Reporters Comm. for Freedom of the Press v. FBI (D.D.C.) -- determining that: (1) FBI improperly relied on Exemption 7(C) to withhold pseudonyms used by agency in its investigation of Clive Bundy; (2) FBI properly withheld names of four Special Agents pursuant to Exemption 7(C), notwithstanding their trial testimony or news reports associating them with the Bundy investigation, because plaintiff failed to show that those Special Agents were involved in specific aspect of the investigation covered by records at issue; (3) FBI properly withheld four categories of records pursuant to Exemption 7(E), rejecting plaintiff’s argument that foreseeable harm provision applies to Exemption 7(E).
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