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FIA-13-0056 - In the Matter of National Security Archive

On August 28, 2013, the Office of Hearings and Appeals (OHA) issued a decision denying an appeal (Appeal) from a Freedom of Information Act (FOIA) determination issued by the Office of Information Resources.  The Appellant appealed OIR’s decision to withhold information contained in two released documents pursuant to Exemption 5.  Those documents were from 1980 and concerned a meeting regarding the United States’ oil supply agreement with Israel. One document was an interagency memorandum to the DOE Secretary and the other was a memorandum addressed to the President.  OHA reviewed the released documents and determined that presidential communications privilege applied to withhold the memorandum to the President and that the deliberative process privilege was properly invoked as to the memorandum addressed to the DOE Secretary.  Thus, OHA denied the Appeal.