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ACLU v. U.S. DOJ, 210 F. Supp. 3d 467 (S.D.N.Y. 2016)
After the DOJ conducted a new FOIA search following court orders in 90 F. Supp. 3d 201, approximately 80 responsive documents were located. Id. at 471. The Court found the scope and conduct of DOJ’s searches adequate. Id. at 478. The Court also finds that the NSD carried its burden of demonstrating applicability of work product protection to the documents withheld, with the exception of one document. Id. at 483. The Court ordered a revised Vaughn submission regarding this document to provided additional support for the work product claim. Id. at 485-86. The Court also requires the DOJ to conduct a segregability analysis. Id. at 485.
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