FOIA Advisor

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Court opinion issued Jan. 9, 2023

Cato v. FBI (D.D.C.) -- concluding that plaintiff was entitiled to relief from court’s judgment because of “newly discovered evidence” concerning the adequacy of FBI’s search, namely an FBI declaration filed in a 2018 case that contradicted the FBI’s position in the instant case regarding the agency’s Central Records System; reasoning, in part, that the public availability of FBI’s 2018 declaration on PACER was not fatal to plaintiff’s motion, because the declaration was not discoverable by a reasonably diligent search.

Summaries of all published opinions issued since April 2015 are available here.