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EFTA00084929
the administrative level before refusing to produce records contained in its investigative files." Tipogaph v. Dept of Justice, 83 F. Supp. 2d 234 (D.D.C. Mar. 18.2015) In addition, the FOIA Improvement Act of 2016 added a provision instructing federal agencies to withhold records only when their release would wor
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