atives of a deceased individual retain privacy interests in their information, even after the individual's death. See generally National Archives v. Favish, 124 S. Ct. 1570 (2004). 33 EFTA00015251 --- PAGE BREAK --- Author: CGM Reviewed: TLC 3/10/21, 3/11/21 Deliberative Process/Attorney-Client/A

identifying information in records containing allegations of abuse by military personnel and by other detainees); Nat'l Archives & Records Admin. v. Favish, 541 U.S. 157, 124 S.Ct. 1570, 158 L.Ed.2d 319 (2004) (holding Freedom of Information Act ("FOIA") recognizes surviving family members' right to pe