1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JEREMY PINSON ) ) Plaintiff, ) ) Civil Action No.: 12- 1872 (RC) v. ) ) Re Document No.: 403 DEPARTMENT OF JUSTICE, et al. , ) ) Defendants. )

MEMORANDUM OPINION
G RANTING IN P ART AND D ENYING IN P ART D EFENDANTS ’ F OURTH M OTION F OR S UMMARY J UDGMENT Jeremy Pinson is a pro se plaintiff who, while in prison, has filed multiple Freedom of Information Act (“FOIA”), 5 U .S.C. § 552, requests seeking reco rds from various components of the United States Department of Justice (“DOJ”). DOJ has filed its fourth motion for summary judgment on Pinson’s requests to t he Federal Bureau of Prisons (“BOP”), claiming that it has performed adequate searches for r ecords responsive to Pinson’s requests, released a number of records, and informed Pinson that some of the records she 1 sought were exempt from disclosure by law. Pinson did not file a n opposition to DOJ’s motion. In its prior opinions, this C ourt has granted in part and deni ed in part DOJ’s first, second, and third motions for summary j udgment as to claims against BOP

. See Pinson v. U.S. Dep’t of
Justice , No. 12–1872, 2016 WL 29245, at *1 (D.D.C. Jan. 4, 2016); Pinson v. U.S. Dep’t of
Justice , 199 F. Supp. 3d 203 (D.D.C. 2016); Pinson v. U.S. Dep’t of Justice , 236 F. Supp. 3d 338

1 Pinson identifies using femin ine pronouns. This Court adopts P inson’s usage. See Pinson v. U.S. Dep’t of Justice , 273 F. Supp. 3d 1, at 4 n.1 (D.D.C. 2017). The Court’s use of feminine pronouns does not convey a ny substantive or legal char acterization.2 (D.D.C. 2017). Now before the Court is DOJ’s fourth motion for summary judgment as to the ten remaining FOIA requests to BOP. 2 See Defs.’ 4th Mot. Summ. J. Respect BOP (“Defs.’ 4th MSJ”), ECF No. 403. DOJ argues that BOP has conducted searches reasonably calculated to identify records responsive to P inson’s requests and has releas ed to Pinson those records not withheld pursuant to the a pplicable FOIA exemptions. See Defs.’ Mem. P. & A. (“Defs.’ Mem.”) at 4, ECF No. 403-1. For the reasons s et forth below, the Court grants in part and denies in part DOJ’s motion for summary judgment.
I. FACTUAL BACKGROUND The Court has already explaine d the factual background in this case in its first Memorandum Opinion. See Pinson , 2016 WL 29245, at *1–8. The Court assumes familiarity with its prior opinion and confines its discussion to the facts most relevant to the present motion. The current motion concerns BOP’s searches for records responsi ve to Requests Nos. 2011- 7156, 2012-39, 2012-40, and 2013-1684; BOP’s withholding of rec ords responsive to such requests pursuant to several FOI A exemptions; and BOP’s reproce ssing of Request Nos. 2010- 12533, 2011-1351, 2011-1886, 2011-2366, 2011-7619, 2012-39, 3 and 2012-975.
A. Request Nos. 2011-7156, 2012-39, and 2012-40 (E-mail Searches) Request No. 2012-40 and the portions of Request Nos. 2011-7156 and 2012-39 that were not yet processed at the time of t his Court’s third memorandum opinion concern certain BOP email records. BOP initially could not perform a search of its email archives due to technical

2 While DOJ’s filings state that it moves for summary judgment w ith respect to nine remaining requests, the Court counts ten remaining requests. See Defs.’ Mem. at 1–2 (requesting summary judgment as to Request Nos. 2010-12533, 2011-1351, 2011 -1886, 2011-2366, 2011- 7156, 2011-7619, 2012-39, 2012-40, 2012-975, and 2013-1684).

3 BOP has reprocessed the non- email portions of Request No. 2012 -39 following the Court’s previous opinion.3 problems, but in October 2016, the s earch tool was fixed and BO P subsequently performed searches for responsive records. See Pinson , 236 F. Supp. 3d at 356–57. However, at the time of DOJ’s third request for summa ry judgment, Pinson had not yet re ceived a response because the search results were still bei ng evaluated for potential FOIA ex emptions. See id. at 357. Thus, this Court deemed that summary judgme nt as to the email portions of these requests was “still not appropriate because the agency has not yet fully discharged its FOIA obligation.” Id. BOP has since completed evaluating these records for potential exemptio ns and responded to Pinson. In Request No. 2011-7156, Pinson sought, among other records, 4 “emails between Central Office staff regarding [her] ADX referral” and “emails between SERO Regional staff regarding [her] ADX referral.” 7th Decl. of Kara Christenson (“ 7th Christenson Decl.”) ¶ 8, ECF No. 403-3. Pinson limited her reques t to no more than two hours search time and no more than 100 pages. Id. After completing its search, B OP responded to Pinson in a lett er dated February 28, 2017, informing her that there w ere no records responsive t o her request for emails. See id. ¶ 11 & Ex. B. DOJ now moves for summary judgment on the grounds t hat BOP’s search was “reasonably calculate d to uncover all documen ts in its files re sponsive to [Pinson’s] requests.” Defs.’ Mem. at 4. In Request No. 2012-39, Pinson sou ght, among other records, 5 “[a]ll emails, memorandums by ADX Florence Executiv e Staff and/or Department S upervisors written or generated in connection with t he 2011 Accreditation review by t he ACA and/or making

4 This Court granted summary judg ment as to the adequacy of BOP’ s search for nonemail records responsive t o Request No. 2011-7156 in its previo us opinion. See Pinson , 236 F. Supp. 3d at 357.

5 This Court granted summary judg ment as to the adequacy of BOP’ s search for nonemail records responsive to Request No. 2012-39 in its previous opinion. See Pinson , 236 F. Supp. 3d at 357.4 reference or mentioning such rev iew.” 7th Christenson Decl. ¶ 1 2 & Ex. C. Pinson limited this request to no more than two hours search time and no more than 100 pages. 7th Christenson Decl. ¶ 12. In a letter dated A pril 6, 2017, BOP responded to P inson’s request and released seventy-five pages of records i n full and eighteen pages in par t. Id. ¶ 16 & Ex. D. Under Exemption 6, BOP withheld the “ telephone extensions and direct telephone numbers of Bureau staff”; “the names of third- party, non-BOP employees who would be conducting an ACA audit”; and “the name of a third-part y, non-BOP employee who assisted w ith a pre-ACA audit.” Id. ¶¶ 19–21; Vaughn Index at 1–3, ECF No. 403-3. BOP also invoked Exemption 7 to w ithhold “information . . . related to the i nstitution’s policies [on] t ools and keys.” 7th Christenson Decl. ¶¶ 26–27; Vaughn Index at 1–3. DOJ now moves for summary judgment on the ground s that BOP’s search was adequate and th at it released to Pinson all no n-exempt records responsive to her request. See Defs.’ Mem. at 4. In Request No. 2012-40, Pinson sought “production of all emails sent by the North Central Regional Director and War den of the U.S. Penitentiary A dministrative Maximum during 2011.” 7th Christenson Decl. ¶ 28. Pinson limited this request to no more than two hours search time and no more than 100 pages. Id. In a letter dated Febru ary 28, 2017, BOP informed Pinson that there were no records re sponsive to her request. Id. ¶ 31 & Ex. G. DOJ now moves for summary judgment on the grounds that BOP’s search was “reasonab ly calculated to uncover all documents in its files responsive to [Pinson’s] requests.” Defs .’ Mem. at 4.
B. Request No. 2013-1684 In November 2011, Pinson requested “production of all informati on produced on or after February 25, 2011 which is located in the Central File, SIS Fil e, and any other file maintained on Jeremy Pinson.” 7th Christenson D ecl. ¶ 32 & Ex. H. After an in itial fee was assessed, Pinson5 modified her request to no longer seek documents from her Centr al File on or before October 1, 2014, or her SIS file between F ebruary 25, 2011 and October 201 3. Id. ¶ 33 & Ex. I. In a letter dated October 23, 2017, BOP responde d to Pinson’s request and r eleased 13,690 pages of records in full and 1481 pages of records in part, and it withh eld 2,325 pages in full. Id. ¶ 45 &
Ex. L. Claiming both Exemptions 6 and 7(C), B OP withheld “the names, r egister numbers, medical information, statements made to law enforcement officer s, and correctional management of third-party inmates”; “the na mes, injuries and other medical information, photographs of their faces, injuries and property, and employment information for [B OP] staff”; “the names of staff who participated in cal culated uses of force and their role on the team”; “the Daily Assignment Rosters for institutions”; “the telephone extensions, direct numbers, and facsimile extensions of Bureau staff”; “the names and pers onal identifyi ng information of individuals associated with a statute-based programming assignmen t used to manage Pinson”; an d “the name of a criminal Assistant U.S. Attorney and the na mes of law enforcement invest igative agents associated” with certain agencies, as well as the ir “contact information, such a s telephone numbers, e-mail addresses, and addresses.” 7th Christenson Decl. ¶¶ 53–72. Using Exemption 7(E), BOP withheld “information . . . consist[i ng] of the Central Inmate Monitoring (CIM), separations, a nd other internal assignments u sed to classify and monitor Pinson and other third-party in mates”; “discussions of gang and informant activity within the [BOP]”; “techniques for investig ating criminal activity within a prison facility [and] factual information developed using these underlying techniques”; “docu ments associated with a statutebased programming assignment used t o manage Pinson”; “steps use d to resolve major crises in a Bureau facility”; “description of the Bureau’s calculated use o f force technique and a photo of6 the technique being used”; and “i nvestigative reports from an i ntelligence database used by BOP staff during law enforce ment investigations.” Id. ¶¶ 81–96. Using Exemption 7(F), BOP withhel d “factual information [which] , if known, would adversely affect Pinson’s safety”; “the Bureau’s monitoring and classification a ssignments for Pinson and third-party inmates”; “ ‘yes’ and ‘no’ response areas to [certain] questions on an Intake Screening Form”; “a porti on of Pinson’s Administrative D etention Order Forms that elaborates on the reason for re moval from general population”; “techniques for investigating criminal activity within a pris on facility”; “the names and reg ister numbers of third-party inmates from whom . . . Pinson needed to be separated”; “documents asso ciated with a statute-based programming assignment used to man age Pinson”; “the institution ’s policies [on] tools and keys”; “photographs of locks on cell door and hand restraints”; “steps used to resolve major crises in a Bureau facility”; “‘ye s’ or ‘no’ response areas to questions on a Screening for Risk of Victimization and Abusiveness Form completed for Pinson”; “the names of staff who participated in calculated uses of force and their role on the team”; “the Daily Assignment Rosters for institutions”; and “a description of the Bureau’s c alculated use of force technique and a photo of the technique being used.” Id. ¶¶ 81–96. DOJ now moves for summary judgmen t on the grounds that BOP’s se arch was adequate and that it has released to Pins on all non-exempt records respo nsive to her request. Defs.’ Mem.
at 4.
C. Request No. 2010-12533 (Reprocessing) In August 2010, Pinson requeste d from BOP “(1) inmate handbooks from ADX Florence and (2) documents relating to the use of force against Pinson d uring November 2007 and any related Administrative Remedy Requests.” Pinson , 236 F. Supp. 3d at 345. DOJ subsequently7 released responsive records, w ith some withholdings, and moved for summary judgment. Id . In its previous opinion, this Court ag reed with DOJ that BOP’s sea rch was adequate, but denied summary judgment reg arding the use of Exemption 5 to withhold s ections of multiple After Action Review Reports because BOP failed to “define the nature of the deliberative process involved.” See id. at 360. BOP has reprocessed this reque st and, in a letter dated April 6 , 2017, released two pages in full and three pages in part . 7th Christenson Decl. ¶ 97 & E x. M. Upon reprocessing, the information regarding “after act ion recommendation/results” and “whether the after action was determined appropriate and the r ecommendations/results,” previo usly withheld under Exemption 5, was released. 7th Christenson Decl. ¶ 100; Vaughn Index at 87–88. Sections of an After Action Review Report from November 18, 2007, previously withhel d under Exemption 5, was again withheld, this time under Ex emption 7(E). 7th Christenson Decl. ¶ 99; Vaughn Index at 87–88. DOJ now moves for summar y judgment on the ground that BO P has released all nonexempt records responsive to Pin son’s request. Defs.’ Mem. at 4

. D. Request No. 2011-1351 (Reprocessing) In 2011, Pinson submitted a request to BOP for production of “‘ [a]ll After-Action Review Reports, pertaining to any i nmate on inmate assault and/ or homicide’ occurring at FCI Talladega during 2009-2010.” Pinson , 236 F. Supp. 3d at 347; see also 3d Christenson Decl. ¶ 53 & Ex. F, ECF No. 293-3. After rel easing some responsive docu ments—with withholdings under Exemptions 5 and 7(F)—DOJ moved for summary judgment. See Pinson , 236 F. Supp. 3d
at 347. In its previous opinion, this Cour t agreed with DOJ that its se arch in response to Request No. 2011-1351 was adequate, but denied summary judgment as to t he use of Exemption 5 to8 withhold sections of multiple After Action Review Reports becau se BOP failed to “define the nature of the deliberative process involved.” Id. at 360; Vaughn Index at 89–93. BOP has reprocessed this reque st and, in a letter dated April 6 , 2017, released to Pinson nine pages of records in part . 7th Christens on Decl. ¶ 101 & Ex . N. Upon reprocessing, BOP released sections on whether the use of force was appropriate, but it applied Exemption 7(E) to withhold the remaining sections on discrepancies noted and reco mmendations/results regarding the use of force. 7th Christenson Decl. ¶ 103; Vaughn Index at 89–93. After reprocessing Document 2 in the request, BOP r eleased information previously withheld under Exemption 5. 7th Christenson Decl. ¶ 104; Vaughn Index at 90–91. DOJ now moves for summary judgment on the ground that BOP has release d all non-exempt records respons ive to Pinson’s request. Defs.’
Mem. at 4.
E. Request No. 2011-1886 (Reprocessing) In 2010, Pinson requested from BO P the production of “documents associated with her placement at ADX Florence.” Pinson , 236 F. Supp. 3d at 347; see 3d Christenson Decl. ¶ 64 & Ex. H. In its disposition of DOJ’s third motion for summary jud gment, the Court denied DOJ’s motion as to the use of Exemp tion 5 to withhold comments and re commendations made by staff regarding the future management of Pinson because BOP “failed t o specify the role of the document in the deliberative pr ocess, or the nature of the deci sionmaking authority vested in each party.” Pinson , 236 F. Supp. 3d at 361. Furthermore, the Court denied summaryjudgment as to the use of Exemption 7(F) t o withhold several staff membe rs’ responses to questions posed by Pinson regarding her ADX referra l because the “potential harm is too speculative in the absence of some explanation a s to why these responses could not. . . be anonymized.” Id. at 371. Additionally, the Court denied su mmary judgment as to the use o f Exemption 7(F) to withhold9 Pinson’s Presentence Investigation Report (“PSR”) because it wo uld satisfy both BOP’s safety concerns and its FOIA obligati ons to release the PSR to Pinson’ s appointed counsel rather than simply denying the request. See id. at 371–72. This Court granted summary judgment as to all other documents within the request. See id. at 374. BOP has now reprocessed Pinson’s request, and in a letter dated April 6, 2017, explained that it has released seventy-sev en pages in full and fifty-seve n pages in part, and three pages were withheld in full. 7th Chr istenson Decl. ¶ 105 & Ex. O. “[C ]omments made by a staff member regarding the future management of Pinson,” previously w ithheld under Exemption 5, were released. Vaughn Index at 94; see 7th Christenson Decl. ¶ 107. BOP also removed the application of Exemption 5 to “a staff member’s recommendation regarding the future management of Pinson” in Documents 21–23, 25, and 35 and releas ed what it determined was segregable from information this Court previously held exempt u nder Exemptions 6, 7(C), 7(E), and 7(F). 7th Christenson Decl. ¶ 108; Vaughn Index at 97–102. As for the responses to witness forms used during Pinson’s referr al hearing to ADX Florence tha t were previously withheld under Exemption 7(F), BOP releas ed some responses, but not all. 7th Christenson Decl. ¶ 109. BOP determined that it could rel ease the response s to other que stions, but releas ing responses to questions number eight and nine in Documents 8–11 and questions number three, four, and eight in Documents 12–17 would increase the risk to Pinson of being t argeted for assault. Id. ¶¶ 109– 111. Pinson’s PSR, however, was disc losed in full to counsel fo r Pinson. Id. ¶ 112; Vaughn Index at 102. DOJ now moves fo r summary judgment on the ground that BOP has released all non-exempt records responsive to P inson’s request. Defs.’ Mem. at 4.10 F. Request No. 2011-2366 (Reprocessing) In December 2010, Pinson submitted a request to BOP to produce copies of “any final settlement resulting in a [p]laintiff receiving monetary compen sation arising from litigation against officers or employees of the [BOP] in Lewisburg, PA; Oa kdale, LA; Talladega, AL, from 2006-[2010].” Pinson , 236 F. Supp. 3d at 348; 3d Christe nson Decl. ¶ 95 & Ex. J. BO P subsequently released responsive records to Pinson—with some wi thholdings—and filed its third motion for summary judgment. See Pinson , 236 F. Supp. 3d at 348. This Court granted DOJ’s motion as to the adequacy of its search in response to Request No. 2011-2366. See id. at 355. However, it denied summary judg ment as to the use of Exemptions 6 and 7(C) to withhold the names of individuals, individuals ’ addresses, and case numbers because BOP did not “sufficiently explain the privacyinterests of the individuals ‘involved’ in each claim.” Id. at 363. Following this Court’s opinion, B OP reprocessed Pinson’s reque st and, by letter dated April 6, 2017, released two pages in full and four pages in part. 7th Christenson Decl. ¶ 113 & Ex. P. Regarding a settlement agr eement in a federal case, BOP conducted a privacy analysis for each individual involv ed and released the name of the federal d istrict court involved in the case, the name and address of the plaint iff’s attorney’s law firm, an d the notary public’s information.
Id. ¶¶ 115, 118–19. However, BOP again applied Exemption 6 to with hold the plaintiff’s name, signature, and case number; the A ssistant U.S. Attorney’s (“AUS A”) name, signature, and direct telephone number; and the plainti ff’s attorney’s name and signa ture. Id. ¶¶ 116–19; Vaughn Index at 103–04. As to a settlemen t offer letter made to an inm ate in a BOP administrative claim process, BOP reviewed the privac y interests of the claimant and staff member and released the name of the Regional Counsel i nvolved. 7th Christenson Decl. ¶¶ 120, 122. However, BOP applied Exemption 6 to withhold the claimant’s name, address, a dministrative claim number, and11 civil case number, as well as th e Regional Counsel’s signature. Id. ¶¶ 120–21; Vaughn Index at 103–04. DOJ now moves for summary judgment on the ground that B OP has released all nonexempt records responsive to Pin son’s request. Defs.’ Mem. at 4

. G. Request No. 2011-7619 (Reprocessing) In May 2011, Pinson requested fro m BOP “(1) All Report of Incid ent (Form 583) regarding homicides within the Bureau of Prisons since 2008, (2 ) all documents related to Report of Incident Tracking #BMP 332.07, (3) Video recording ECN BMP-0 7599-A, (4) All documents mentioning, involving, or relevant t o Incident Report Nos. 1639 219, 1639220, 2033414, (5) Anything related to the removal of televisions from ADX Special Housing Unit at ADX Florence, and (6) Anything relate d to policies, pr ocedures or g uidelines for issuance of a clock radio to SHU inmates at ADX Florence.” Pinson , 236 F. Supp. 3d at 350–51; 3d Christenson Decl. ¶ 126 & Ex. N. BOP subsequen tly released records responsi ve to Pinson’s request—with some withholdings—and noted that a dditional records responsive to the request may have existed at some point, but were destroyed according to BOP poli cy during the two years Pinson failed to satisfy her delinquent fees. See id. at 355–56.The Court grante d summary judgment as to the adequacy of BOP’s search and the use of Exemptions 6, 7( C), and 7(E) to withhold information in multiple Incident Reports. See id. at 355–56, 374. However, the Court denied summary judgment as to the use of Exemption 7(F) to withhold th e classification of various reported incidents because BO P failed to explain why the purpor ted increased risk of harm to Pinson from disclosure “coul d not be addressed by redacting the name of the victim . . . instead of withholding the entire classification.” Id. at 371–72. BOP has reprocessed the request following the Court’s prior op inion, and in a letter dated April 6, 2017, released fifty-four pages in full and eight page s in part, and withheld two pages in12 full. See 7th Christenson Decl. ¶ 123 & E x. Q. The information in the “T ype of Incident” and “Cause of Incident” sections prev iously withheld under Exemptio n 7(F) was released. 7th Christenson Decl. ¶ 125; Vaughn Index at 105–06. DOJ now moves for summary judgment on the ground that BOP has release d all non-exempt records respons ive to Pinson’s request. Defs.’
Mem. at 4.
H. Request No. 2012-39 (Reprocessing) In September 2011, Pinson sought, “Re port of Incident and After -Action Review Report written, produced or generate d in connection with the 2008 U.S. Penitentiary High riot at Florence, CO” and some email records. 6 Pinson , 236 F. Supp. 3d at 351. BOP released responsive records—with some w ithholdings—and DOJ subsequently requested summary judgment. This Court granted su mmary judgment as to the adequac y of the non-email portions of the search. Id. at 357. However, this Court denie d summary judgment as to the use of Exemption 5 to withhold information in an Aft er Action Review Report, a d ocument discussing steps for reaccreditation, and a document describing the preliminary cause of death of inmates and estimating costs because BOP “fa iled to specify the role of the document[s] in the deliberative process, or the nature of the de cisionmaking authority vested i n each party.” Id. at 361. Following this Court’s opinion, BOP reprocessed this request an d, in a letter dated April 6, 2017, released to Pinson five page s in full and eight in par t, and it withheld three pages in full.
See 7th Christenson Decl. ¶ 126 & Ex. R . BOP withdrew its previous withholdings and redactions under Exempti on 5. 7th Christenson Decl. ¶¶ 128–29. However, within a section previously withheld under Exem ption 5 in an incident report dat ed April 20, 2008, it applied

6 As noted above, portions of the r esponse to this request was a ffected by a malfunction in BOP’s email search tool. Thi s reprocessing only pertains to non-email searches and emails that were not affected by the m alfunction at the time of this C ourt’s third memorandum opinion.13 Exemption 7(E) to withhold inf ormation on the weapons used duri ng the incident. Id. ¶ 129; Vaughn Index 107–08. DOJ now moves for summary judgment on the ground that BOP has released all non-exempt records responsive to Pinson’s request. Defs.’ Mem. at 4.
I. Request No. 2012-975 (Reprocessing) In October 2011, Pinson submitted a request to BOP for “the ‘2 010-2011 U.S. Penitentiary Admin. Max. - Flore nce, CO Administrative Remedy I ndex’” and “all 2010-2011 Form 583 Report of Incident[s] f rom ADX Florence reporting Inma te on Inmate assaults to the
NRCO.” Pinson , 236 F. Supp. 3d at 351; 3d Christenson Decl. ¶ 162 & Ex. T. B OP subsequently released responsive records—w ith some withholdings—and DOJ move d for summary judgment. This Court granted DOJ’s motion a s to the adequacy of its searc h. See Pinson , 236 F. Supp. 3d at 355. However, the Court denied su mmary judgment as to the appli cation of Exemption 7(F) to “information regarding an assaul t on an inmate and attachments [to the form]” in multiple incident reports because BOP’s assertions of risk of harm were “too vague” and did not “explain why BOP could not simply anonymize the names of the inmates.” Id. at 372. Furthermore, BOP gave no description of the contents of the attachments or an ex planation of the danger posed by their release. Id

. After this Court’s previous opi nion, BOP, in a letter dated Ap ril 6, 2017, released to Pinson eight pages in full and f orty pages in part. 7th Christe nson Decl. ¶ 130 & Ex. S. BOP removed its application of Exe mption 7(E) and 7(F) from the “De scription of Incident and Attachments Sections,” and ins tead applied Exemptions 6 and 7(C ) to these documents, using them to withhold “inmate names a nd register numbers” and “file names that included names of inmates.” Id. ¶ 133; Vaughn Index at 110–23. DOJ now moves for summary judgment on the14 ground that BOP has released all no n-exempt records responsive to Pinson’s request. Defs.’
Mem. at 4.
II. LEGAL STANDARD “FOIA cases typically and appr opriately are decided on motions for summary judgment.” Defs. Of Wildlife v. U.S. Border Patrol , 623 F. Supp. 2d 83, 87 (D.D.C. 2009) (citing Bigwood v. U.S. Agency for Int’l Dev. , 484 F. Supp. 2d 68, 73 (D.D.C. 2007)). S ummary judgment is appropriate where “the movant shows that there is no genuine di spute as to any material fact and the movant is entitled to judgmen t as a matter of law.” Fed. R. Civ. P. 56(a). A “material” fact is one capable of affecting the substantive outcome of the litigat ion. Anderson v. Liberty Lobby,
Inc. , 477 U.S. 242, 248 (1986). A dispute is “genuine” if there is enough evidence for a reasonably jury to return averdict for the nonmovant. See Scott v. Harris , 550 U.S. 372, 380 (2007). In a motion for summary judgment, the movant “always bears the initial res ponsibility of informing the district court of the basis for its motion, and i dentifying those [records] . . . on file, together with the affidavits, if any, which it believes demonst rate the absence of a genuine issue of material fact.” Celotex Corp. v. Catrett , 477 U.S. 317, 323 (1986). In response, the nonmovant must point to specific facts in t he record that reveal a genuin e issue that is suitable for trial. Id. at 324. In considering a motion for s ummary judgment, the court “m ust view the evidence in the light most favorable to the nonmoving party, . . . draw all rea sonable inferences in her favor, and eschew making credibility determ inations or weighing the eviden ce.” Czekalski v. Peters , 475 F.3d 360, 363 (D.C. Cir. 2007). When a court assesses a summar y judgment motion in a FOIA case, it must determine whether the defending agency ha s shown “beyond material doubt [ ] that it has conducted a15 search reasonably calculated to un cover all relevant documents. ” Morley v. CIA , 508 F.3d 1108, 1114 (D.C. Cir. 2007) (internal quotation marks and citations o mitted). In determining the adequacy of a search methodology, t he court applies a reasonabl eness test. Id. (citing Campbell v. U.S. Dep’t of Justice , 164 F.3d 20, 27 (D.C. Cir. 1998)). Furthermore, the court mak es a de

novo assessment of whether the agenc y has properly withheld the req uested documents under a FOIA exemption. See 5 U.S.C. § 552(a)(4)(B); Judicial Watch v. U.S. Dep’t of Homeland Sec. , 598 F. Supp. 2d 93, 95 (D.D.C. 2009). “Ul timately, an agency’s justification for invoking a FOIA exemption is sufficient if it appears ‘logical’ or ‘plausi ble.’” Wolf v. CIA , 473 F.3d 370, 374–75 (D.C. Cir. 2007) (quoting Gardels v. CIA , 689 F.2d 1100, 1105 (D.C. Cir. 1982)). Thus, to prevail on a motion for sum mary judgment, the defending agen cy “must demonstrate that ‘each document that falls within t he class requested either has been produced, is unidentifiable or is wholly [or partially] exempt fr om the Act’s inspection requi rements.’” Citizens for Ethics & Responsibility in Wash. v. Dep’t of Labor , 478 F. Supp. 2d 77, 80 (D.D.C. 2007) (citing Goland
v. CIA , 607 F.2d 339, 352 (D.C. Cir. 1978)). To meet its burden, a defendant agency may rely on declarations that are reasonably detailed and non-conclusory. See id. “[T]he Court may award su mmary judgment solely on the basis of information provided by t he department or agency in de clarations when the declarations describe ‘the documents and the justifications for nondisclosur e with reasonably specific detail, demonstrate that the informati on withheld logica lly falls withi n the claimed exemption, and are not controverted by either contrar y evidence in the record nor by evidence of agency bad faith.’”
Id. (quoting Military Audit Project v. Casey , 656 F.2d 724, 738 (D.C. Cir. 1981)). Moreover, a reviewing court shoul d “respect the expert ise of an agency” and not “overstep the proper limits16 of the judicial role in FOIA review.” Hayden v. Nat’l Sec. Agency/Cent. Sec. Serv. , 608 F.2d 1381, 1388 (D.C. Cir. 1979). Even if the nonmovant has not r esponded to a motion for summaryjudgment, the court cannot grant the motion because it has been conceded. See Winston & Strawn, LLP v. McLean , 843 F.3d 503, 505 (D.C. Cir. 2016) “Under the Federal Rules of Civil Procedure, a motion for summary judgment cannot be ‘co nceded’ for want of opposition. ‘ The burden is always on the movant to demonstrate why summa ry judgment is warranted. The no nmoving party’s failure to oppose summary judgment does not sh ift that burden.’ The Distri ct Court ‘must always determine for itself whether the record and any undisputed mate rial facts justify granting summary judgment.’” Id. (quoting Grimes v. District of Columbia , 794 F.3d 83, 97 (D.C. Cir. 2015) (Griffith, J., concurring ) and citing Fed. R. Civ. P. 56( e)(3)).
III. ANALYSIS A. Adequacy of BOP’s Search In its fourth motion for summar y judgment, DOJ asserts that BOP ’s searches in response to Request Nos. 2011-7156, 2012-39, 2012-40 and 2013-1684 were adequate. 7 See Defs.’ 4th MSJ; Defs.’ Mem. at 4–8. Though Pinson has not contested the ad equacy of these searches, the Court will nonetheless independently determine whether undisput ed material facts justify granting summary judgment. The Cour t agrees that the searches w ith respect to Request Nos. 2011-7156, 2012-39, 2012-40, and 2013-1684 were adequate, and t herefore grants DOJ summary judgment on the adequ acy of these searches.

7 In its previous opinion, this C ourt granted summary judgment a s to the adequacy of BOP’s searches in respons e to Request Nos. 2010-12533, 2011-843 , 2011-1351, 2011-1886, 2011-2366, 2011-7619 2012-975, and the non-email portions of Re quest Nos. 2011-7156 and 2012-39. See Pinson , 236 F. Supp. 3d at 354–58.17 Under FOIA, an adequate search is one that is “reasonably calcu lated to uncover all relevant documents.” Morley , 508 F.3d at 1114 (internal citations omitted). The agency nee d not search “every record system” for the requested documents, but i t “must conduct a good faith, reasonable search of those sys tems of records likely to possess the requested records.” Marino v. Dep’t of Justice , 993 F. Supp. 2d 1, 9 (D.D.C. 2013) (citing Oglesby v. U.S. Dep’t of the Army , 920 F.2d 57, 68 (D.C. Cir. 1990)). When an agency seeks summaryjudgment on the basis that it conducted an adequate search, it mu st provide a “reasonably det ailed” affidavit describing the scope of that search. Iturralde v. Comptroller of the Currency , 315 F.3d 311, 313–14 (D.C. Cir. 2003) (quoting Oglesby , 920 F.2d at 68). It is not enough, how ever, for the affidavit to state in conclusory fashion that the agency “conducted a review of [the files] which would contain information that [the plainti ff] requested” and did not find an ything responsive to the request. Weisberg v. U.S. Dep’t of Justice , 627 F.2d 365, 370 (D.C. Cir. 1980). On the other hand, once the agency has provided a reason ably detailed affidavit describ ing its search, the burden shifts to the FOIA requester to produce “countervailing evidence” suggest ing that a genuine dispute of material fact exists as to the adequacy of the search. Morley , 508 F.3d at 1116 (citation omitted). However, even when the nonm ovant does not respond to a motion f or summary judgment, as is the case here, the Court will “determine for itself whether the record and any undisputed material facts justify granting summary judgment.” Grimes , 794 F.3d at 95. 1. Request Nos. 2011-7156, 2012-39, and 2013-1684 The Court agrees with DOJ that its searches in response to Request Nos. 2011-7156, 2012-39 and 2013-1684 were adequate. See Defs.’ Mem. at 4–8. DOJ provides a declaration from BOP showing that the sear ches were thorough and reasonablycalculated to uncover all relevant documents. See generally 7th Christenson Decl. The declarat ion describes in detail the18 requests for documents; the spec ific databases searched and why they were likely to contain responsive documents; 8 the search methodology employed; a nd the specific search terms used to locate the documents. See Defs.’ Mem. at 4–8; 7th Chr istenson Decl. ¶¶ 2–6, 11–16. The declaration is thus a “reasona bly detailed” des cription of the scope of BOP’s search for each of these requests. See Iturralde , 315 F.3d at 313–14; see also Hidalgo v. FBI , No. 10-5219, 2010 WL 5110399, at *1 (D.C. Cir. Dec . 15, 2010) (“[S]ubstantial wei ght traditionally [is] accorded [to] agency affidavits in FOIA ‘ adequacy of search’ cases.” (ci ting Chambers v. U.S. Dep’t of the
Interior , 568 F.3d 998, 1003 (D.C. Cir. 2009))). However, the Court dee ms it appropriate, despite a lack of response from Pinson, to specifically address the searches in response to Request Nos. 2011-7156 and 2012-39 because of the results of th ese searches. The D.C. Circuit has held that FOIA does not require a perfect search, only an adequate

one. Meeropol v. Meese , 790 F.2d 942, 956 (D.C. Cir. 1986). More over, “a search is no t unreasonable simply because it fails to produce all relevant ma terial.” Id. at 952–53. “Rather, the adequacy of a FOIA search is generally determined not by the fr uits of the search, but by the appropriateness of the methods us ed to carry out the search.” Ancient Coin Collectors Guild v. U.S. Dep’t of State , 641 F.3d 504, 514 (D.C. Cir. 2011). Furthermore, “[a]gency af fidavits are accorded a presumption of good faith, which cannot be rebutted by purely speculative claims

8 Regarding Request No. 2013-1684, w hich sought “production of a ll information produced on or after February 25, 20 11 which is located in the Central File, SIS File, and any other file maintained on Jeremy P inson,” BOP interpreted “any o ther file maintained on Jeremy Pinson” as a request for Medical and Psychology Records. 7th Ch ristenson Decl. ¶ 35. Though Ms. Christenson does not provide adetailed explanation for thi s interpretati on, Pinson has not contested the interpretati on, and this Court finds no reason in the record to rebut the presumption that the interpretation was made in good faith and based on BOP ’s expertise on what records are maintained on inmates. See SafeCard Servs., Inc. v. SEC , 926 F.2d 1197, 1200 (D.C. Cir. 1991) (“Agency affidavits are accorded a presumption of good faith, w hich cannot be rebutted by purely speculative claims about t he existence and discoverabili ty of other documents.”).19 about the existence and discove rability of other documents.” SafeCard Servs., Inc. , 926 F.2d at 1200 (quoting Ground Saucer Watch, Inc. v CIA , 692 F.2d 770, 771 (D.C. Cir. 1981)). Regarding Request No. 2011-7156, a lthough BOP’s search produced no responsive materials, Ms. Christenson’s d eclaration provides a reasonably detailed explanati on of the search terms used, the reasoning for the date range applied, and why t he email directories searched were likely to produce responsive rec ords. 7th Christenson Decl. ¶ 9 . As such, the declaration is sufficiently detailed to demonstrate the “appropriateness of th e methods used to carry out the search.” Ancient Coin Collectors Guild , 641 F.3d at 514. Similarly, although BOP’s search i n response to Request No. 201 2-39 produced some corrupted emails 9 —which were counted in BOP’s 200- page search limit and possiblyforeclosed additional, uncorrupted emails f rom being included in the relea se to Pinson—this Court similarly finds that the description of t he search methods employed is su fficient to establish that the search was adequate. The corrupted e mails contain blank bodies and onl y identify the s ender, subject line, and date. However, Pinson ha s not challenged the responsi veness of these records to her request for emails at least “mak ing reference or mentioning” th e 2011 Accreditation. 7th Christenson Decl. ¶ 12. Furthermor e, a finding that the search was inadequate because inclusion of the corrupted emails foreclos ed inclusion of uncorrupted ema ils would merely be a “speculative claim about the e xistence and discoverability of o ther documents.” SafeCard Servs. , 926 F.2d at 1200. Accordingly, the Court grants DOJ’s motion fo r summary judgment with respect to the adequacy of BOP’s searches for records responsiv e to Request Nos. 2011-7156, 2012-39, and 2013-1684.

9 BOP searched the email director ies of Peter Blu dworth and Chri s Synsvoll, but only the emails located in Bludworth’s d irectory were corrupted. 7th Chr istenson Decl. ¶ 15.20 2. Request No. 2012-40 Lastly, the Court finds that BOP’ s search for records responsiv e to Request No. 2012-40, which sought “production of all ema ils sent by the North Centra l Regional Director and Warden of the U.S. Penitentiary Adm inistrative Maximum during 2011,” w as adequate. 7th Christenson Decl. ¶ 28. FOIA does not require an agenc y to retain records, but only to provide access to records that have been retained. Kissinger v. Reporters Comm. for Freedom of the Press , 445 U.S. 136, 151–52 (1980). Furthermore, “[a]n agency need not establish bey ond doubt that it does not possess a document.” Whitaker v. CIA , 31 F. Supp. 3d 23, 46 (D.D.C. 2014) (internal citation and quotation marks omitted). How ever, if the agency is no long er in possession of responsive records, it cannot be for a reas on that is itself “suspect.” See SafeCard Servs., Inc. , 926 F.2d at 1201 (finding that an agency’s search was adequate because the agency’s affidavit had explained that the FOIA contact had determined that certain documents wer e of the type that the agency did not keep). In the present case, Ms. Christe nson attests th at a search for “ allemails sent” by Michael Nalley, North Central Regional Di rector of BOP, and Blake Davis , Warden of ADX Florence, during the entirety of 2011 produced no responsive records. 7th Christenson Decl. ¶¶ 29–30. Ms. Christenson provides some clar ity by explaining that, under the Netmail system, “[r]egular email messages are flagged for a seven year retention and emails flag ged as trash are subject to a 45- day retention period.” Id. ¶ 5. While one could question as “ suspect” the fact that two h igh-level BOP officials sent no emails for ayear (or that BOP failed to retain any of those emails after their departure from the agenc y), Pinson has not presented any countervailing evidence to indicate that BOP does in fact s till maintain these emails. For example, it is possible that both of21 these officials marked all of t heir emails as trash during thatyear or at the time of their departure if more than forty-five days prior to the time the searches wer e conducted. Because Pinson has not raised any countervailing evide nce to indicate that BOP’s s earch was inadequate, the Court grants DOJ summary judgment as to the adequacy of BOP’s search for records responsive to Request No. 2012-40. B. FOIA Exemptions DOJ asserts that BOP properly invoked Exemptions 6, 7(C), 7(E) , and 7(F) when it redacted or withheld certain inf ormation from responsive record s. See Defs.’ 4th MSJ; Defs.’ Mem. at 4; see generally Vaughn Index. The Court will evaluate each invoked exemption in turn. “[D]isclosure, not secrecy, is the dominant objective of [FOIA ].” Dep’t of the Air Force
v. Rose , 425 U.S. 352, 361 (1976). “Consistent with this purpose, agen cies may withhold only those documents or portions the reof that fall under one of nine delineated statutory exemptions.”
Elliot v. USDA , 596 F.3d 842, 845 (D.C. Cir. 2010) (ci ting 5 U.S.C. § 552(b)) . “[T]he exemptions are ‘explicitly exclusive.’” U.S. Dep’t of Justice v. Tax Analysts , 492 U.S. 136, 151 (1989) (quoting FAA Adm’r v. Robertson , 422 U.S. 255, 262 (1975)). The agency has the burden of show ing that withheld material fa lls within one of the statutory exemptions, see 5 U.S.C. § 552(a)(4)(B); see also Elliot , 596 F.3d at 845, and “the [C]ourt . . . ‘impose[s] a substa ntial burden on an agency seek ing to avoid disclosure’ through the FOIA exemptions.” Morley , 508 F.3d at 1114 (quoting Vaughn v. Rosen , 484 F.2d 820, 828 (D.C. Cir. 1973)) (alter ation in original). T he agency’s docume nts supporting the exemption, including its Vaughn index, must “permit adequate adversary testing of the agency’s claimed right to an exemption.” Citizens for Responsibility & Ethics in Wash. v. U.S. Dep’t of Justice , 840 F. Supp. 2d 226, 230 (D.D.C. 2012) (quoting Kimberlin v. U.S. Dep’t of Justice , 139 F.3d22 944, 950 (D.C. Cir. 1998)). Accordingl y, disclosure exemptions are “narrowly construed,” and “‘conclusory and generalized all egations of exemptions’ are una cceptable.” Morley , 508 F.3d at 1114–15 (quoting Founding Church of Scientology of Wash., D.C., Inc. v. Nat’l Sec. Agency , 610 F.2d 824, 830 (D.C. Cir. 1979)). However , courts generally resp ect the factual reasoning of agencies, and “[u]ltimately[] an agency’s justification for inv oking a FOIA exemption is sufficient if it appears ‘logical’ or ‘plausible.’” Wolf v. CIA , 473 F.3d 370, 374–75 (D.C. Cir. 2007) (quoting Gardels v. CIA , 689 F.2d 1100, 1105 (D.C. Cir. 1982)). Thus, “a reviewing cou rt should ‘respect the expertise of an agency’ and not ‘overstep t he proper limits of the judicial role in FOIA review.’” Pinson v. U.S. Dep’t of Justice , 160 F. Supp. 3d 285, 293 (D.D.C. 2016) (quoting Hayden , 608 F.2d at 1388). 1. Exemption 6 DOJ argues that BOP properly invoked Exemption 6 in response t o Request Nos. 2011- 2366, 2012-39, 2012-975, and 2013-1684. 10 See Defs.’ Mem. at 23–25; 7th Christenson Decl. ¶¶ 18–22; 53–60; 113–22; 130–33. BOP has withheld the names and ad dresses of individuals involved in cases against certai n BOP sites; the names of an in mate and BOP employee from a letter regarding an administrative claim; the case numbers and administrative claim number in a settlement agreement; the tele phone extensions and direct telep hone numbers of BOP staff; the names of third-party, non-BOP employees who would be conducting an ACA audit; and the name of a third-party, non-BOP employee who assisted with a pre -ACA audit. 7th Christenson Decl. ¶¶ 18–22, 113–22; Vaughn Index at 1–3, 103–04. As explained b elow, the Court agrees

10 BOP also claims Exemption 6 in its response to Request No. 201 3-1684 and its reprocessing of Request No. 2012-975, but because the Court fin ds that Exemption 7(C) is applicable to these other withhol dings, it does not address the m under Exemption 6.23 that almost all of these withholdings are covered by Exemption 6, and may therefore be withheld. Under Exemption 6, an agency may withhold “personnel and medica l files and similar files” when the disclosure of s uch information “would constitut e a clearly unwarranted invasion of personal privacy.” 5 U.S.C. § 55 2(b)(6). The exemption has b een interpreted broadly to protect “bits of personal inform ation, such as names and addres ses.” Prison Legal News v.
Samuels , 787 F.3d 1142, 1147 (D.C. Cir. 2015) (brackets and internal q uotation marks omitted). “The information in the file ‘n eed not be intimate’ for the fil e to satisfy the standard, and the threshold for determining whether information applies to a part icular individual is minimal.” Milton v. U.S. Dep’t of Justice , 783 F. Supp. 2d 55, 58 (D.D.C. 2011) (quoting N.Y. Times Co. v.
NASA , 920 F.2d 1002, 1006 (D.C. Cir. 1990)). P rivate information mu st also implicate a “significant privacy inter est” to trigger protection. Multi Ag Media LLC v. Dep’t of Agric. , 515 F.3d 1224, 1229 (D.C. Cir. 2008) (quoting Nat’l Ass’n of Retired Fed. Emps. v. Horner , 879 F.2d 873, 874 (D.C. Cir. 1989)). This standard, however, “means less than it might seem,” as a significant interest is “anything greater than a de minimis privacy interest.” Id. at 1229–30. “[S]omething, even a modest priv acy interest, outweighs nothing every time” under the balancing test. Billington v. U.S. Dep’t of Justice , 245 F. Supp. 2d 79, 86 (D.D.C. 2003) (quoting
Horner , 879 F.2d at 879). When private information in a record implicates a significant privacy interest, the court must determine if disclosing the information would constitute a clearly unwarranted invasion of personal privacy by balancing “the privacy interest that would be compromised by disclosure against any public interest i n the requested information.” Multi Ag Media , 515 F.3d at 1228. “The scope of a privacy interest under Exemption 6 will always be dependent on the context in24 which it has been asserted.” Prison Legal News , 787 F.3d at 1147 (D.C. Cir. 2015) (quoting Armstrong v. Exec. Office of the President , 97 F.3d 575, 581 (D.C. Cir. 1996)). “The only relevant public interest in disc losure to be weighed in this ba lance is the extent to which disclosure would . . . contribut [e] significantly to public und erstanding of the operations or activities of the government.” Bartholdi Cable Co. v. FCC , 114 F.3d 274, 282 (D.C. Cir. 1997) (internal quotations and citations omitted). “Information that ‘reveals little or nothing about an agency’s own conduct’ does not fur ther the statutory purpose.” Beck v. Dep’t of Justice , 997 F.2d 1489, 1493 (D.C. Cir. 1993) (quoting U.S. Dep’t of Justice v. Reporters Comm. for Freedom of
the Press , 489 U.S. 749, 773 (1989)). In its previous opinion, the Cour t denied summary judgment as to the application of Exemption 6 to withhold informati on including names, case numbe rs, and administrative claim numbers involved in settlement agreements with certain BOP site s because BOP did not “sufficiently explain the privacyinterests of the individuals involved in each claim” and thus the Court could not “correctly balan ce the public and private inter ests.” Pinson , 236 F. Supp. 3d at 363. BOP has since filed a supplemen tal affidavit to address th e Court’s concerns and sufficiently identified the priv acy interests of the individual s involved. See 7th Christenson Decl. ¶¶ 113–122. For example, BOP explai ned that it determined that it was proper to withhold the plaintiff’s name and signature a nd the case number in a suit ov er negligent medical care received for HIV/AIDS because such disclo sure would “increase the likeli hood of the plaintiff’s private medical information becoming mo re widely known,” and “a medical diagnosis of HIV/AIDS is incredibly stigmatizing” and “l eads to potentially false assump tions about . . . drug use and unprotected homosexual sex.” Id. ¶ 116.25 With this new explanation, the Court is now able to perform it s balancing test. First, this Court finds that the public inte rest in discovering what the go vernment is up to is not served by disclosing the name and signature of the plaintiff in a lawsuit against BOP; the name and signature of that plaintiff’s at torney; the name, address, admi nistrative claim number, and civil case number of the plaintiff in a n administrative claim under t he FTCA; or the signature of the Regional Counsel involved in that claim. The Court finds it sig nificant that the information withheld involves only one govern ment official, and the Court c annot see how disclosing her signature would inform citizens ab out the inner workings of the ir government. Accordingly, because even a “modest privacy interest” outweighs nothing “eve ry time,” Billington , 245 F. Supp. 2d at 86, these individuals’ privacy interests outweigh the nonexistent public interest in disclosure, and the applicati on of Exemption 6 to withhold such information is appropriate. BOP also asserts that telephone extensions and direct telephone numbers of BOP staff were properly withheld because the staff members may be reached through a “general telephone number for the institution,” and t hey therefore “maintain a pri vacy interest in not being contacted directly at their extensions.” 7th Chr istenson Decl. ¶ 19. Cou rts in this district have varied in their approach to determining w hether work telephone numbers ca n be withheld pursuant to Exemption 6. Some courts have fou nd that work telephone numbers are not personal or intimate enough to constitute “similar files, ” and therefore can never b e protected under Exemption 6. See, e.g. , Brown v. FBI , 873 F. Supp. 2d 388, 402 (D.D.C. 2012) (“W ork telephone numbe rs are different from personal informa tion that would be protected . . . such as ‘place of birth, date of birth, date of marriage, employm ent history, and comparable dat a.”); Leadership Conference on Civil Rights v. Gonzales , 404 F. Supp. 2d 246, 257 (D.D.C. 2005) ( finding that names an d work numbers of paralegals are not “si milar to a ‘personnel’ or ‘med ical’ file[s]” or “personal or26 intimate information, such as a home address or a social securi ty number, that normally would be considered protected inf ormation under . . . Exemption 6”); Friedman v. U.S. Secret Serv. , 923 F. Supp. 2d 262, 282 (D.D.C. 2013) (same). Other courts have assum ed that work telephone numbers and email addresses do constitute “similar files,” and have therefore proceeded to examining the privacy and public interests at stake. See, e.g. , Shurtleff v. EPA , 991 F. Supp. 2d 1, 18–19 (D.D.C. 2013) (finding that the EPA Administrator and Whi te House employees had a privacy interest in preventing t he disclosure of their work ema il addresses); Competitive Enterprise Inst. v. EPA , 12 F. Supp. 3d 100, 123 (D.D.C. 2014) (questioning whether a retired government employee had a privacy i nterest in preventing the di sclosure of their defunct work email address). The Court is in agreement with t he courts in the latter set of cases—in some instances, employees’ direct contact inform ation may be personal informati on, the disclosure of which would constitute a clearly unwa rranted invasion of personal pri vacy. Here, the release of BOP employees’ direct telephone ext ensions could possibly lead to t he same sort of harassment that courts have feared other government employees might suffer if t heir direct work contact information is divulged. See, e.g. , Brown , 873 F. Supp. 2d at 403 (discu ssing the possible, though unlikely, harassment of FBI employees when analyzing the withho lding of work telephone numbers under Exemption 7(C)). B ecause Pinson has presented no public interest to justify this potential invasion of personal pr ivacy, the Court grants Defend ants’ motion as to the office telephone numbers and extensions. However, BOP has failed to demons trate why the third-party, non -BOP employee who assisted with a pre-ACA audit ha s a privacy interest in not dis closing his or her name that outweighs the public interest i n disclosure. The record maintai ns the possibility that this27 individual was a government emp loyee or a paid government consu ltant, and “information that ‘merely identifies the names of government officials who author ed documents and received documents’ does not generally fall within Exemption 6.” Aguirre v. S.E.C. , 551 F. Supp. 2d 33, 53 (D.D.C. 2008). However, there a re instances where merely ide ntifying names may lead to clearly unwarranted invasi ons of privacy interests. See, e.g., U.S. Dep’t of State v. Ray , 502 U.S. 164, 176 (1991) (“[D]isclosure of the interviewees’ identities could subject them or their families to embarrassment in their social and community relationships.”) (internal quotations omitted). Accordingly, “whether disclosure of a list of names is a signif icant or a de minimis threat depends upon the char acteristic(s) revealed by virtue of being on the particular list, and the consequences likely to ensue.” Ray , 502 U.S. at 176 n.12 (internal quotations omitted). Here, without providing any further det ails, BOP merely concludes tha t this individual has a privacy interest in not being identified a nd that this privacy interest outweighs the “limited additional value” of disclosure. See 7th Christenson Decl. ¶ 21. It di d not attempt to explain how m erely identifying the individual’s name would be a clearly unwarrante d invasion of privacy. As mentioned above, “‘conclusory and g eneralized allegations of ex emptions’ are unacceptable.” See Morley , 508 F.3d at 1115. As such, Exemp tion 6 is inappropriate becau se BOP has failed to adequately establish a si gnificant privacy interest. Conversely, the Court agrees wit h DOJ that BOP properly invoked Exemption 6 to withhold the names of the third -party, non-BOP employees who co nducted the ACA audit. As BOP has explained, there is a s ignificant privacy interest at s take here because revealing the names of individuals who conduct AC A audits could threaten thei r objectivity during the audit
process. See 7th Christenson Decl. ¶ 20. Pins on has not presented any count ervailing public interest in such a disclosure. The refore, this privacy interest outweighs any public interest in28 disclosure. While disc losing other details about the ACA audit would certainly inform citizens about “what their government is up to,” U.S. Dep’t of Def. v. Fed. Labor Relations Auth. , 510 U.S. 487, 497 (1994), disclosing the names of the ACA auditors would contribute little, if anything, to this purpose. Acco rdingly, the use of Exemption 6 to withhold these individuals’ names is appropriate. 2. Exemption 7 DOJ next argues that BOP pr operly invoked Exemption 7, which protects from disclosure certain “records or information c ompiled for law enforcement pu rposes,” 5 U.S.C. § 552(b)(7), when it withheld certain docum ents in response to Request Nos. 2010-12533, 2011-1351, 2011- 1886, 2012-39, 2012-975, and 2013-1684. See Defs.’ Mem. at 25–32. For the reasons set forth below, the Court grants summa ry judgment to BOP on each of its withholdings pursuant to Exemption 7, except for its withholdings pursuant to Exemptions 7(E) and 7(F) of documents responsive to Request No. 2013-1684 associated with Pinson’s st atute-based programming assignment. a. Threshold Inquiry “In order to withhold documents under Exemption 7, the agency must, as a preliminary matter,” make a “threshold” show ing “that the records were comp iled for a law enforcement purpose.” Kay v. FCC , 976 F. Supp. 23, 37 (D.D.C. 1997). Agencie s classified as law enforcement agencies receive a s pecial deference in their claim s of law enforcement purpose. See
Pratt v. Webster , 673 F.2d 408, 418 (D.C. Cir. 1982) (expl aining this deference stems from “the generally accurate assumption tha t federal agenci es act within their legislated purposes”). However, this review, although “ne cessarily deferential,” is “n ot vacuous.” Id. at 421.29 Not every document compiled by a law enforcement agency satisfi es the law enforcement purpose inquiry. See Am. Immigration Council v. U.S. Dep’t of Homeland Sec. , 950 F. Supp. 2d 221, 245–46 (D.D.C. 2013) (rejecting ICE’s argument that all of its records are compiled for a law enforcement purpose (citing Pratt , 673 F.2d at 419)); Benavides v. Bureau of Prisons , 774 F. Supp. 2d 141, 146–47 (D.D.C. 2011) (rejecting a “per se” rule t hat all BOP documents are created for law enforcement pur poses and finding that BOP’s rec ordings of inmates’ telephone conversations fell outside of lawenforcement purposes (citing Pratt , 673 F.2d at 416)). Instead, the withheld records “must be r elated to the enforcement of fed eral laws or to the maintenance of national security,” and that nexus “must be based on informatio n sufficient to support at least a colorable claim of its rationality.” Pinson , 236 F. Supp. 3d at 364. Records relating to an investig ation are one common type of rec ord compiled for law enforcement purposes. Under the D. C. Circuit’s two-part test, “ the government can show that its records are law enforcement records” if (1) “the investigatory activity that gave rise to the documents is ‘related to the enfo rcement of federal laws,’” and (2) “there is a rational nexus between the investigation at issu e and the agency’s law enforce ment duties.” Jefferson v. Dep’t of Justice, Office of Prof’l Responsibility , 284 F.3d 172, 177 (D.C. Cir. 2002) (citing Pratt , 673 F.2d at 420–21). However, where t here is no ongoing investigati on, materials may still meet the threshold requirement if they a re akin to “guidelines, techniqu es, and procedures for law enforcement investigations and prosecutions outside of the cont ext of a specific investigation.” Tax Analysts v. IRS , 294 F.3d 71, 78 (D.C. Cir. 2002). In its previous opinions, the Court has outlined this framework as it relates to BOP. “[T]he ‘BOP is a law enforcemen t agency and thus deserves [] de ference’ on its claims of law enforcement purpose.” Pinson , 236 F. Supp. 3d at 365 (citing Pinson , 202 F. Supp. 3d at 101).30 Courts in this district have prev iously held tha t certain recor ds generated as part of BOP’s law enforcement mission of protecting inmates, staff, and the commu nity, were compiled for law enforcement purposes. See, e.g. , id. (holding that an “administ rative remedy index, which collects complaints by inmates a bout the conditions of their co nfinement,” were compiled for law enforcement purposes because they pertain to BOP’s “law enf orcement responsibility of protecting inmates”); Mingo v. U.S. Dep’t of Justice , 793 F. Supp. 2d 447, 453 (D.D.C. 2011) (holding that records “pertain [ing] to an altercation involving over 50 inmates” and “maintained by the Special Investigative Offi ce at that facility” were comp iled for law enforcement purposes because they were “created in conn ection with BOP’s responsibil ity to protect[] inmates, staff, and the community” (internal quo tation marks and citations omit ted)); Holt v. U.S. Dep’t of
Justice , 734 F. Supp. 2d 28, 41 (D.D.C. 2010) (holding that records “p ertain[ing] to the investigation of an inmate-on-in mate assault” were compiled for law enforcement purposes because they were “created in conn ection with BOP’s responsibil ity to protect[] inmates, staff, and the community” (internal quotation marks and citation omitt ed)). The Court thus analyzes BOP’s withholdings under this framework. The records at issue in this mo tion are similar to those previo usly found to have been compiled for law enforcement purposes. For instance, BOP applie d Exemption 7 to “records . . . generated by FCC Florence staff inpreparation for an ACA accre ditation audit,” which address “the institution’s handling of t hreats to its security, handlin g of inmate escapes, processing of criminal violations, and internal discipline procedures.” 7th C hristenson Decl. ¶ 25. BOP also applied Exemption 7 to withhold docu ments in Pinson’s “Central File, Medical Records, and Psychology Records,” and records “maintained by the SIS office, which compiles investigatory records for potential criminal activity within an institution and investigates potential misconduct31 by inmates.” Id. ¶¶ 62–63. Like the records in Mingo , Holt , and this Court’s prior opinions in this case, BOP documents at issue he re—which pertain to how BOP hand les threats to security, how it monitors and maintains the he alth and safety of its inmates and staff, and how it investigates criminal activity—were create d by BOP to fulfill its responsibi lity of protecting inmates and prison staff. Thus, the Court finds that BOP has presented suff icient facts to show that the documents it withheld under Ex emption 7 were compiled for law e nforcement purposes. b. Exemption 7(C) DOJ argues that BOP properly invoked Exemption 7(C) in respons e to Request Nos. 2012-975 and 2013-1684. BOP used the exemption to withhold: “in mate names and register numbers” and “file names that i ncluded names of inmates”; “the names, register numbers, medical information, statements made to law enforcement officer s, and correctional management of third-party inmates”; “the na mes, injuries and other medical information, photographs of their faces, injuries and property, and employment information for [B OP] staff”; “the names of staff who participated in cal culated uses of force and their role on the team”; “the telephone extensions, direct numbers, and f acsimile extensions of Bureau staff”; “the names and personal identifying information of indivi duals associated with a statut e-based programming assignment used to manage Pinson”; and “the name of a criminal Assistant U .S. Attorney and the names of law enforcement investigative agents associated” with certain a gencies, as well as their “contact32 information, such as telephone numbers, e-mail addresses, and a ddresses.” 11, 12 7th Christenson Decl. ¶¶ 64–72, 133. DOJ argues that the disclosure of this inf ormation “could reasonably be expected to constitute an unwa rranted invasion of [the] persona l privacy” of other inmates, staff members, and other third-party individuals. See Defs.’ Mem. at 26–28. The Court agrees. Under Exemption 7(C), an agenc y is exempt from producing “reco rds or information compiled for law enforcement purposes . . . to the extent that the production of such law enforcement records or information . . . could reasonably be expected to constitute an unwarranted invasion of personal privacy. 5 U.S.C. § 552(b)(7)( C). Exemption 7(C), like Exemption 6, protects private i nformation, but “Exemption 7(C) is more protective of privacy than Exemption 6 and thus establishes a lower bar for withholdi ng material.” Prison Legal News , 787 F.3d at 1146 n.5 (D.C. Cir. 2015) (in ternal quotation marks omitted) (quoting ACLU v. U.S. Dep’t of Justice , 655 F.3d 1, 6 (D.C. Cir. 2011). In an Exemption 7(C) analysis , the court must first determine if there is a pr ivacy interest in the informati on to be disclosed, and then it balances the individual’s privacyinterest against the public i nterest in disclosure, considering only the extent to which disclosu re “further[s] the citizens’ r ight to be informed about ‘what their government is up to.’” ACLU , 655 F.3d at 6 (quoting Reporters Comm. , 489 U.S. at 773). And as this Court previously stated, “[i ]t is a FOIA requester’s oblig ation to articulate a public interest sufficient to outweigh the indivi duals’ privacy interest, and the public interest must be

11 BOP withheld the foregoing inf ormation from Request No. 2013-1 684. BOP also applied Exemption 7(C) to withhold “the Daily Assignment Roster s for institutions,” but because the Court has determined that th ese records are protected by Ex emption 7(F), the Court does not address the question of whether Exemption 7(C) applies as well.

12 DOJ also invokes Exemption 6 as grounds for these withholdings . Because the Court reviews the withholdi ng of these records under Exemption 7(C), the Court does not address whether Exemption 6 may be applie d to these withholdings as wel l.33 significant.” Pinson , 236 F. Supp. 3d at 367 (citing Nat’l Archives & Records Admin. v. Favish , 541 U.S. 157, 172 (2004)). Here, BOP has sufficiently demons trated that private individua ls, BOP staff, and other inmates have a privacy interest in withholding their names and other identifying information that outweighs the public interest i n disclosure. For example, BOP w ithheld the “names, dates of birth, telephone numbers, social security numbers, [and] driver ’s license numbers . . . for thirdparty individuals”; the “names, i njuries and other medication i nformation, [and] photographs of . . . faces” of BOP staff; and the na mes and contact information of “a criminal Assistant U.S. Attorney” and “law enforcement i nvestigative agents associated with” the FBI, DOJ and BOP. 7th Christenson Decl. ¶¶ 66–67, 72. Pinson has not presented an y evidence showing illegal activity by the agency or any other significant public interest in disclosure, and the Court does not find any such evidence in t he record. Accordingly, the Cour t finds that withholding this information under Exemption 7(C) is appropriate. BOP also properly withheld the work telephone numbers of some s taff members using Exemption 7(C). While “a name and work telephone number is not . . . information . . . that normally would be considered protec ted,” disclosure of the work telephone numbers of law enforcement officials could “s ubject [them] to harassing teleph one calls,” Brown v. FBI , 873 F. Supp. 2d 388, 402–03 (D.D.C. 2012), and w ould thus be protected . In the present case, while the “likelihood of disruptive and ha rassing phone calls is debatabl e,” the disclosure of these numbers when the general institution num ber is provided creates only a de minimis public interest, and “[a]ny amount of privacy expecta tion outweighs the virtually no nexistent public interest.” Id. at 403. Accordingly, the Court grants DOJ summary judgment as to B OP’s use of Exemption 7(C).34 c. Exemption 7(E) DOJ next argues that BOP prope rly invoked Exemption 7(E) in res ponse to Request Nos. 2010-12533, 2011-1351, 2012-39, and 2013-1684. BOP used Exempti on 7(E) to withhold: “recommendations for improving f uture uses of force and correct ive measures to be taken for errors identified in the use of force under review” in an After Action Review Report; “discrepancies noted and recommen dation/results” in Form 586 Af ter Action Review Reports; a list of “weapons used during the i nstitution disturbance” from an April 20, 2008 Report of Incident; “information . . . consist[ ing] of the Central Inmate Monitoring (CIM), separations, and other internal assignments use d to classify and monitor Pinson and other third-party inmates”; “techniques for investigating c riminal activity within a prisonfacility [and] factual information developed using these law enforcem ent techniques”; “documents a ssociated with a s tatute-based programming assignment used to man age Pinson”; “description of the Bureau’s calculated use of force technique and a photo of t he technique being used”; and “ investigative reports from an intelligence database used by BOP staff during law enforcement investigations.” 13 7th Christenson Decl. ¶¶ 73–74, 76–77, 79–80, 96, 103, 129. DOJ arg ues that the disclosure of this information “would give insight i nto investigative techniques o r processes” and thus enable inmates to “circumvent the effec tiveness of the law enforcement techniques.” See Defs.’ Mem. at 28–30. The Court agrees with DOJ except as to the use of Exempt ion 7(E) to withhold the documents associated with Pinson’ s statute-based programming as signment.

13 BOP also applied Exemption 7(E) t o withhold “discussions of ga ng and informant activity within the [BOP]” and “st eps used to resolve major cri ses in a Bureau facility,” 7th Christenson Decl. ¶ 75, 78, but because this Court has determin ed that such information is protected under Exemption 7(F), it does not address whether Exe mption 7(E) applies as well.35 Exemption 7(E) protects law enfo rcement information that “woul d disclose techniques and procedures for law enforcemen t investigations or prosecutio ns, or would disclose guidelines for law enforcement investiga tions or prosecutions if such disc losure could reasonably be expected to risk circumven tion of the law.” 5 U.S.C. § 552(b)(7 )(E). The D.C. Circuit has “set[] a relatively low bar for the agency to justify withholding.” Blackwell v. FBI , 646 F.3d 37, 42 (D.C. Cir. 2011). Such information m ay be withheld “not just fo r circumvention of the law, but for a risk of circumvention; not just for an actual or certain risk of circumvention, but for an expected risk; not just for a n undeniably or universally expect ed risk, but for a reasonably expected risk; and not just for certitude of a reasonably expec ted risk, but for the chance of a reasonably expected risk.” Mayer Brown LLP v. IRS , 562 F.3d 1190, 1193 (D.C. Cir. 2009). Moreover, “[t]he first clause of Exemption 7(E) affords ‘catego rical’ protection for ‘techniques and procedures used in law enforcem ent investigations or prosec utions,” McRae v. U.S. Dep’t of
Justice , 869 F. Supp. 2d 151, 168 (D.D.C. 2012) (citing Pub. Emps. for Envtl. Responsibility v. U.S. Section Int’l Boundary & Water Comm’n (“ PEER ”), 839 F. Supp. 2d 304, 327 (D.D.C. 2012)); whereas the second clause “separately protects ‘guideli nes for law enforcement investigations or prosecutions i f [their] disclosure could reas onably be expected to risk circumvention of the law.’” Id. (alteration in original). Furth ermore, “[t]he government ‘must show that the records contain law-enforcement techniques and pr ocedures that are generally unknown to the public.” Elkins v. Fed. Aviation Admin. , 134 F. Supp. 3d 1, 4 (D.D.C. 2015) (quoting Am. Immigration Council v. U.S. Dep’t of Homeland Sec. , 950 F. Supp. 2d 221, 245 (D.D.C. 2013)). BOP has sufficiently shown that the “recommendations for improv ing future uses of force and corrective measures t o be taken for err ors identified in the use of force under review”36 in an After Action Review Report; the “discrepancies noted and recommendation/results” in Form 586 After Action Review Re ports; the list of “weapons used during the institution disturbance” from an April 20, 2008 Report of Incident; and the “description of the Bureau’s calculated use of force techni que and a photo of the technique being used” that it withheld are not generally known to the public a nd could reasonably be expec ted to risk circumvention of the law. 7th Christenson Decl. ¶¶ 79, 96, 103, 129. Regarding the information in the After Action Review Reports, B OP asserts that such information mentions “equipment to be used during the use of fo rce technique, which staff members were to perform what r ole during the use of force, and steps to be taken if the inmate remained noncompliant.” Id. ¶¶ 99, 103. According to BOP, disc losing such information woul d allow inmates to “target certa in staff or equipment during a us e of force or anticipate what steps staff would be taking based on the ir noncompliance,” thus allow ing circumvention and rendering the procedures ineffective. Id. BOP asserts similar concerns about disclosing a description of BOP’s calculated use of force t echnique and a photo of the tech nique being used. Id. ¶ 79. The Court agrees that disclosing t his information could reasonably be expected to create a risk of circumvention by revealing the tech niques involved in the use o f force and the effectiveness of such techniques, rendering them in effective in future uses. Pin son has not challenged these withholdings, and similar materials have been withheld by other courts in this jurisdiction. See,

e.g. , Whitfield v. U.S. Dep’t of Treasury , No. 04-0679, 2006 WL 2434923, at *6 (D.D.C. Aug. 22, 2006) (holding that Exemption 7(E) protects documents detai ling arrest locat ion, equipment used, and law enforcement personn el involved in the arrest); Shore v. FBI , 185 F. Supp. 2d 77, 85 (D.D.C. 2002) (holding that inma te was not entitled to information regarding the effectiveness37 of investigative techniques). T herefore, the Court grants DOJ s ummary judgment as to BOP’s use of Exemption 7(E) to withhold this information. BOP has also sufficiently shown t hat “techniques for investiga ting criminal activity within a prison facili ty [and] factual information developed us ing these underlying techniques” and “investigative reports from an intelligence database used b y BOP staff during law enforcement investigations” thatit withheld are not generally known to the public and could reasonably be expected to risk c ircumvention of the law. 7th Ch ristenson Decl. ¶¶ 76, 80. Ms. Christenson attests that the wit hheld documents include informa tion on “who might be interviewed or the types of data reviewed for a particular inve stigation” and “how the data was collected and organized within the database, how staff searched the database, and how the information can be reported.” Id. Knowledge of such informati on could purportedly “enable potential criminals to manipulate witnesses [and] hide evidence ” or “reveal the BOP’s methods of intelligence gathering [tha t are] not generally known” and t hus allow inmates to circumvent such techniques and methods. Id. With these assertions, BOP has “demonstrate[d] logically how the release of the requested i nformation might create a risk of circumvention of the law.”
Blackwell , 646 F.3d at 42. The information withheld here is similar to t he information that other courts in this jurisdiction ha ve found to be appropriately with held under Exemption 7(E). See,

e.g. , Barnard v. Dep’t of Homeland Sec. , 598 F. Supp. 2d 1 (D.D.C. 2009) (finding application of Exemption 7(E) appropriate t o withhold Custom and Border Pro tection’s examination and inspection procedures, internal reporting requirements, and ins tructions on how to process international travelers); Harrison v. Fed. Bureau of Prisons , 611 F. Supp. 2d 54 (D.D.C. 2009) (finding application of 7 (E) appropriate t o withhold records in dicating when and why an investigator chose to investigat e and listen to a prisoner’s te lephone conversations). In the38 present case, the Court agrees t hat disclosing information such as the subjects of interviews, what data may be reviewed, and how data is collected would enable in mates to manipulate witnesses, hide evidence, avoid methods of da ta collection, and otherwise circumvent the law. Accordingly, the Court grants DOJ summary judgment as to BOP’s use of Exempt ion 7(E) to withhold this information. BOP has failed, however, to show that the disclosure of “docum ents associated with a statute-based programming assignmen t used to manage Pinson” cou ld reasonably be expected to risk circumvention of the law . 7th Christenson Decl. ¶ 77. Whil e Exemption 7(E) protects law enforcement techniques from di sclosure when “public knowledge o f those techniques could result in the circumvention of statutes or regulations,” Clemente v. FBI , 741 F. Supp. 2d 64, 83 (D.D.C. 2010), the agency has the burden of showing that “the r ecords contain law-enforcement techniques and procedures that are generally unknown to the pub lic.” Elkins , 134 F. Supp. 3d at 4. Here, BOP merely asserts, w ithout explaining in any further detail, that disclosure of the statute-based programming assignmen t would enable inmates to ci rcumvent reporting requirements. BOP does not explai n whether, because this progra mming assignment is statutebased, the withheld information is available in the statute and is therefore generally known to the public. Thus, BOP’s bald assertion is too conclusory for the Co urt to find the application of Exemption 7(E) appropriate. See Smith v. Bureau of Alcohol, Tobacco & Firearms , 977 F. Supp. 496 (D.D.C. 1997) (finding Exempti on 7(E) withholding inappropr iate because agency merely claimed that it withheld “details ” of various techniques not al ready known to the general public). The Court therefore denies DOJ s ummary judgment as to BOP’s use of Exemption 7(E) to withhold this information.39 d. Exemption 7(F) Finally, DOJ claims that BOP properly invoked Exemption 7(F) t o withhold records in response to Request Nos. 2011-1886, 2012-39 and 2013-1684. BOP used Exemption 7(F) to withhold: certain answers to quest ions in “witness forms used d uring Pinson’s referral hearing to ADX Florence”; “discussions of ga ng and informant activity with in the [BOP]”; information that would adversely affect Pinson’s sa fety; answers to certain ques tions on an Intake Screening Form; “a portion of Pinson’s Admi nistrative Detention Order For ms”; “names and register numbers of third-party inmat es from whom . . . Pinson needed to be separated”; “documents associated with a statute-bas ed programming assignment used to manage Pinson”; the “institution’s policie s [on] tools and keys ”; “photographs of l ocks on cell door and hand restraints”; “steps used to reso lve major crises in a Bureau fa cility”; answers to certain questions on a “Screening for Risk of Victim ization and Abusiveness Form completed for Pinson”; and the “Daily Assignment Rosters for institutions.” 14 7th Christenson Decl . ¶¶ 81–95, 109. Court agrees that this withheld material falls under Exemption 7(F), excepti ng the documents associated with Pinson’s statute-based programming assignment. Exemption 7(F) protects from di sclosure information contained in law enforcement records that “could reasonably be expected to endanger the life or physical safety of any individual.” 5 U.S.C. § 552(b)(7 )(F). The D.C. Circuit has desc ribed the reach of Exemption 7(F) as “expansive.” See Elec. Privacy Info. Ctr. v. U.S. Dep’t of Homeland Sec. , 777 F.3d 518, 526

14 BOP also applied Exemption 7(F) to withhold other information, but because the Court finds that Exemption 7(C) protec ts the “names of staff who part icipated in calculated uses of force and their role on the t eam,” and Exemption 7(E) protects “techniques for investigating criminal activity” and “a descri ption of the Bur eau’s calculate d use of force technique and a photo of the technique being use d,” the Court does not address whether Exemption 7(F) also applies.40 (D.C. Cir. 2015). Under this broa d language, the exemption “doe s not require that a particular kind of individual be at risk of ha rm; ‘any individual’ will do .” PEER , 740 F.3d at 205. Moreover, “[d]isclosure need not definitely endanger life or physical safety; a reasonable expectation of endangerment suffices.” Id. (emphasis in original). The re is no balancing test in an Exemption 7(F) analysis, as it is “an absolute ban against [ disclosure of] certain information,” Raulerson v. Ashcroft , 271 F. Supp. 2d 17, 29 (D.D.C. 2002), and “[w]ithin limits, c ourts defer to the agency’s assessment of danger,” Sanchez-Alaniz v. Fed. Bureau of Prisons , No. 13-1812, 2016 WL 1222214, at *7 (D.D.C. Mar. 28, 2016); see also Gardels v. CIA , 689 F.2d 1100, 1104 (D.C. Cir. 1982) (“Once satisfie d that . . . the information lo gically falls into the exemption claimed, the courts need not go fur ther to test the expertise o f the agency.”). In its previous opinion, the Cour t held that the application o f Exemption 7(F) to withhold answers to every question in witn ess forms used during Pinson’s referral hearing to ADX Florence was inappropriate beca use the risk of harm was too spe culative in the absence of some explanation as to why these res ponses could not be anonymized. See Pinson , 236 F. Supp. 3d at 371–72. After reprocessing Request No. 2011-1886, BOP disclosed the answers to some questions, but continued to wit hhold the answers to others. See 7th Christenson Decl. ¶¶ 109–12. In the present motion, BOP has su fficiently explained its reaso ning for withholding this information. For instance, Ms. C hristenson asserts that disclos ing answers to questions such as “Do you believe there are dangers to this inmate’s safety?” wou ld “potentially lend[] credibility to the conclusion that there are threats to Pinson’s safety” or that she is a weak inmate and thereby risk Pinson bein g targeted for assault. Id. ¶ 110. Ms. Christenson also attests that disclosing the answer to que stions such as “Do you personally b elieve that inmate Pinson is a threat to any person?” would “in crease the risk Pinson would be targeted for a preemptive41 assault.” Id. ¶ 111. Thus, BOP has provided a su fficiently detailed affidavi t to establish a “reasonable expectation of endangerment,” PEER , 740 F.3d at 205, and the Court grants DOJ summary judgment as to BOP’s us e of Exemption 7(F) to withhold this information. Regarding BOP’s withholding of doc uments associated with Pinso n’s statute-based programming assignment, BOP fa ils to consider how the withholdi ng of names under Exemption 7(C) affects the need for withhol ding the documents in full und er Exemption 7(F). BOP asserts that “[i]f inmates know they are subject to reporting requireme nts and who the information is being reported to, the lives a nd physical safety of those indiv iduals receiving the information is potentially compromised.” 7th C hristenson Decl. ¶ 89. But as st ated above, this Court has granted summary judgment as to t he application of Exemption 7(C ) to withhold the names and personal identifying information of third-party individuals in these documents. See supra at Section III.B.2.b. Although the Court defers to an agency asses sment of danger, it does so within

reason, see Sanchez-Alaniz , 2016 WL 1222214, at *7, and reason suggests that the applicat ion of Exemption 7(C) to withhold name s and identifying information of third-party individuals in these documents will likely disp el any danger to those individu als from disclosing the documents. Therefore, because BOP failed to demonstrate a reaso nable expectation of endangerment, the Court denies DOJ summary judgment as to the u se to Exemption 7(F) to withhold these documents. As to the other withheld inf ormation, BOP has sufficiently dem onstrated that the application of Exemption 7(F) i s appropriate. Pinson has not ch allenged these withholdings, and the Court, in its own independe nt evaluation, does not identify any reason to doubt BOP’s assessment of the endangerment t o individual safety that would be caused by disclosure. 15 BOP

15 Regarding BOP’s withholding of “ information regarding gang and informant activity within the [BOP]” and the “Daily Assignment Rosters for institutions,” this Court has already42 determined that disclosure of doc uments that could reveal infor mation such as: Pinson’s possible status as an “informant[], se x offender[], or former law enforc ement agent”; whether Pinson “had concerns about being placed into general population, . . . had assisted law enforcement with criminal investigations, [or] te stified against anyone in court ”; “reasons for [Pinson’s] removal from general population”; and whe ther Pinson has been “approach ed for sex or threatened with sexual assault while incarcerat ed [or] been the victim of a sex ual assault,” would endanger Pinson’s life or physical safet y, and it withheld those documen ts accordingly. 7th Christenson Decl. ¶¶ 82, 85–86, 93. Because BOP is an agency with expertise in the prison setting—and because the Court finds no reason to doubt that knowledge of su ch information in a prison setting would make Pinson a target for physical or sexual violence—the Court will “defer to the agency’s assessment of danger.” Sanchez-Alaniz , 2016 WL 1222214, at *7. BOP also withheld the “names and register numbers of third-party inmates from who m . . . Pinson needed to be separated,” Id. ¶ 88, and the Court agrees that this withholding is appropriat e under Exemption 7(F) because disclosure of such information could reasonably be expected to endanger the safety of those individuals. See Anderson v. U.S. Marshals Serv. , 943 F. Supp. 37 (D.D.C. 1996) (holding that Exemption 7(F) was properly applied to withhold t he identity and location of an individual who required separati on from the plaintiff). Finally , BOP withheld the “institution’s policies [on] tools and keys”; “photographs of locks on cell do or and hand restraints”; and the “steps used to resolve major cri ses in a Bureau facility.” 7th Christenson Decl. ¶¶ 90–92. BOP has sufficiently explained that disclosure of such information would enable inmates to use the staff’s resources against them , allow capable inmates to pick c ell locks and hand restraints, and

determined in its previous opini on that such wit hholdings are appropriate under Exemption 7(F), see Pinson, 236 F. Supp. 3d at 369, and it ap plies that same reaso ning here.43 enable individuals to circumvent the staff’s techniques in cris es situations—such as a hostage negotiation—thus endangering th e life or physical safety of inm ates, staff, and the public. Id. Therefore, the Court finds that BOP has sufficiently establishe d that the disclosure of the above information would create a “rea sonable expectation of endangerm ent.” Accordingly, the Court grants DOJ summary judgment as to BOP’s use of Exemption 7(F) t o withhold this information. C. Segregability FOIA requires that any reasonabl y segregable portion of a reco rd shall be provided to any person requesting such record aft er removal of exempt portions, unless the non-exempt portions are inextricably intertw ined with exempt portions. See 5 U.S.C. § 552(b); see also Johnson v. Exec. Office for U.S. Attorneys , 310 F.3d 771, 776 (D.C. Cir. 2002). “Agencies are entitled to a presumption that they complie d with the obligation to disclose reasonably segregable material.”
Sussman v. U.S. Marshals Serv. , 494 F.3d 1106, 1117 (D.C. Cir. 2007). T o demonstrate that all reasonably segregable material h as been released, the agency mu st provide a “detailed justification” for its non-segregability. Mead Data Cent., Inc. v. Dep’t of the Air Force , 566 F.2d 242, 261 (D.C. Cir. 1977). However, the agency is not required to provide so much detail that the exempt material would e ffectively be disclosed. Id. DOJ has provided Pinson with a comprehensive Vaughn Index that describes each document withheld in part or i n full and the exemption under wh ich it was withheld. See generally Vaughn Index. Ms. Christenson att ests to having prepared the Vaughn Index and that “[e]very effort has been made t o release all segregable informa tion without [releasing protected information].” See, e.g., 7th Christenson Decl.¶¶ 17, 22. Pin son has not challenged this attestation. The combination of the Vaughn Index and Ms. Christenson’s declaration are sufficient to fulfill the agency’s obligation to show with “rea sonable specificity” why a