Pub. Justice Found. v. Farm Serv. Agency (N.D. Cal.) -- determining that: (1) agency properly relied on Exemption 3, in conjunction with 7 U.S.C. § 8791 (Food, Conservation, and Energy Act of 2008), to withhold various records concerning applicants to agency’s farm loan program, except for specific earmarks by FSA for approved loans; (2) Exemption 4 was inapplicable because FSA failed to provide express implied assurance of confidentiality; and (3) agency could not use Exemption 6 to withhold loan payment information, but it properly withheld sensitive personally-identifiable information such as social security numbers, bank account information, personal assets, etc.

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