Participated in an amicus brief (with other amici) filed with the U.S. Court of Appeals for the Second Circuit in ACLU v. Central Intelligence Agency. The brief notes the intent of Congress that courts can and must conduct a de novo review of all claims of exemptions under the Freedom of Information Act, including those premised on national security – contrary to the assertion of the CIA in this case. The brief argued that the district court conducted a careful de novo review of the CIA’s exemption claims, just as Congress intended, and thus the court’s ruling should be upheld. [2018]