Hajro v. U.S. Citizenship & Immigration Servs. (9th Cir.) (unpublished) -- affirming district’s ruling that plaintiff failed to demonstrate that he personally filed FOIA requests that were delayed and, therefore, he did not have standing to bring “pattern or practice” claim. In rejecting the adequacy of plaintiff’s duplicative declaration, the Court amusingly remarked that “[w]hatever salience the adage ‘if at first you don't succeed—try, try again’ has in daily life, expecting identical arguments to yield different results is a poor strategy for success in our court.”
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