Bartko v. DOJ (D.D.C.) -- on remand from D.C. Circuit, determining that: (1) FBI needed to provide more detailed showing in order to rely solely upon Exemption 7(C) to withhold material sought by grand jury; (2) Office of Professional Responsibility properly withheld records pursuant to Exemption 5 (deliberative process privilege) and Exemption 6; and (3) EOUSA properly withheld records pursuant to Exemptions 5, 6, and 7(C), as court had ruled in earlier opinion.
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