Court opinion issued Sept. 27, 2022
Hall & Assocs. v. EPA (D.D.C.) -- determining that: (1) agency performed adequate search for records transmitted between headquarters and Region 7 concerning November 2013 meeting; (2) agency properly relied on Exemptions 5’s deliberative process, attorney work-product, and attorney-client privileges to withhold portion of email discussing possible enforcement action; and (3) in camera inspection was required to ascertain whether eleven documents concerning contemplated regulatory action contained purely factual material; (4) agency conducted adequate search for certain enforcement orders and properly withheld most, but not all, records pertaining to draft administrative order pursuant to multiple Exemption 5 privileges.
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