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130 A JrlnousE LAwER's MaNulr, ch.

A-3. Sample Vaughn Motion

[use the proper court caption]

Motion Under Vaughn u. Rosen to Require


Detailed Indexing, Justifrcation and Itemization

Plaintiff [your name] moves this Court for an order requiring


Defendants [name of agency and agency head] to provide within 30
days of the filing of the Complaint in this action, a detailed
justification for allegations contained in the Defendant's Answer and
previous administrative denial that the requested documente are
exempt from disclosure under the Freedom of Information Act, 5 U.S.C.
$ 552, including an itemization and index of the documents claimed to
be exempt, correlating specific statements in such justification with
actual portions of the requested documents. SeeVaughn u. Rosen,484
F.zd 820 (D.C. Cir. 1973), cert. dcn.,415 U.S. 977 (L974).

Respectfully Submitted,

lNo-e of plaintifr or plaintiffs attorneyl


Address

Dated: [dateJ [city and state]

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