All Party Parliamentary Group on Extraordinary Rendition v. DOD, No. 13-5176, 2014 WL 2721381 (D.C. Cir. June 17, 2014) (Tatel, J.)

All Party Parliamentary Group on Extraordinary Rendition v. DOD, No. 13-5176, 2014 WL 2721381 (D.C. Cir. June 17, 2014) (Tatel, J.)

Re: Request for records concerning United Kingdom's alleged involvement in extraordinary rendition

Disposition: Reversing and remanding district court's grant of defendant's motion for summary judgment

• Procedural Considerations, FOIA Requesters:  The court "conclude[s] that FOIA requesters who have authority to file requests on behalf of foreign government entities are 'representatives' of such entities when they file requests of the sort they have authority to file."  The court "think[s] it reasonable to infer that Congress included the 'representative' provision in order to prevent foreign government entities from evading the Foreign Government Entity Exception by filing FOIA requests through agents, not to create a separate and independent class of disfavored FOIA requesters."  Therefore, the court finds that "[s]ince the intelligence agencies concede that under this theory these three FOIA requesters fall outside the Foreign Government Entity Exception, the exception poses no barrier to the FOIA requests at issue."