Case 1:12-cv-00127-BJR Document 40 Filed 03/04/15 Page 6 of 22 Info. Ctr., 384 F. Supp. 2d at 106 (quoting Military Audit Project v. Casey, 656 F.2d 724, 738 (D.C. Cir. 1981). An agency “is not required to provide so much detail that the exempt material would be effectively disclosed.” Johnson v. Executive Office for U.S. Attorneys, 310 F.3d 771, 776 (D.C. Cir. 2002) (citing Mead Data Cent., Inc. v. U.S. Dep't of Air Force, 566 F.2d 242, 261 (D.C. Cir. 1977)). IV. ANALYSIS A. Adequacy of Search Plaintiff challenges the adequacy of the NSD’s and FBI’s respective searches. Where a plaintiff challenges the adequacy of a search under FOIA, the agency “must show beyond material doubt . . . that it has conducted a search reasonably calculated to uncover all relevant documents.” Weisberg v. United States Dep’t of Justice, 705 F.2d 1344, 1351 (D.C. Cir. 1983). To demonstrate the adequacy of the search, an agency may rely solely on “a reasonably detailed affidavit [or declaration], setting forth the search terms and the type of search performed, and averring that all files likely to contain responsive materials (if such records exist) were searched.” Valencia–Lucena v. U.S. Coast Guard, 180 F.3d 321, 326 (D.C. Cir. 1999) (quoting Oglesby v. U.S. Dep’t of Army, 920 F.2d 57, 68 (D.C. Cir. 1990)). Courts give substantial weight to an agency’s affidavits, and the presumption of good faith accorded to such affidavits “cannot be rebutted by purely speculative claims about the existence and discoverability of other documents.” Nat’l Whistleblower Ctr. v. Dep't of Health & Human Servs., 849 F. Supp. 2d at 22 (quoting SafeCard Servs. Inc. v. Sec. & Exch. Comm’n, 926 F.2d 1197, 1200 (D.C. Cir. 1991)) (internal quotation marks omitted). 1. NSD Has Failed to Demonstrate an Adequate Search Upon receiving Plaintiff’s request, NSD FOIA personnel determined that the Counterespionage Unit (CES) was likely to have responsive records. Def.’s Mot., Ex. 3 (1st 6

Select target paragraph3