Coss v. DOJ (D.D.C.) -- Rejecting FBI’s Glomar response where requester sought a notebook that had been entered into evidence in third party’s criminal trial and cited in publicly available court opinion. “Refusing to acknowledge whether or not the notebooks exist borders on foolishness,” observed the court, which ordered the agency to conduct a search.
- Related coverage from Courthouse News here.
Kuzman v. CIA (W.D.N.Y.) -- Holding that CIA performed an adequate search for records concerning plantiff's participation in a protest against CIA; the agency was not obligated to identify the employees who searched for records or when those searches were conducted. The court also held that the CIA properly invoked a Glomar response pursuant to Exemptions 1 and 3 in response to the portion of plaintiff's request for all records pertaining to himself generally.