CEI v. EPA – Sept 11 Opposition to Motion for Summary Judgment in Richard Windsor Lawsuit
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Defendant’s motion for summary judgment should be rejected, because it has not complied with this Court’s order that it produce a representative sample Vaughn Index of 172 fully-withheld documents, has not consistently sampled every tenth document, omitted several hundred records from its sampling, and has instead demonstrated that its withholding of documents under FOIA exemptions is based on unreliable and often erroneous privilege claims.