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D.D.C. Ruling on Adequacy of Search by Navy

Today, Judge Dabney Friedrich issued a decision, Carlborg v. Dep't of the Navy, No. 18-cv-1881 (DLF), 2020 U.S. Dist. LEXIS 142543 (D.D.C. Aug. 10, 2020), reviewing whether or not searches of .pst email archives and shared drives were reasonably calculated to lead to the discovery of requested documents. The Court concluded that a 9 page gap in the Bates numbering of an email production could be disregarded because a subsequent search did not turn up any relevant documents omitted from the initial production.

It also ruled that, “the reasonableness of the Navy's search is buttressed by the fact that Carlborg has offered ’no suggestion as to where else‘ the Navy ’might have looked for his records or what other search criteria should have been used.’”, Id at *13 (quoting Peavey v. Holder, 657 F. Supp. 2d 180, 190 (D.D.C. 2009)).


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