FOIA Advisor

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Court opinion issued Aug. 24, 2021

Prot. Democracy Proj. v. NSA (D.C. Cir.) -- affirming district court’s decision that NSA properly relied on Exemption 5’s presidential communications privilege to withhold in its entirety a memo documenting a telephone call between the NSA Director and President Trump, rejecting plaintiff’s arguments that the privilege was subject to FOIA’s segregability requirement and waived by disclosures in the Mueller Report.

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