Greenspan v. EOUSA (D.D.C.) -- in case seeking investigative records about named individuals who operated a heroin ring in Chicago in the 1990s, ruling that: (1) DEA was precluded from using Glomar response regarding one named individual because DOJ publicly filed an IRS affidavit in a forfeiture matter that expressly acknowledged DEA’s investigation of same individual; (2) both the DEA and FBI were precluded from using Glomar responses with respect to a second named individual (currently Nigeria’s president), because the above-referenced IRS affidavit acknowledged that that individual was criminally investigated by those agencies, among others; and (3) CIA’s Glomar response concerning the Nigerian president was not waived by the presence of documents in the agency’s FOIA Reading Room that generally addresses Nigeria’s involvement with heroin narcotrafficking during the mid-1980s.
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