Energy Policy Advocates v. SEC (D.D.C.) -- determining that: (1) agency performed an adequate search for various electronic communications, and (2) agency properly relied on Exemption 5’s deliberative process privilege to withhold in full five pages discussing the “nuts and bolts of proposed rulemaking”; further noting that the agency met the “deliberative process privilege’s ‘foreseeable harm’ requirement” with a concrete and focused declaration (albeit brief), which was supported by the “context and purpose” of the withheld records.
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