Specifically, CREW requests all records related to the now-closed investigation conducted by DOJ and the Federal Bureau of Investigation (“FBI”) of Rep. [...] If it is your position that a document contains non- Case 1:24-cv-01497 Document 1-5 Filed 05/21/24 Page 3 of 5 exempt segments, but that those non-exempt segments are so dispersed throughout the document as to make segregation impossible, please state what portion of the document is non-exempt, and how the material is dispersed throughout the document. [...] The subject of this request concerns the operations of the federal government, and the disclosures likely will contribute to a better understanding of relevant government procedures by CREW and the general public in a significant way. [...] CREW is committed to protecting the public’s right to be aware of the activities of the activities of government officials, to ensuring the integrity of those officials. [...] 1989) (holding that non-profit was a “representative of the news media” and broadly interpreting the term to include “any person or organization which regularly publishes or disseminates information to the public”).
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