Heritage Found. v. DOJ (D.D.C.) -- in case concerning various communications about Timothy Thibault, a former Assistant Special Agent in Charge of the FBI’s Washington Field Office, determining that: (1) DOJ properly relied on Exemptions 6 and 7(C) in refusing to confirm or deny the existence of records compiled for law enforcement purposes, but not for administrative records that plaintiff’s request conceivably sought; and (2) DOJ properly withheld—on a categorical basis—records of communications containing the terms “Thibault” and “Grassley” pursuant to Exemptions 6 and 7(C), except as to any responsive administrative records.

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