Driggs v. CIA (E.D. Va.) -- in case involving records about Americans allegedly held as prisoners of war following the Korean and Vietnam Wars, deciding that: (1) plaintiffs waived their right to challenge redactions to a partially declassified “Critical Assessment” based on their representations in two joint status reports that limited the parties’ disputed issues; (2) one plaintiff was precluded from challenging Exemption 1 and 3 redactions made to another report (“Review of the Charges”), because same plaintiff lost an earlier case involving same report; (3) government properly relied on Exemptions 1 and 3 to withhold the disputed report, and plaintiff’s allegations of bad faith in the creation of that report over 25 years ago were legally irrelevant.
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