Kinnucan v, NSA (W.D. Wash.) -- ruling that the National Security Agency properly withheld a U.S. House committee report related to a 1967 attack by Israeli forces on a U.S. naval intelligence ship, because the report was not an agency record; reasoning that that the facts and circumstances of the report’s creation and its transfer to NSA demonstrated that Congress “manifested a clear intent to maintain control over” the report, which was consistent with the test set forth by the D.C. Circuit in Am. Civil Liberties Union v. CIA, 823 F.3d 655, 662-63 (D.C. Cir. 2016).
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