Broward Bulldog, Inc. v. U.S. Department of Justice, No. 17-13787 (11th Cir. 2019)
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This appeal involved two requests for documents by Broward Bulldog under the Freedom of Information Act (FOIA), seeking documents reviewed by the 9/11 Review Commission. The government disclosed hundreds of documents, bur redacted some information.
The Eleventh Circuit held that the FBI established that it performed an adequate search; the district court had an adequate factual basis to render a decision; Broward Bulldog has abandoned its challenge of the denial of its request to depose an agent; the district court did not err in most of its rulings on the applicable exemptions, with the exception of its rulings regarding redactions under Exemptions 7(C), 7(D), and 7(E); the district court did not err when it failed to make express findings of segregability; and the district court did not err when it refused to entertain a request for documents that were already the subject of a separate, nearly identical lawsuit. Accordingly, the court affirmed in part, reversed in part, and remanded.
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