Full opinion text
OPINION PAUL L. FRIEDMAN, District Judge. Plaintiffs Susan B. Long and David Burnham have filed the above-captioned cases to challenge the responses of the United States Department of Justice to a series of requests under the Freedom of Information Act, 5 U.S.C. § 552 et seq., for records from or relating to the central case management databases of the Executive Office for United States Attorneys (the “EOUSA”), a component of the Department of Justice. The consolidated cases are before the Court for consideration of (1) two motions for partial summary judgment filed by plaintiffs in Civil Action No. 00-0211 {“Long I ”); (2) the Department’s motion for summary judgment filed in Long I; and (3) the parties’ cross-motions for summary judgment filed in Civil Action No. 02-2467 {“Long II”). Upon consideration of the arguments of the parties as set forth in their voluminous briefs and at oral argument in Long I, the Court denies as moot plaintiffs’ first motion for partial summary judgment filed in Long I. The Court grants in part and denies in part plaintiffs’ second motion for partial summary judgment filed in Long I and plaintiffs’ motion for summary judgment filed in Long II. The Court also grants in part and denies in part the Department’s motions for summary judgment filed in both Long I and Long II. I. BACKGROUND A. The Central Case Management Databases Each of the 94 United States Attorney’s Offices (“USAOs”) maintains computerized record-keeping systems for civil, criminal, and debt collection cases, and for personnel resource matters. Defendant’s Motion for Summary Judgment, filed in Long II, May 30, 2003 (“Def. Mot. {Long II)”), Declaration of Marie A. O’Rourke (“O’Rourke Deck”) ¶ 5. Every month, computer programs maintained by the USAOs automatically extract certain pre-determined fields of information from their computer databases and transmit the information electronically to the EOUSA. Id. The EOUSA, in turn, uses the information it receives to compile various centralized databases (the “central case management databases”) that track the work of each of the 94 USAOs. Id. For example, the central case management databases contain information on matters such as how many and what types of criminal investigations various law enforcement agencies have referred to USAOs for prosecution; the outcome of criminal prosecutions (including sentences); and the types and results of civil actions brought by or against federal agencies. The EOUSA uses the information contained in the central case management databases to justify budget requests, allocate resources among USAOs, and produce management reports. O’Rourke Deck ¶ 6. The EOUSA also uses the information to produce numerous periodicals and ad hoc reports for the Office of Management and Budget (“OMB”), the Government Accountability Office (“GAO”), Congress, and various federal agencies and private sector organizations. Id. The databases are updated on a monthly basis, and at the end of each fiscal year information from the databases is used to produce the United States Attorneys’ Annual Statistical Report, which is made available to the public. Id. At issue in these consolidated eases are the central ease management databases relating only to criminal, civil, and debt collection matters. 1. Criminal and Civil Matters The EOUSA compiles the information it receives from the USAOs related to criminal and civil matters into a record-keeping system known as the “Central System.” See O’Rourke Decl. ¶ 5. The information in the Central System currently is divided into five core files: (1) the “criminal flagged master” file, which contains records pertaining to criminal cases and investigations; (2) the “criminal immediate declination” file, which contains records of criminal offenses for which federal prosecution immediately was declined by the USAOs upon referral (requiring less than one hour of Assistant United States Attorney (“AUSA”) time); (3) the “criminal charge” or “central charge” file, which contains records of all criminal matters that entered the prosecutorial phase; (4) the “civil flagged master” file, which contains records pertaining to civil cases and investigations; and (5) the “civil immediate declination” file, which contains records pertaining to requests for affirmative civil litigation that immediately were declined by the USAOs upon referral (requiring less than one hour of AUSA time). See Def. Mot. (Long II), Declaration of Siobahn E. Sperin (“Sperin Decl. (Long II)”) ¶ 3. The Central System also contains (1) criminal and civil “unflagged master” files, which contain records from the “flagged master” files, but without certain added “flags” that allow the EOUSA to analyze the data for statistical purposes; and (2) criminal and civil “delete history” files, which are systems maintenance files that contain records that are no longer placed in the master files because more than six successive months have elapsed since the EOUSA received a matching record from the relevant USAO. See Sperin Decl. (Long 7/)¶4. Each case or investigation appears within these files as a single “record.” Garvey Decl. (Long I) ¶ 8. Each record, in turn, contains a set number of “fields” of information depending upon the type of file in which it appears. See id. For example, criminal flagged master records contain more than 100 fields, while the criminal charge records contain 13 fields. See Def. Mot. (Long I), Exhibit O (Central System Vaughn Index). The category of information contained in each field is pre-determined, and each field bears a label that generally relates to that category. Examples include “defendant name,” “criminal lead charge,” “arrest date,” “agency file number,” and “court number.” See id. 2. Debt Collection Matters The EOUSA compiles the information it receives from the USAOs related to debt collection matters into a record-keeping system known as the Transactional Informational Government Accounting System, or “TIGAS.” Def. Mot. (Long I), Declaration of Rhonda M. Price (“Price Decl.”) ¶ 3. TIGAS, which is a “relational database,” is structured somewhat differently from the Central System (and its predecessor, the DNR System). In the DNR and Central Systems, which are “flat-file systems,” the files are self-contained units, and information from one file cannot be accessed from another file. See Garvey Decl. (Long I) ¶3. In a relational database, information is subdivided into tables, and connections or linkages can be programmed between the tables, allowing the data maintained in one table to be related to the data stored in another. TIGAS data is stored in two tables: one contains 65 fields, and the other contains 28 fields. Each debt collection matter appears in TIGAS as a record and generally has information stored in both tables. See Price Decl. ¶ 5. B. Transactional Records Access Clearinghouse Plaintiffs are co-directors of the Transactional Records Access Clearinghouse (“TRAC”), a nonprofit organization affiliated with Syracuse University. TRAC compiles information about the functioning of federal law enforcement and regulatory agencies, analyzes the data, and publishes reports. See PI. Combined Mem. (Long I) at 5; Brief in Support of Plaintiffs’ Resubmitted Motion for Summary Judgment, filed in Long II, May 16, 2003 (“PL Mem. (Long II)”) at 2; TRAC website, available at http://trac.syr.edu/. TRAC also makes data compilations and tools for analyzing data available to others — including Congress, journalists, scholars, public interest organizations and other members of the public. See Plaintiffs Resubmitted Motion for Summary Judgment, filed in Long II, May 16, 2003 (“Pl. Mot. (Long II)”), Declaration of Susan Long (“Long Decl. (Long II)”) ¶ 4. TRAC data and studies have been cited by congressional leaders and news organizations in debates over gun control, tax policy, immigration, terrorism, and similar law enforcement issues. See PL Mem. (Long II) at 2 & n. 2, 4-5 (listing examples). C. The FOIA Requests at Issue 1. Long I Since 1989, TRAC has requested release of the EOUSA’s central case management data under the FOIA. In response to past requests, the Department released to TRAC electronic' copies of the' data for fiscal years 1974 through 1997 but withheld various fields of information, thus giving rise to disputes between TRAC and the Department. See Plaintiffs’ Motion for Partial Summary Judgment, Preliminary Injunction and Consolidation of Preliminary Hearing with Consideration of the Merits, filed in Long I, May 16, 2000 (“PI. Mot. (Long I, 5/16/00)”), Declaration of Susan Long (“Long Decl. (Long I)”) ¶ 3. The disputes culminated in March 1998, when plaintiffs, on behalf of TRAC, sued the Department for the release of data from two of the USAOs that provide data, to the EOUSA. See Long v. U.S. Dep’t of Justice, 10 F.Supp.2d 205 (N.D.N.Y.1998). In connection with that litigation, the Department was ordered, on July 7, 1998, to produce an index of the records and portions thereof that were withheld in accordance with Vaughn v. Rosen, 484 F.2d 820 (D.C.Cir.1973), cert. denied, 415 U.S. 977, 94 S.Ct. 1564, 39 L.Ed.2d 873 (1974) (a so-called “Vaughn index”). Long v. U.S. Dep’t of Justice, 10 F.Supp.2d 205, 209, 211 (N.D.N.Y.1998). On June 17, 1999, the Department completed a Vaughn index listing all of the fields in the databases at issue in that action, which includes all of the fields that comprise the Central System databases that are among those at issue in these consolidated cases. The June 1999 Vaughn index identifies certain fields of information that' the Department concludes are exempt in whole or in part under Exemptions 6 and 7(C) of the FOIA, 5 U.S.C. § 552(b)(6) and (7)(C), because of privacy concerns. See Long Decl. (Long I), Exhibit 15. No other FOIA exemptions are claimed in the index as a basis for the withholding. By letter dated June 18, 1999, the head of the EOUSA informed counsel for TRAC that “[i]n response to future requests for case management system records, we intend to continue to release the fields agreed upon in the subject lawsuit [Long v. U.S. Dep’t of Justice, 10 F.Supp.2d 205 (N.D.N.Y.1998) ] as the appropriate ones under FOIA, absent unforeseen complications, errors or changes.” Long Decl. (Long I), Exhibit 2. In October 1999, the EOUSA released to TRAC central case management data for fiscal year 1998 that had been processed in accordance with the exemptions identified in the June 1999 Vaughn index. See Long Decl. (Long I) ¶ 10. That same month, the EOUSA announced that it also would re-release the year-end data for fiscal years 1974 through 1997 — which TRAC previously had requested and received — -in accordance with the exemption claims articulated in June 1999. See id. ¶ 11 & Exhibit 3. In other words, the EOUSA informed TRAC that it would release the data for those years to TRAC again, but with fewer redactions. In addition to TRAC’s prior requests for data for fiscal years 1974 through 1997, TRAC also had submitted a FOIA request on April 15, 1999 for central case management data for the first six months of fiscal year 1999. See Long Decl. (Long I) ¶ 15 & Exhibit l. By letter dated October 29, 1999, the EOUSA informed TRAC that it would not release the requested mid-year data for fiscal year 1999 until the year-end verification of the data was complete, on the ground that “[ijnterim, draft data is unreliable and clearly falls within the definition of pre-decisional/work product which is exempt from disclosure pursuant to 5 U.S.C. § 552(b)(5).” Long Decl. (Long I), Exhibit 3. Accordingly, on December 9, 1999, TRAC submitted a FOIA request for the year-end data for fiscal year 1999, Long Deel. (Long I), Exhibit 7, and on February 7, 2000, plaintiffs filed their initial complaint in Long I, challenging the Department’s exemption claim with respect to mid-year data. By letter dated March 21, 2000 — six weeks after plaintiffs filed suit — the EOU-SA questioned whether TRAC qualified for a fee waiver, and requested that TRAC provide, among other information, “any and all records for the previous five years regarding all fee schedules utilized by TRAC, and any and all records of any fees proposed, charged and/or received by TRAC in the previous five years.” Long Deck (Long /), Exhibit 10. Then, on March 24, 2000, the Department informed plaintiffs that it was developing new guidelines for the redaction of records from its central case management databases and that the process would delay indefinitely release of year-end data for fiscal years 1974 through 1997 and year-end data for fiscal year 1999. Long Deck (Long /), Exhibit 11. On April 11, 2000 — at which time the Department still had not released any of the records requested by TRAC — plaintiffs amended their complaint in Long I in order to challenge the EOUSA’s decision to delay release of the year-end data for fiscal years 1974 through 1997 and fiscal year 1999. And on January 3, 2001, plaintiffs filed a second amended complaint, in part to include TRAC’s request for the midyear central ease management data for fiscal year 2000, which TRAC submitted on April 3, 2000. See Long Deck (Long I), Exhibit 12. As a result, the records at issue in Long I include (1) the year-end central case management data for fiscal years 1974-1997 and fiscal year 1999; and (2) the mid-year central case management data for fiscal years 1999 and 2000. In addition to placing more records in issue, the second amended complaint also added two counts that are relevant to the motions presently being considered. The first such count relates to TRAC’s request for the mid-year data for fiscal year 2000. With respect to this request, plaintiffs allege that the EOUSA has followed a pattern and practice of not meeting the deadlines prescribed by the FOIA and not providing TRAC with the notice required by the statute and regulations when it cannot process TRAC’s requests within those deadlines. Second Amended Complaint (Long I), Fourth Count. The second added count relates to the EOUSA’s processing of TRAC’s fee waiver request. Plaintiffs allege that the EOUSA’s request for records of TRAC’s fee schedules and funding sources is unlawful, and that the EOUSA’s failure to determine whether TRAC is entitled to a fee waiver is arbitrary and capricious. Second Amended Complaint (Long I), Fifth Count. Shortly after filing their initial complaint in Long I, plaintiffs filed a motion for partial summary judgment seeking, in part, injunctive relief to require the Department to release all database records and documentation to which an exemption under the FOIA does not apply. See PI. Mot. (Long I, 5/16/00). On September 25, 2001, this Court directed the Department to release all records that erroneously had been withheld and to file a Vaughn index on or before October 15, 2001. See Order (Long I), Sept. 25, 2001, at 4. In July 2002, after years of false starts (dating back to June 1999), shifting positions, and error-filled productions of records and submissions of summary judgment motions— three of which were withdrawn or stricken because of errors, see Long v. U.S. Dep’t of Justice, 207 F.R.D. 4, 5-6 (D.D.C.2002) (denying motion for leave to supplement motion for summary judgment and directing the Department to file corrected motion) — the Department completed the “near-overwhelming project of responding to plaintiffs’ requests.” Combined Memorandum of Points and Authorities in Support of Defendant’s Combined Motion for Summary Judgment and in Opposition to Plaintiffs’ Partial Motion for Summary Judgment, filed in Long I, July 31, 2002 (“Def. Combined Mem. (Long I, 7/31/02)”) at 3. According to the Department, the vast majority of data from approximately 25 million records has been released, and only a small number of fields have been redacted. See Def. Combined Mem. (Long I, 7/31/02) at 3. The Department submits that the redacted fields are limited to names, street addresses, social security numbers, and other types of personal information relating to the subjects of the case management records (or other information that would enable the subjects to be identified); information about ongoing criminal investigations that could enable the suspects to evade or obstruct law enforcement efforts; internal administrative file numbers of no legitimate public interest; or information that could not reasonably be segregated from the above. See id. Plaintiffs, in fact, acknowledge that the Department “has come almost full circle” with respect to its exemption claims over the three-year-period between June 1999 and July 2002. PI. Combined Mem. (Long I) at 8. For example, they concede that the Department’s current position on the application of the FOIA to the central case management data for fiscal years 1974 through 1997 is identical to the position endorsed by the head of the EOUSA in June 1999. See id. Plaintiffs further describe the Department’s position with respect to the data for fiscal year 1999 and later periods as nearly identical to its June 1999 position. See id. Nevertheless, several issues remain in dispute and are the subject of the parties’ cross-motions for summary judgment in Long I. Specifically, plaintiffs challenge the Department’s exemption claims for four categories of information the Department continues to withhold: (1) internal agency file numbers; (2) the names of litigants, court docket numbers, and cases captions in civil and criminal actions; (3) the names of properties, businesses, and other non-individual entities; and (4) the lead criminal charge in ongoing criminal investigations. The parties also have cross-moved on the following three legal claims: (1) whether the Department properly may withhold data until the end of the Department’s fiscal year; (2) whether the Department provided TRAC with adequate notices under 5 U.S.C. § 552(a)(6) and 28 C.F.R. § 16.5; and (3) whether the Department acted appropriately in its consideration of TRAC’s fee waiver request. 2. Long II In April 2002, TRAC began to request central case management data from the EOUSA on a monthly basis. See O’Rourke Decl. ¶¶ 9-18. As noted above, prior to that time TRAC generally had requested mid-year or fiscal year data. By letter dated April 1, 2002, however, TRAC requested four files from the EOU-SA’s Central System containing data covering only the month of March 2002. The four files TRAC requested were the criminal flagged master, criminal immediate declination, criminal charge, and civil flagged master files. See id. ¶ 10. By letter dated May 1, 2002, TRAC requested the same four files containing data covering the month of April 2002. See id. ¶ 11. Within a few months of TRAC’s requests, the EOUSA released the March and April 2002 data, redacted in accordance with the Vaughn index filed in Long I. By letter dated June 4, 2002, TRAC requested six files from the EOUSA’s Central System containing data covering the month of May 2002. In addition to the four files requested in March and April 2002, TRAC also requested the criminal and civil delete history files. See O’Rourke Deck ¶ 14. Subsequently, in three separate FOIA requests, TRAC requested the same six files containing data covering the months of June, July, and August 2002. See id. ¶¶ 15-17. On September 17, 2002, the EOUSA notified TRAC that there would be a delay in the release of the data for May 2002 and subsequent months so that the EOUSA could undertake a thorough review “as to whether the release of information within the Central System could compromise national security or jeopardize the Department’s anti-terrorism efforts.” O’Rourke Deck, Exhibit 1. Then on October 29, 2002, the EOUSA notified TRAC of its final agency determination that, among other things, the continued release of information contained in the “program category” field from records of ongoing criminal investigations could reasonably be expected to interfere with the Department’s law enforcement efforts. See id., Exhibit 2. More specifically, the EOUSA informed TRAC that it would not release the “program category” field from the records that pertain to ongoing criminal investigations in the criminal flagged master, criminal unflagged master, and criminal delete history files for May 2002 and subsequent months. See id. By December 10, 2002, the EOUSA had released all six Central System files that TRAC had requested containing data from May through August 2002. See O’Rourke Deck ¶ 26. Other than the redactions of the “program category” fields from records of ongoing criminal investigations in the criminal flagged master, criminal unflagged master, and criminal delete history files, the materials were redacted in accordance with the Vaughn index filed in Long I. On December 16, 2002, plaintiffs filed their complaint in Long II to challenge the Department’s decision to withhold certain “program category” information from data compiled in May 2002 and later months. On May 12, 2003, the Court granted plaintiffs’ motion to consolidate the cases. II. DISCUSSION A. The Freedom of Information Act The fundamental purpose of the FOIA is to assist citizens in discovering “what their government is up to.” U.S. Dep’t of Justice v. Reporters Comm. for Freedom of the Press, 489 U.S. 749, 773, 109 S.Ct. 1468, 103 L.Ed.2d 774 (1989). The FOIA therefore strongly favors openness, since Congress recognized in enacting it that an informed citizenry is “vital to the functioning of a democratic society, needed to check against corruption and to hold the governors accountable to the governed.” NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214, 242, 98 S.Ct. 2311, 57 L.Ed.2d 159 (1978); see also Dep’t of the Air Force v. Rose, 425 U.S. 352, 360, 96 S.Ct. 1592, 48 L.Ed.2d 11 (1976) (purpose of the FOIA is “to pierce the veil of administrative secrecy and to open agency action to the light of public scrutiny”). As such, “the Act is broadly conceived,” EPA v. Mink, 410 U.S. 73, 79-80, 93 S.Ct. 827, 35 L.Ed.2d 119 (1973), and “disclosure, not secrecy, is the dominant objective of the Act.” Dep’t of the Air Force v. Rose, 425 U.S. at 361, 96 S.Ct. 1592. Under the FOIA, an agency may withhold documents responsive to a FOIA request only if the responsive documents fall within one of nine enumerated statutory exemptions. See 5 U.S.C. § 552(b). Consistent with the Act’s “goal of broad disclosure, these exemptions have been consistently given a narrow compass,” U.S. Dep’t of Justice v. Tax Analysts, 492 U.S. 136, 151, 109 S.Ct. 2841, 106 L.Ed.2d 112 (1989), and there is a “strong presumption in favor of disclosure.” U.S. Dep’t of State v. Ray, 502 U.S. 164, 173, 112 S.Ct. 541, 116 L.Ed.2d 526 (1991). The agency bears the burden of justifying any withholding, and the Court reviews the agency claims of exemption de novo. See 5 U.S.C. § 552(a)(4)(B); see also U.S. Dep’t of State v. Ray, 502 U.S. at 173-74, 112 S.Ct. 541; Assassination Archives and Research Ctr. v. CIA 334 F.3d 55, 57 (D.C.Cir.2003); Summers v. Dep’t of Justice, 140 F.3d 1077, 1079-80 (D.C.Cir.1998). To enable the Court to determine , whether documents properly were withheld, the agency must provide a detailed description of the information withheld through the submission of a so-called “Vaughn index,” sufficiently detailed affidavits or declarations, or both. See Oglesby v. U.S. Dep’t of the Army, 79 F.3d 1172, 1178 (D.C.Cir.1996); Vaughn v. Rosen, 484 F.2d 820, 827-28 (D.C.Cir.1973), cert. denied, 415 U.S. 977, 94 S.Ct. 1564, 39 L.Ed.2d 873 (1974). Furthermore, the FOIA requires that “[a]ny reasonably segregable portion of a record shall be provided ... after deletion of the portions which are exempt.” 5 U.S.C. § 552(b). This comports with the policy of disclosure and prevents the withholding of entire documents, see Billington v. U.S. Dep’t of Justice, 233 F.3d 581, 586 (D.C.Cir.2000), unless the agency can demonstrate that the non-exempt portions of a document are “inextricably intertwined with exempt portions.” Trans-Pacific Policing Agreement v. U.S. Customs Serv., 177 F.3d 1022, 1027 (D.C.Cir.1999) (quoting Mead Data Cent., Inc. v. U.S. Dep’t of the Air Force, 566 F.2d 242, 260 (D.C.Cir.1977)). To withhold the entirety of a document, the agency must demonstrate that it cannot segregate the exempt material from the non-exempt and disclose as much as possible. See Kimberlin v. Dep’t of Justice, 139 F.3d 944, 949-50 (D.C.Cir.1998). The Court may grant a motion for summary judgment if the pleadings, depositions, answers to interrogatories, and admissions on file, together with affidavits or declarations, show that there is no genuine issue of material fact and that the moving party is entitled to judgment as a matter of law. See Fed. R. Civ. P. 56(c); Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). In a FOIA case, the Court may award summary judgment solely on the basis of information provided by the department or agency in affidavits or declarations when the affidavits or declarations describe “the documents and the justifications for nondisclosure with reasonably specific detail, demonstrate that the information withheld logically falls within the claimed exemption, and are not controverted by either contrary evidence in the record nor by evidence of agency bad faith.” Military Audit Project v. Casey, 656 F.2d 724, 738 (D.C.Cir.1981); see also Vaughn v. Rosen, 484 F.2d at 826-28. Agency affidavits or declarations must be “relatively detailed and non-eonelusory.” SafeCard Servs., Inc. v. SEC, 926 F.2d 1197, 1200 (D.C.Cir.1991). Such affidavits or declarations are accorded “a presumption of good faith, which cannot be rebutted by ‘purely speculative claims about the existence and discoverability of other documents.’” Id. (internal citation and quotation omitted). An agency must demonstrate that “each document that falls within the class requested either has been produced, is unidentifiable, or is wholly [or partially] exempt from the Act’s inspection requirements.” Goland v. CIA, 607 F.2d 339, 352 (D.C.Cir.1978) (internal citation and quotation omitted). B. Exemption % Exemption 2 of the FOIA protects from mandatory disclosure records “related solely to the internal personnel rules and practices of an agency.” 5 U.S.C. § 552(b)(2). To fall within Exemption 2, the material withheld must be “used for predominantly internal purposes.” Schiller v. NLRB, 964 F.2d 1205, 1207 (D.C.Cir.1992) (quoting Crooker v. Bureau of Alcohol, Tobacco & Firearms, 670 F.2d 1051, 1073 (D.C.Cir.1981) (en banc)). If the threshold test of predominant internality is met, an agency may withhold the material “by proving that either (1) disclosure may risk circumvention of agency regulation, or (2) the material relates to trivial administrative matters of no genuine public interest.” Schwaner v. Dep’t of the Air Force, 898 F.2d 793, 794 (D.C.Cir.1990) (internal quotation marks and citations omitted). Predominantly internal records the disclosure of which would risk circumvention of agency statutes or regulations are protected by the so-called “high 2” exemption. Schiller v. NLRB, 964 F.2d at 1207. Predominantly internal records that deal with trivial administrative matters fall under the “low 2” exemption. Id. Invoking the “low 2” exemption, the Department has withheld certain database fields that contain the file numbers assigned by the agencies that have referred matters to USAOs. These fields include the “investigative agency number” and “program agency file number” in the criminal flagged master, criminal unflagged master, and criminal delete files; “agency file number” in the criminal immediate declination file; “agency file number” in the civil flagged master, civil unflagged master, and civil delete files; “agency file number” in the civil immediate declination file; “agency number/social security number” in the civil immediate declination test files; “agency number” in the TIGAS records; and “agency file number” in the Central and DNR Collections records. See Def. Combined Mem. (Long I, 7/31/02) at 48-49; Def. Mot. (Long I), Declaration of Teresa Davis (“Davis Deck”) ¶ 113. The Department submits that the file numbers are used by the law enforcement agencies involved in the cases or investigations to which the records pertain as part of their internal administrative case tracking systems. See Def. Combined Mem. (Long I, 7/31/02) at 50; Davis Deck ¶ 113. In support of its exemption claim, the Department lists several decisions where courts have held or otherwise indicated that file numbers and other internal identification systems are predominantly internal records that fall squarely within the category of information protected from disclosure under the “low 2” exemption. See Def. Combined Mem. (Long I, 7/31/02) at 50 (citing cases); Defendant’s Combined Opposition to Plaintiffs’ Motion for Partial Summary Judgment/Reply to Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment, filed in Long I, Sept. 9, 2002 (“Def. Combined Mem. (Long I, 9/9/02)”) at 44 (citing cases). The Department further submits that the rationale behind the “low 2” exemption is that trivial administrative details generally do not elucidate what the government is doing substantively and that an agency therefore should not be required to incur the burden of locating, assembling, and producing records that do not shed any light on the agency’s performance of its duties. See id. at 51. It follows, the Department continues, that when releasing “low 2” exempt information would not pose any significant burden on an agency, the agency may exercise its discretion to waive the exemption and release the information. See id. (citing Fonda v. CIA, 434 F.Supp. 498, 503 (D.D.C.1977)). With respect to many of the fields in the central case management databases that contain internal administrative numbers, the Department in fact has exercised such discretion and has released the fields. See id.; Def. Combined Mem. (Long I, 9/9/02) at 47. With respect to the fields it has withheld, however, the Department contends that releasing them would pose a significant burden on the Department. That is because in at least some of the records at issue the withheld fields contain the names or social security numbers of individuals associated with the records or contact information for law enforcement agents — information the Department maintains is exempt from disclosure under Exemption 6 and, in some instances, under Exemption 7(C) as well. See Def. Mot. (Long I), Declaration of Jeffrey D. Rupert (“Rupert Decl. (Long I)”) ¶¶ 9, 10; Declaration of Laurie Hamilton (“Hamilton Decl.”) ¶ 18; Davis Decl. ¶ 113. Therefore, in order to release these fields, the Department would have to incur the substantial burden of segregating the fields that contain such privacy-protected information from those that do not. See Def. Combined Mem. (Long I, 7/31/02) at 51; Def. Combined Mem. (Long I, 9/9/02) at 47. Plaintiffs respond that the withheld file numbers do not fall within the scope of Exemption 2 for two reasons: (1) they do not meet the threshold requirement of relating to internal personnel rules and practices; and (2) there is a public interest in their disclosure. See PI. Combined Mem. (Long I) at 43-45. In support of their first argument, plaintiffs rely primarily on Schwaner v. Dep’t of the Air Force, 898 F.2d 793 (D.C.Cir.1990). According to plaintiffs, the court in Schwaner rejected the claim that Exemption 2 allows the government to withhold information solely on the basis that it is “trivial and internal.” PI. Combined Mem. (Long I) at 44 (citing Schwaner v. Dep’t of the Air Force, 898 F.2d at 795-96, 797). Instead, relying in part on Jordan v. U.S. Dep’t of Justice, 591 F.2d 753 (D.C.Cir.1978) (en banc), plaintiffs contend that the exemption is limited to information that relates to the internal personnel rules and the internal personnel practices of an agency. See Reply in Support of Plaintiffs’ Motion for Partial Summary Judgment on the Department’s Revised Exemption Claims, and Its Claims Concerning Notice of Delay and Fee Waiver, filed in Long I, Oct. 2, 2002 (“PI. Reply (.Long I, 10/2/02)”) at 24 (citing Jordan v. U.S. Dep’t of Justice, 591 F.2d at 764 (statutory term “internal personnel” modifies both “rules” and “practices”)). Because, in plaintiffs’ estimation, the agency file numbers at issue do not relate to a personnel rule or practice, they do not qualify for Exemption 2 as a threshold matter. Plaintiffs next argue that even if the agency file numbers satisfied the statutory language, Exemption 2 still would not justify withholding them because of the legitimate public interest in their disclosure. According to plaintiffs, the Department uses the agency file numbers to reconcile its data with that of the referring agencies. See PL Combined Mem. (Long I) at 45. Inasmuch as different agencies occasionally report inconsistent statistics regarding activities that the agencies have in common, plaintiffs assert that the “agency file numbers allow researchers to correlate data reported by different agencies and identify the reasons for these conflicting reports.” Id.; see also PL Mot. (Long I, 8/5/02), Second Declaration of David Burn-ham (“Second Burnham Decl. (Long /)”) ¶¶3-5; Declaration of Michael D. Maltz (“Maltz Decl. (Long I)”) ¶¶ 8, 9, 12. Because agency data is used for budget and policy decisions, plaintiffs therefore argue that there is a significant public interest in disclosure of the agency file numbers to researchers such as TRAC. See PL Combined Mem. at 45. Although a much closer call than the Department suggests, the Court concludes that the Department properly has invoked Exemption 2 to withhold the file numbers at issue. On the threshold question — i. e., whether the information withheld falls within the statutory language— the D.C. Circuit has clarified that Exemption 2 broadly “applies to material ‘used for predominantly internal purposes.’ ” Schiller v. NLRB, 964 F.2d at 1207 (quoting Crooker v. Bureau of Alcohol, Tobacco & Firearms, 670 F.2d at 1073); see also id. (“threshold test” is one of “predominant internality”). The agency file numbers the Department has withheld, which are used by agency personnel as part of their internal administrative case tracking systems, satisfy that threshold requirement. See Schiller v. NLRB, 964 F.2d at 1207 (holding that “recordkeeping directions” are “housekeeping matters appropriately withheld under exemption 2”); Changzhou Laosan Group v. U.S. Customs and Border Protection Bureau, Civil No. 04-1919, 2005 WL 913268, at *3 (D.D.C. Apr. 20, 2005) (administrative markings, including file numbers, “are clearly documents that are predominantly internal to the agency, or are sufficiently related to a personnel rule or practice”). Neither Jordan nor Schwaner supports the narrow construction of Exemption 2 advanced by plaintiffs. While they are correct that the court in Jordan construed the statutory language of Exemption 2 strictly to cover only minor employment-related matters, they ignore subsequent circuit authority repudiating the narrow construction announced in Jordan. For example, the year immediately following Jordan, the court of appeals issued a decision in Cox v. U.S. Dep’t of Justice, 601 F.2d 1 (D.C.Cir.1979), overruled on other grounds by Benavides v. Bureau of Prisons, 993 F.2d 257 (D.C.Cir.1993), in which it held that certain information contained in the Manual for United States Marshals properly was withheld under Exemption 2 because the information relates: solely to housekeeping concerns of interest only to agency personnel. The undisclosed material does not purport to regulate activities among members of the public. Nor does it set standards to be followed by agency personnel in deciding whether to proceed against or take action affecting members of the public. Differently stated, the unreleased information is not “secret law,” the primary target of [the FOIA’s] broad disclosure provisions. Cox v. U.S. Dep’t of Justice, 601 F.2d at 5. Then in Lesar v. U.S. Dep’t of Justice, 636 F.2d 472 (D.C.Cir.1980), the court held that symbols used to refer to FBI informants in FBI documents and records “plainly fall within the ambit of Exemption 2 ... [as] a matter of [only] internal significance” in which the public has no substantial interest. Id. at 485. In Crooker, the D.C. Circuit, sitting en banc, noted that from the cases cited above, “it is plain that there is some uncertainty in this circuit regarding the scope of Exemption 2.” Crooker v. Bureau of Alcohol, Tobacco & Firearms, 670 F.2d at 1069; see also id. (“While Cox purports to follow the analysis in Jordan, its result seems inconsistent with the rationale of Jordan.”). In affirming the judgment of the district court, which had held that portions of a training manual for agents of the Bureau of Alcohol, Tobacco & Firearms were exempt under Exemption 2, the court in Crooker expressly rejected the narrow construction of the statutory language that had been adopted in Jordan. See Crooker v. Bureau of Alcohol, Tobacco & Firearms, 670 F.2d at 1053, 1074, 1075. According to the court: Although the majority opinion in Jordan stated that the language of Exemption 2 “would seem to refer to those rules and practices that concern the relations among the employees of an agency,” 591 F.2d at 763, and that “personnel” “normally eonnote[s] matters relating to pay, pension, vacations, hours of work, lunch hours, parking, etc.,” id., we feel that the meaning of Exemption 2 is not so limited. Id. at 1073 (emphasis added). Construing the statutory language more broadly, the court in Crooker concluded that the proper threshold question under Exemption 2 is whether the material relates to any rule or practice “governing agency personnel,” id. at 1056, and “is used predominantly for internal purposes,” id. at 1073; see also id. at 1074; Schwaner v. Dep’t of the Air Force, 898 F.2d at 795; Schiller v. Nat’l Labor Relations Bd., 964 F.2d at 1207. Plaintiffs’ reliance on Schwaner to support a narrow construction that would exclude the contested file numbers from the scope of Exemption 2 also is misplaced. In Schwaner, Judge Williams, writing for a divided panel, qualified the threshold test of “predominant internality” by emphasizing that information withheld under Exemption 2 must relate in some meaningful way to a genuine rule or practice of an agency. See Schwaner v. Dep’t of the Air Force, 898 F.2d at 795-98. Accordingly, the court held Exemption 2 inapplicable to a list of names and duty addresses of Air Force personnel,' which the Air Force maintained “for purely internal convenience.” Id. at 794; see also id. at 795-96 (noting that “the only ‘practice’ to which the material is relatéd is the practice of collecting data”). By contrast, the database records at issue here are maintained by the Department not merely for administrative convenience, but rather for the fundamental purpose of “track[ing] the caseload of the United States Attorney’s Offices.” PL Combined Mem. (Long I) at 1; see also O’Rourke Decl. ¶ 6. (“The EOUSA' uses this information to justify budget requests, allocate resources among district offices, and produce management reports.”). In other words, unlike compiling raw lists of names and addresses for no discernible purpose other than “purely internal convenience,” compiling information to track an agency’s performance of its core functions — which are carried out by agency personnel — is a quintessential agency practice. It follows that “the numbering system by which an agency controls the categorizing, retrieval, and dissemination of’ such information, Def. Combined Mem. (Long I, 9/9/02) at 44, sufficiently relates to an agency practice within the meaning of Exemption 2. Indeed, as the Department emphasizes, cases following Schwaner routinely include internal file or routing numbers as among the category of information that is exempt from disclosure under the “low 2” exemption. See, e.g., Dipietro v. Executive Office for U.S. Attorneys, 368 F.Supp.2d 80, 82 (D.D.C.2005); Changzhou Laosan Group v. U.S. Customs and Border Protection Bureau, 2005 WL 913268, at *3; Judicial Watch, Inc. v. U.S. Dep’t of Commerce, 83 F.Supp.2d 105, 109 (D.D.C.1999); Coleman v. FBI, 13 F.Supp.2d 75, 78 (D.D.C.1998); cf. Schiller v. NLRB, 964 F.2d at 1207 (holding that “recordkeeping directions” are “housekeeping matters appropriately withheld under exemption 2”); but see Fitzgibbon v. U.S. Secret Serv., 747 F.Supp. 51, 56 (D.D.C.1990) (internal identifications and markings are not covered by Exemption 2). While the Court can conceive of situations where agency file numbers would not qualify for consideration under Exemption 2, the Court finds that the agency numbers at issue here do. Moving to the second part of the analysis, the Court also finds that plaintiffs have failed to demonstrate a genuine public interest that would be served by disclosure. For example, although plaintiffs assert that release of the agency file numbers will help them and other researchers to identify the reasons for certain discrepancies in agency statistics, the Court — without addressing whether plaintiffs’ asserted interest even constitutes a genuine public interest — agrees with the Department that plaintiffs’ submissions insufficiently demonstrate how access to the withheld information would assist them in achieving this goal. In any event, whatever limited public interest in disclosure that may exist is outweighed by the government’s interest in avoiding the significant burden involved in collecting and evaluating this information for release — namely, locating and redacting the privacy-protected information that is scattered throughout the relevant database fields. See Def. Combined Mem. (Long I, 7/31/02) at 51; Def. Combined Mem. {Long I, 9/9/02) at 47. Accordingly, for the reasons stated, the Court concludes that the Department properly has withheld the agency file numbers under the “low 2” exemption. C. Exemption 5 Exemption 5 of the FOIA excludes from disclosure any documents that are “inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with the agency.” 5 U.S.C. § 552(b)(5). This provision protects from disclosure those documents traditionally afforded protection “pursuant to evidentiary privileges in the civil discovery context,” including those covered by the attorney-client, attorney work product, and deliberative process privileges. Dow Jones & Co. v. Dep’t of Justice, 917 F.2d 571, 573 (D.C.Cir.1990) (quoting Formaldehyde Inst. v. Dep’t of Health and Human Servs., 889 F.2d 1118, 1121 (D.C.Cir.1989) (internal quotation marks omitted)). In keeping with the FOIA’s general goal of broad disclosure, Exemption 5 is construed narrowly, Dep’t of the Interior v. Klamath Water Users Protective Ass’n, 532 U.S. 1, 8, 121 S.Ct. 1060, 149 L.Ed.2d 87 (2001), and the burden is on the agency invoking Exemption 5 to “establish[] its right to withhold evidence from the public .... [C]onclusory assertions of privilege will not suffice to carry” the agency’s burden. Senate of the Commonwealth of Puerto Rico v. U.S. Dep’t of Justice, 823 F.2d 574, 585 (D.C.Cir.1987) (quoting Coastal States Gas Corp. v. Dep’t of Energy, 617 F.2d 854, 861 (D.C.Cir.1980)). As noted above, on April 15, 1999, TRAC submitted a FOIA request for central case management data for the first six months of fiscal year 1999. See Long Decl. {Long I) ¶ 15 & Exhibit 1. By letter-dated October 29, 1999, the EOUSA informed TRAC that it would not release the requested mid-year data for fiscal year 1999 until the year-end verification of the data was complete, on the ground that “[i]nterim, draft data is unreliable and clearly falls within the definition of predecisional/work product which is exempt from disclosure pursuant to 5 U.S.C. § 552(b)(5).” Long Decl. (Long I), Exhibit 3. On February 7, 2000, plaintiffs filed their initial complaint in Long I, challenging the Department’s exemption claim with respect to mid-year data, and on May 16, 2000, they filed a motion for partial summary judgment seeking, in part, judgment against the Department’s claim that Exemption 5 of the FOIA permits the Department to withhold, database entries in their entirety prior to ■ year-end verification. See PI. Mot. (Long I, 5/16/00) at 1, 2. According to plaintiffs, the Department’s Exemption 5 claim is foreclosed as a matter of law by Petroleum Info. Corp. v. U.S. Dep’t of the Interior, 976 F.2d 1429 (D.C.Cir.1992). See Memorandum in Support of Plaintiffs’ Motion for Partial Summary Judgment and Preliminary Injunctive Relief, filed in Long I, May 16, 2000 (“PL Mem. (Long /)”) at 20-21. In that decision, the court held that an agency could not withhold certain database records on the ground that correcting errors was a privileged deliberative process protected by Exemption 5. See Petroleum Info. Corp. v. U.S. Dep’t of the Interior, 976 F.2d at 1439. The Department argues that plaintiffs’ claim now is moot because the Departmént no longer is asserting that data is exempt from disclosure prior to year-end verification and has released the records in question. According to the Department, the D.C. Circuit “has held unequivocally that the agency’s release of a document after having earlier claimed that the document was exempt ‘moots the question of the validity of the original exemption claim.’ ” Def. Combined Mem. (Long I, 7/31/02) at 36 (quoting Armstrong v. Executive Office of the President, 97 F.3d 575, 582 (D.C.Cir.1996)); see also id. at 34 (citing cases). Although acknowledging that there is an exception to the above-stated principle “for cases in which an agency has followed a ‘policy or practice’ of withholding, and the plaintiff seeks an injunction against application of that policy or practice ‘in the future,’ ” see id. at 35 (quoting Payne Enters., Inc. v. United States, 837 F.2d 486, 491 (D.C.Cir.1988)), the Department contends that there is no evidence in the record to establish such a policy or practice on the part of the Department, see id. at 35-36. Specifically, the Department submits that prior to October 29, 1999, the “EOUSA has no record of ever having ... denied a FOIA request for mid-year data on the grounds that it was categorically exempt from disclosure” under Exemption 5. Id. at 35; see also Davis Deck ¶ 15. Plaintiffs reply with two arguments. First, they contend that, contrary to the Department’s assertion otherwise, the D.C. Circuit has not established “a special mootness doctrine for FOIA actions.” Reply to Defendant’s July 31, 2002 Opposition to Plaintiffs’ Motion for Partial Summary Judgment, filed in Long I, Aug. 1, 2002 (“Pl. Reply (Long I, 8/1/02)”) at 5. Plaintiffs argue that courts long have recognized that an agency’s decision to voluntarily abandon a legal position after being challenged does not render the challenge moot if the agency may assert the same claim against the plaintiffs in the future, see id. at 4 (citing Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., 528 U.S. 167, 189, 120 S.Ct. 693, 145 L.Ed.2d 610 (2000); City of New York v. Baker, 878 F.2d 507, 511-12 (D.C.Cir.1989)), and that the D.C. Circuit has applied the principles underlying the “voluntary cessation” doctrine to FOIA cases. See id. at 5 (citing Payne Enters., Inc. v. United States, 837 F.2d 486 (D.C.Cir.1988); Better Gov’t Ass’n v. Dep’t of State, 780 F.2d 86 (D.C.Cir.1986)). Plaintiffs further assert that the cases cited by the Department suggesting a “unique rule for FOIA actions” are inapposite “because none of the cases involve situations in which the requester planned to continue to submit FOIA requests that could be subject to the same exemption claim.” Id. at 5-6. Second, relying again on Payne Enterprises and Better Government, plaintiffs argue that the Department’s claim that a FOIA requester must suffer more than one denial before the voluntary cessation doctrine applies is without merit. See PL Reply (Long I, 8/1/02) at 7. In any event, they contend that “the record shows that withholding interim data from plaintiffs was not an isolated incident, but the result of a position repeatedly reiterated by the Department over the course of several years.” Id. Specifically, in addition to the October 1999 denial letter, they point to several oral representations made by EOUSA personnel to plaintiff Long dating back to at least 1993. See Third Declaration of Susan Long, filed in Long I, May 10, 2001, ¶34. Plaintiffs also emphasize that in its submissions to the Court, “the Department has not even attempted to show that the EOUSA will not respond to [future requests for interim data] by interposing its Exemption 5 claim again to deny or delay the release of the data to Plaintiffs.” Pl. Reply (Long I, 8/1/02) at 5. The Court agrees with the Department that the question of whether Exemption 5 applies to interim data that already has been released to plaintiffs is moot. As a general proposition, “however fitful or delayed the release of information under the FOIA may be,” once an agency has released all nonexempt material, the courts “have no further judicial function to perform under the FOIA.” Tijerina v. Walters, 821 F.2d 789, 799 (D.C.Cir.1987) (quoting Perry v. Block, 684 F.2d 121, 125 (D.C.Cir.1982)); see also Crooker v. U.S. State Dep’t, 628 F.2d 9, 10 (D.C.Cir.1980) (“[0]nce the records are produced the substance of the controversy disappears and becomes moot since the disclosure which the suit seeks has already been made.”). Moreover, the record does not establish a “policy or practice” on the part of the Department that will impair TRAC’s access to interim data in the future. To the contrary, the record demonstrates that TRAC has requested and the Department has released interim data on multiple occasions subsequent to the Department’s lone denial of such a request. See O’Rourke Decl. ¶¶ 9-26. The D.C. Circuit’s decision in Payne Enterprises provides no support for plaintiffs’ contention that the controversy between the parties regarding interim data is a live one. In that case, the court emphasized that the agency had conceded both that it was following an “impermissible practice” in evaluating FOIA requests and that the requester would suffer a “continuing injury due to this practice.” Payne Enters., Inc. v. United States, 837 F.2d at 491 (footnote omitted). Here, the Department vigorously challenges any such assertions and has submitted evidence to the contrary. Plaintiffs’ reliance on Better Government also misses the mark. The FOIA requesters in that case — frequent requesters like TRAC — challenged the validity of Justice Department guidelines and an Interior Department regulation — both of which were applied by the agencies to evaluate FOIA fee waiver requests. See Better Gov’t Ass’n v. Dep’t of State, 780 F.2d at 88. Although they had been granted fee waivers for the specific FOIA requests at issue in the case — having initially been denied such waivers — the court nevertheless held that their arguments regarding the facial validity of the guidelines and regulation were not moot. Id. at 91. The dispositive issue for the court, however, was that “the Government clearly intends to apply these purportedly objectionable standards to FOIA requests in the future.” Id. Here, plaintiffs are not chailenging the standards by which the Department evaluates FOIA requests, and there is no indication that the Department intends to assert unsupported Exemption 5 claims in the future. Plaintiffs instead are challenging the application of a specific FOIA exemption to specific records in the context of a specific FOIA request. In this regard, the court’s decision in Better Government not only fails to support plaintiffs’ position but actually forecloses it. Because the requesters in that case had been granted fee waivers for the specific FOIA requests at issue, the court held that: the appellants’ challenge to the standards as applied to their specific fee waiver requests is, in fact, moot. Even assuming appellants’ claims that they were improperly denied fee waivers were well-founded, we cannot order the appellee departments to do , something they already have done, ie., waive the FOIA fees in the instant cases. As to this issue, [the appellants] “ *ha[ve] obtained everything that [they] could recover ... by a judgment of this court in their favor.’ ” The appellants apparently seek a declaration from this court that the initial refusals to waive FOIA fees were unlawful; however, such a declaration would be an advisory opinion which federal courts may not provide. Better Gov’t Ass’n v. Dep’t of State, 780 F.2d at 91 (emphasis in original; footnotes omitted). Here too, the Court cannot order the Department to do something it already has done — namely, release interim data. Here too, as well, any declaration regarding the application of Exemption 5 to interim data that the Department already has released would be an impermissible advisory opinion. See Long v. Bureau of Alcohol, Tobacco and Firearms, 964 F.Supp. 494, 497 (D.D.C.1997) (“Plaintiffs cannot evade the mootness of their claim by requesting a declaratory judgment.”). Accordingly, for the reasons stated, the Court concludes that plaintiffs’ claims regarding interim data are moot. D. Exemptions 6 and 7(C) Exemption 6 of the FOIA permits the government to withhold “personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy.” 5 U.S.C. § 552(b)(6). Under this provision, the threshold question is whether the requested information is contained in personnel, medical or “similar” files. See U.S. Dep’t of State v. Washington Post Co., 456 U.S. 595, 600, 102 S.Ct. 1957, 72 L.Ed.2d 358 (1982) (“[T]he phrase ‘similar files’ was to have a broad, rather than a narrow meaning.”); see also Horowitz v. Peace Corps, 428 F.3d 271, 277 (D.C.Cir.2005); Nat’l Ass’n of Home Builders v. Norton, 309 F.3d 26, 32 (D.C.Cir.2002); Billington v. U.S. Dep’t of Justice, 233 F.3d at 586; Ripskis v. Dep’t of Hous. and Urban Dev., 746 F.2d 1, 3 (D.C.Cir.1984). If the information sought is contained in such files, the Court must assess “whether the information is of such a nature that its disclosure would constitute a clearly unwarranted privacy invasion.” Nat’l Ass’n of Home Builders v. Norton, 309 F.3d at 32 (citing U.S. Dep’t of State v. Washington Post Co., 456 U.S. at 598, 102 S.Ct. 1957; New York Times Co. v. NASA, 920 F.2d 1002, 1004 (D.C.Cir.1990) (en banc)). To determine what constitutes a “clearly unwarranted privacy invasion,” the Court must balance the individual’s interest in privacy against the public interest in disclosure, keeping at the forefront the FOIA’s “basic policy of opening agency action to the light of public scrutiny.” Nat’l Ass’n of Home Builders v. Norton, 309 F.3d at 32 (quoting U.S. Dep’t of State v. Ray, 502 U.S. at 175, 112 S.Ct. 541 (internal quotation marks omitted)). The “public interest” inquiry is whether disclosure would “contribute significantly to public understanding of the operations or activities of government.” U.S. Dep’t of Defense v. Fed. Labor Relations Auth., 510 U.S. 487, 495, 114 S.Ct. 1006, 127 L.Ed.2d 325 (1994) (quoting U.S. Dep’t of Justice v. Reporters Comm. for Freedom of the Press, 489 U.S. at 775, 109 S.Ct. 1468); see Horowitz v. Peace Corps., 428 F.3d at 278. Throughout this analysis, the burden remains on the government to justify any withholdings, since “under Exemption 6, the presumption in favor of disclosure is as strong as can be found anywhere under the Act.” Nat’l Ass’n of Home Builders v. Norton, 309 F.3d at 32 (quoting Washington Post Co. v. U.S. Dep’t of Health and Human Servs., 690 F.2d 252, 261 (D.C.Cir.1982)); see also Ripskis v. Dep’t of Hous. and Urban Dev., 746 F.2d at 3 (“[T]he ‘clearly unwarranted’ language of Exemption 6 weighs the scales in favor of disclosure.”). Exemption 7(C) of the FOIA protects from mandatory disclosure “records compiled for law enforcement purposes” to the extent that disclosure “could reasonably be expected to constitute an unwarranted invasion of personal privacy.” 5 U.S.C. § 552(b)(7)(C). The threshold question under this provision is whether the information requested is contained in “records that have been compiled for law enforcement purposes.” Id.; Quinon v. FBI, 86 F.3d 1222, 1228 (D.C.Cir.1996). If the information sought is contained in such files, the Court must assess whether disclosure “could reasonably be expected to constitute an unwarranted invasion of personal privacy.” Nat’l Archives & Records Admin. v. Favish, 541 U.S. 157, 165, 171, 124 S.Ct. 1570, 158 L.Ed.2d 319 (2004). As with Exemption 6, in determining whether Exemption 7(C) applies to particular material, the Court must balance the interest in privacy of the individual mentioned in the record against the public’s interest in disclosure. See Beck v. Dep’t of Justice, 997 F.2d 1489, 1491 (D.C.Cir.1993); Stern v. FBI, 737 F.2d 84, 91 (D.C.Cir.1984). It is the “interest of the general public, and not that of the private litigant” that the Court considers in this analysis. Brown v. FBI, 658 F.2d 71, 75 (2d Cir.1981) (citing Ditlow v. Shultz, 517 F.2d 166, 171-72 (D.C.Cir.1975)). “[T]he only public interest relevant for purposes of Exemption 7(C) is one that focuses ‘on the citizens’ right to be informed about what their government is up to.’ ” Davis v. U.S. Dep’t of Justice, 968 F.2d 1276, 1282 (D.C.Cir.1992) (quoting U.S. Dep’t of Justice v. Reporters Comm, for Freedom of the Press, 489 U.S. at 773, 109 S.Ct. 1468). Furthermore, while acknowledging that the Supreme Court has construed Exemption 7(C) to be “somewhat broader” than Exemption 6, Nat’l Archives & Records Admin. v. Favish, 541 U.S. at 165-66, 124 S.Ct. 1570; U.S. Dep’t of Justice v. Reporters Comm. for Freedom of the Press, 489 U.S. at 756, 109 S.Ct. 1468, the D.C. Circuit “has deemed the privacy inquiry of Exemptions 6 and 7(C) to be essentially the same.” Judicial Watch, Inc. v. Dep’t of Justice, 365 F.3d 1108, 1125 (D.C.Cir.2004) (citing Reed v. NLRB, 927 F.2d 1249, 1251 (D.C.Cir.1991); Nat’l Ass’n of Retired Fed. Employees v. Horner, 879 F.2d 873, 874 (D.C.Cir.1989)); see also Beck v. Dep’t of Justice, 997 F.2d at 1491. Thus, “the difference between the standards for the two exemptions ‘is of little interest’ except when analyzing ‘the magnitude of the public interest that is required to override the respective privacy interests protected by the exemptions.’ ” Horowitz v. Peace Corps., 428 F.3d at 279 n. 2 (quoting U.S. Dep’t of Def. v. Fed. Labor Relations Auth., 510 U.S. 487, 496 n. 6, 114 S.Ct. 1006, 127 L.Ed.2d 325 (1994)). The Department has withheld certain fields on the ground that release of the information contained therein “would generally reveal private information about the subject of a case management record (i.e., the defendant, litigant, suspect, etc.).” Def. Combined Mem. (Long I, 7/31/02) at 39. Specifically, the Department has withheld the following fields: “defendant name” in the criminal flagged master, criminal unflagged master, and criminal delete history files; “suspect” and “social security number” in the criminal immediate declination file; “litigant name” in the civil flagged master, civil unflagged master, and civil delete history files; “name” in the civil immediate declination file; “name” and “agency number/social security number” in the civil immediate declination test file; “name_first,” “name_last,” “social security number,” and “address_l” in the TIGAS database; “debtor last name,” “debtor first name,” “SSN,” and “street” in the Central Collections database; and “debtor name,” “debtor last name,” “debtor first name,” “SSN,” a