What is the test for adequacy of a search by the US Department of Justice?

MultiRegion, United States of America

The following excerpt is from Citizens Com'n on Human Rights v. Food and Drug Admin., 45 F.3d 1325 (9th Cir. 1995):

The adequacy of the agency's search is judged by a standard of reasonableness, construing the facts in the light most favorable to the requestor. See Zemansky v. EPA, 767 F.2d 569, 571 (9th Cir.1985) ("The agency must: demonstrate that it has conducted a search reasonably calculated to uncover all relevant documents." (quotations omitted)). Despite CCHR's arguments about the missing volumes, "the issue to be resolved is not whether there might exist any other documents possibly responsive to the request, but rather whether the search for those documents was adequate." Id. (quotation omitted).

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