador operated as a waiver of State Dep’t’s ability to assert Glomar regarding requests made during that time period on behalf of UN Ambassador to NSA re: any unmasking of USPs; (3) HPSCI release of UN Ambassador testimony did not constitute an “official disclosure” to overcome Glomar; (4) NSA could limit search to records of Director, Deputy Director, Exec. Director; (5) search terms used by NSA were not reasonably calculated to uncover records associated with particular official’s email address; (6) NSA not required to consider alias that AG was found to have used; (7) email chain with internal deliberations re: speech by UN Ambassador was not “post-decisional” so as to preclude chain from being covered by FOIA’s deliberative-process privilege; (8) State sufficiently demonstrated all reasonably segregable material had been released