Von Chase v. BIA (D.D.C.) -- finding that: (1) Bureau of Indian Affairs conducted adequate search for records concerning plaintiff and properly redacted third-party information pursuant to Exemptions 6 and 7(C), issues that plaintiff conceded; (2) agency’s post-litigation release of records did not necessarily entitle plaintiff to litigation costs, because agency explained that end of post-conviction proceedings triggered release of records; (3) even if plaintiff were eligible for costs, he was not entitled to them because records conferred no benefit to the public and agency’s actions were reasonable.

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