Lenahan v. HHS (N.D. Cal.) -- ruling that: (1) agency performed adequate search for various contractual records pertaining to agency’s purchase of antibiotics for the Strategic National Stockpile; (2) agency properly relied on Exemption 3 in conjunction with 41 U.S.C. § 4702(b) to redact successful bidder’s proposal, which had not been incorporated into the awarded contract; and (3) agency’s offer to provide an informal Vaughn Index to plaintiff during the meet-and-confer process was insufficient to justify remaining withholdings under Exemptions 3 and 5.
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