Callimachi v. Fed. Bureau of Investigation

2 Citing cases

  1. Leopold v. U.S. Dep't of Justice

    1:20-cv-03651 (TNM) (D.D.C. Dec. 18, 2024)

    Based on the Department's declarations and briefing, the Court finds that it conducted a line-by-line review of each record and released all reasonably segregable portions. Accord Callimachi v. FBI, 583 F.Supp.3d 70, 93 (D.D.C. 2022) (noting challenger must provide a “quantum of evidence” to overcome presumption that agency complied with its obligation to disclose reasonably segregable material).

  2. Holmes-Hamilton v. Fed. Bureau of Investigation

    21-cv-2927 (TNM) (D.D.C. Aug. 23, 2024)

    After all, “[t]he text of 7(E) allows withholding only when the withheld material ‘could reasonably be expected to risk' circumvention of the law.” Id. (quoting 5 U.S.C. § 552(a)(8)(A)(i)); accord Callimachi v. FBI, 583 F.Supp.3d 70, 89 (D.D.C. 2022). And here, the FBI's declarant has explained that disclosure of the toxicology reports would “reveal limitations of the FBI Lab's testing abilities” in manner that “criminals could utilize to circumvent the law.