Case 1:12-cv-00127-BJR Document 40 Filed 03/04/15 Page 10 of 22
Nevertheless, the FBI interpreted “Plaintiff’s request broadly,” and “concluded that records
concerning its investigation of the disclosure of the classified information that was published on
the WikiLeaks website would be responsive to Plaintiff’s request.” Hardy 1st Decl. n.3.
Plaintiff now argues that FBI failed to follow through on “obvious leads to discover
requested documents” because it only used one search term, WikiLeaks. Pl.s’ Cross-Mot.
Summ. J. at 22. FBI responds that while it began its search using the term WikiLeaks, it
“broadened its search by using the information obtained to contact particular case agents and
identify additional investigative files that likely contained responsive information.” Def.’s Mot.
at
The Court finds that FBI’s search for responsive records was adequate. The FBI used the
key term WikiLeaks to search its CRS, but its search efforts did not cease there. The FBI then
used the results of the CRS search to locate the case agents working with potentially responsive
material. The Court deems that this strategy was especially reasonable given that the term
WikiLeaks is repeatedly stated in Plaintiff’s FOIA request when describing each group of
requested documents. See Defs.’ Mot. Summ. J., Exs. 1A, 3-1, 5-1. Once identifying the case
agents, the FBI requested that these case agents review their files for further responsive
documents, specifically referring to the language in Plaintiff’s FOIA request. The Court finds
that the FBI’s use of the term WikiLeaks at the initial stages of the search was reasonable in light
of the Plaintiff’s own consistent use of term when drafting its FOIA request, as well as the FBI’s
later search efforts with its case agents that went beyond the term WikiLeaks.
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