San Juan Citizens All. v. Bureau of Land Mgmt. (D. Colo.) -- in a wieldy opinion, (1) denying parties' summary judgment motions regarding adequacy of government's search for records concerning Glade Run Recreation Area, noting that "each party has the burden of proof showing reasonableness and neither party has met that burden"; (2) finding that "there may be merit in proceeding" with plaintiff's claim that agency has pattern and practice of illegally withholding records from plaintiff; and (3) denying plaintiff's motion for contempt orders against agency officials for submitting declarations that plaintiff asserted were "ambiguous and unresponsive."
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