Proj. for Privacy & Surveillance Accountability v. ODNI (D.D.C.) -- in a case concerning records about former agency director’s testimony purchases of Americans’ data, determining that: (1) ODNI properly relied on Exemption 1 and 3 to withhold certain classified records on intelligence sources and methods, but agency’s explanation for some redactions were too conclusory; (2) ODNI’s redactions under the attorney-client communications privilege were proper, but its justifications for the deliberative process privilege were conclusory and insufficiently detailed to show foreseeable harm; (3) ODNI’s reliance on Exemption 7(E) appeared to be proper for FBI records describing non-public law enforcement techniques under Section 702 of FISA, but a supplemental affidavit was required to clarify whether any redactions improperly included legal analysis or interpretations of the law; and (4) rejecting the plaintiff’s argument that previously issued unclassified policy guidance constituted official acknowledgment of withheld information.
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