Full opinion text
RULING ON DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT [Doc. Nos. 15, 20, 25, 39, 57] JANET C. HALL, District Judge. This action is brought under the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552. Plaintiff, Rashad Ahmad Refaat El Badrawi, seeks declaratory and injunctive relief to compel disclosure of records held by the defendants, the Department of Homeland Security (“DHS”), the Department of State (“DOS”), and the Department of Justice (“DOJ”). On October 19, 2006, El Badrawi submitted FOIA requests to three component agencies of DHS — Customs and Border Protection (“CBP”), Citizenship and Immigration Services (“CIS”), and Immigration and Customs Enforcement (“ICE”) — as well as DOS, the Federal Bureau of Investigation (“FBI”) (a component of DOJ), and the Employment and Training Administration (“ETA”) (a component of the Department of Labor). Each agency responded to El Badrawi individually. On March 9, 2007, El Badrawi initiated the current action, alleging that the agencies had been largely unresponsive to his requests for records. In November 2007, El Badrawi dropped his claim against ETA. The five remaining defendants, CBP, DOS, FBI, ICE, and CIS, have each filed a Motion for Summary Judgment. See Doc. Nos. 15, 20, 25, 39, and 57. Specifically, the defendants seek summary judgment with respect to: 1) the adequacy of the agencies’ searches; 2) the reasonableness of the referral of documents to their originating agencies for direct review and response; 3) the propriety of the withholding of certain records and the propriety of the exemptions invoked to justify those withholdings; and 4) the reasonableness of the agencies’ segregability determinations. For the reasons that follow, the Motions are GRANTED in part and DENIED in part. I. STANDARD OF REVIEW The Freedom of Information Act is “broadly conceived to reflect a general philosophy of full agency disclosure.” ACLU v. DOD, No. 06-3140-cv (2d Cir. Sept. 22, 2008) (internal quotations omitted). In other words, “[the Act] adopts as its most basic premise a policy strongly favoring public disclosure of information in the possession of federal agencies.” Halpern v. FBI, 181 F.3d 279, 286 (2d Cir.1999). It “... was enacted to promote honest and open government and to assure the existence of an informed citizenry....” Grand Cent. P’ship., Inc. v. Cuomo, 166 F.3d 473, 478 (2d Cir.1999). There are, however, limits to FOIA’s reach. Specifically, “[i]n recognition of those interests that may at times conflict with [the] policy of full disclosure, FOIA also provides nine exemptions from its disclosure requirement....” Halpern, 181 F.3d at 287. Yet, “[i]n keeping with the policy of full disclosure, the exemptions are narrowly construed with doubts resolved in favor of disclosure.” Id. (internal quotations omitted). In a motion for summary judgment, the burden is on the moving party to establish that there are no genuine issues of material fact in dispute and that it is entitled to judgment as a matter of law. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 256, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986); White v. ABCO Engineering Corp., 221 F.3d 293, 300 (2d Cir.2000). “In order to prevail on a motion for summary judgment in a FOIA case, the defending agency has the burden of showing that its search was adequate and that any withheld documents fall within an exemption to FOIA.” Carney v. United States Dep’t of Justice, 19 F.3d 807, 812 (2d Cir.1994). “Affidavits ... supplying facts indicating that the agency has conducted a thorough search and giving reasonably detailed explanations why any withheld documents fall within an exemption are sufficient to sustain the agency’s burden.” Id. “Affidavits submitted by an agency are accorded a presumption of good faith, ... [and] accordingly, discovery relating to the agency’s search and the exemptions it claims for withholding records generally is unnecessary if the agency’s submissions are adequate on their face.” Id. (internal quotations omitted). “When this is the case, the district court may forgo discovery and award summary judgment on the basis of affidavits.” Id. (internal quotations omitted). As the Second Circuit has noted, however, “... the good faith presumption that attaches to agency affidavits only applies when accompanied by reasonably detailed explanations of why material was withheld.” Halpern, 181 F.3d at 295. Finally, FOIA instructs district courts to review de novo agency decisions to withhold records. 5 U.S.C. § 552(a)(4)(B). The de novo standard of review for FOIA cases is well established in this circuit. See, e.g., Halpern, 181 F.3d at 288; Massey v. FBI, 3 F.3d 620, 622 (2d Cir.1993); Hopkins v. United States Dep’t of Hous. & Urban Dev., 929 F.2d 81, 84 (2d Cir.1991). II. FACTUAL BACKGROUND A. Plaintiffs Arrest, Detention, and Voluntary Departure El Badrawi is a foreign national who studied and worked lawfully in the United States for nearly eleven years. Declaration of Rashad Ahmad Refaat El Badrawi (“El Badrawi Deck”) at ¶¶ 1-2. He worked primarily in the biotechnology industry. Id. at ¶ 2. On May 26, 2003, DOS issued El Badrawi an Hl-B non-immigrant visa authorizing him to enter the United States and accept employment at the University of Connecticut (“UCONN”) Health Center in Hartford, Connecticut. From June 2003 to October 2004, El Ba-drawi was employed at the UCONN Health Center as a research associate in the Richard D. Berlin Center for Cell Analysis and Modeling. Unknown to El Badrawi or his employer, however, DOS had administratively revoked his visa on October 2, 2003. Id. at ¶ 7; Exhibit 12 to Plaintiffs Memorandum in Opposition to FBI’s Motion for Summary Judgment (“Plaintiffs Mem. in Opp. to FBI”). By the terms of the certificate of revocation, the revocation was effective only upon El Badrawi’s departure from the United States. Id. El Badrawi did not leave the United States between June 2003 and his eventual removal, and therefore he had no indication that his visa had been revoked. El Badrawi Deck at ¶ 8. On October 29, 2004, El Badrawi was arrested in the parking lot of his Hartford residence by officers from Immigration and Customs Enforcement (“ICE”), an investigative branch of DHS. Id. at ¶ 11. He was subsequently detained at the Hartford Correctional Center where he was placed in the general population of inmates. Id. at ¶ 12. Due to harsh detention conditions and fearful that he had been falsely linked with national security concerns, El Badrawi felt he had no choice but to accept voluntary departure from the United States. Id. at ¶ 13. On November 10, 2004, he accepted voluntary departure. Rather than being released, however, El Badrawi was imprisoned at the Hartford Correctional Center for an additional 42 days. Id. at ¶¶ 14-15. On December 22, 2004, ICE officers finally took El Badrawi to John F. Kennedy International Airport in Queens, New York and placed him on a flight out of the United States. Id. at ¶ 16. In January 2005, El Badrawi met with officials at the United States Embassy in Beirut, Lebanon to discuss his visa revocation. Id. at ¶ 17. Embassy officials did not provide El Badrawi with any specific information regarding his treatment. Id. at ¶ 17. To date, he has not received any specific information from any source regarding the reasons for his visa revocation, arrest, or removal. Id. at ¶ 18. B. El Badrawi’s FOIA Requests and Defendant’s Responses 1. CBP On October 19, 2006, El Badrawi filed a FOIA request with CBP seeking access to, and copies of, any records held by CBP mentioning or concerning himself. See Plaintiffs Mem. in Opp. to CBP at 3. El Badrawi noted in this initial FOIA request that there was at least one known alternative spelling of his name. Exhibit B to CBP’s Local Rule 56(a)l Statement of Material Facts Not in Dispute (“CBP 56(a)l Stmt”). In responding to plaintiffs request, CBP located eight records mentioning El Ba-drawi in its Treasury Enforcement Communications System (“TECS”) database, but determined that all eight records belonged to other agencies. Suzuki Deck at ¶ 7. As a result, on December 9, 2006, CBP issued a response to El Badrawi, stating that it was “unable to locate any records in the [CBP] database within the releasing authority of CBP.” Exhibit C to CBP 56(a)l Stmt. On December 20, 2006, El Badrawi appealed CBP’s response. Exhibit D to CBP 56(a) 1 Stmt. Due to administrative error, CBP misplaced the appeal. Suzuki Deck at ¶ 8. CBP later located the appeal and began processing it on March 21, 2007. Id. at ¶ 8. In response to El Badrawi’s appeal, CBP reversed its initial decision and determined that one of the eight documents was a responsive CBP record. CBP provided that document to El Badrawi in redacted form on July 9, 2007. Exhibit E to CBP 56(a)l Stmt. CBP confirmed that the other seven documents located during the initial search were not CBP records, and thus should be referred to the originating agencies for determinations as to their releasa-bility. Suzuki Deck at ¶ 9. Of these, two records were referred to DOS, and three were referred to ICE. Id. at ¶ 9. The remaining two documents were later determined to be CBP documents and released in part to El Badrawi on December 18, 2007. Id. at ¶ 11. Subsequently, on January 4, 2008, CBP received from ICE six CBP records responsive to plaintiffs request containing variations in the spelling of El Badrawi’s name. Supp. Suzuki Deck at ¶ 7. Noting the variant spellings — apparently for the first time — CBP conducted another search of its TECS database and discovered another eight responsive records. Id. at ¶ 11. These fourteen additional records were released to El Badrawi on January 15, 2008. Id. at ¶ 12. Thirteen were released in part; one in full. Id., Attachment A. 2. DOS On October 19, 2006, El Badrawi submitted a FOIA request to DOS seeking, inter alia, “[a]ny record concerning the revocation of Mr. Badrawi’s Hl-B visa on October 2, 2003.” Plaintiffs Mem. in Opp. to DOS at 4. By letter dated December 1, 2006, defendant acknowledged receipt of the request. Id. El Badrawi brought the instant claim on March 9, 2007, after having received no records from DOS. In a letter dated March 21, 2007, DOS informed El Badrawi that it had located 37 relevant documents totaling 57 pages. DOS Memorandum in Support of Motion for Summary Judgment (“DOS Mem.”) at 4. DOS further advised El Badrawi that, of the 37 documents, two were being released in full, four released in part, and 30 withheld in full. The letter also noted that one document had originated with another agency and had been forwarded to that agency for a response. Id. at 4. This statement was erroneous, however, as the document in question was actually released in full to El Badrawi with the March 21 letter (this error was communicated to El Badrawi by letter on December 18, 2007). Id. at 6-7. Subsequently, by letter dated March 26, 2007, DOS informed El Badrawi that it had located an additional seven responsive documents in the Central Foreign Policy Records database, and that all seven documents were being withheld in full. Id. at 4. Finally, two other documents retrieved by DOS were forwarded to another agency for its review. Declaration of Margaret Grafeld (“Grafeld Decl.”) at ¶ 24. It was determined by the unnamed originating agency that the documents were to be withheld in full. Supplementary Declaration of Margaret Grafeld (“Supp. Grafeld Decl.”) at ¶ 4. This determination was communicated to El Badrawi in a letter from DOS on September 9, 2008. Id. El Badrawi appealed the DOS withhold-ings and the adequacy of the DOS search in letters dated April 2, 2007 and April 3, 2007. Id. at 5. Both appeals were denied by DOS in a December 4, 2007 letter. Id. Finally, by separate letter on December 4, DOS advised El Badrawi that all searches — including a search of the United States Embassy in Damascus — had been completed, and that no additional responsive documents had been found. Id. 3. FBI By letter dated October 19, 2006, El Badrawi submitted a FOIA request to the FBI for “any record held by the [FBI] mentioning or concerning” himself. Plaintiffs Mem. in Opp. to FBI at 5. On November 21, 2006, the FBI responded by letter, informing El Badrawi that “a search of the automated indices to the Central Records System at FBIHQ located no records responsive to [El Badrawi’s] FOIA request....” FBI Mem. at 3. El Badrawi appealed this determination by letter dated December 11, 2006. Id. On January 11, 2007, the FBI acknowledged receipt of El Badrawi’s administrative appeal. Id. at 3-4. El Badrawi commenced the instant action on March 9, 2007, after which the FBI informed El Badrawi that it was closing his appeal due to the court proceedings, in accordance with 28 C.F.R § 16.9(a)(3). Id. at 4. On April 19, 2007, the FBI filed an Answer to El Badrawi’s Complaint (Doc. No. 7). In the Answer, the FBI stated that “the ‘no records’ response which, was provided in administrative error to plaintiff, ... was incorrect. FBI’s policy under FOIA is to neither confirm nor deny the existence of records responsive to the type of request made by plaintiff.” Def. Ans. at 10. In separate litigation, however, the federal government confirmed the existence of at least one FBI record responsive to El Badrawi’s FOIA request. Plaintiffs Mem. in Opp. to FBI at 6. Specifically, in El Badrawi v. Commissioner, State of Connecticut, Department of Corrections, Docket No. FIC 2007-136, United States Attorney Kevin O’Connor (“O’Connor”) submitted a Statement of Interest on July 18, 2007 confirming the existence of a “data sheet from the National Crime Information Center (‘NCIC’), a database operated by the [FBI], in connection with the pre-deportation detention of [El Badrawi] at the Hartford Correctional Center.” Id. Having received confirmation of the existence of at least one NCIC record, El Badrawi submitted a follow-up FOIA request to the FBI on November 19, 2007, specifically requesting the NCIC record at issue. Id. In the same letter, El Badrawi informed the FBI that he had received a record from ICE confirming that the FBI had “participated in [El Badrawi’s] arrest and subsequent interview” pursuant to Operation Frontline. Id. at 7. Consequently, El Badrawi also specifically requested records pertaining to the FBI’s investigation of him under Operation Frontline. Id. In a letter dated December 4, 2007, the FBI acknowledged the existence of the NCIC data sheet referenced by O’Connor, but “denie[d] that the existence of this NCIC data sheet either confirms or denies the existence of records regarding [El Ba-drawi].” Id. The FBI also stated that it “continues to assert its Glomar response to plaintiffs FOIA request.” Id. Later, by letter dated January 15, 2008, the FBI released to El Badrawi five pages of records, in redacted form, responsive to his original FOIA request. Id. These five pages consisted of two “cross-reference” files from the FBI’s Central Records System (“CRS”), containing mere mention or reference to El Badrawi in a record located in a separate “main” file on a different subject matter. Id. To date, the FBI has not released any NCIC record concerning El Badrawi or any record regarding the Operation Front-line investigation of him. Id. It has informed El Badrawi that of the NCIC’s 18 computerized database files, no records related to El Badrawi exist in 17 of the databases. Declaration of Kimberly J. Del Greco (“Del Greco Dec!.”) at 6. The FBI refuses to confirm or deny that any responsive records are contained in the NCIC’s Violent Gang and Terrorist Organization File (“VGTOF”). 4. ICE By letter dated October 19, 2006, El Badrawi submitted a FOIA request to ICE for all records “mentioning or concerning” himself. Plaintiffs Mem. in Opp. to ICE at 3. ICE had not begun processing El Badrawi’s request when this action was commenced on March 9, 2007. ICE Mem. at 5. In connection with another lawsuit, in July, 2007, ICE released a number of records from its investigative file on El Ba-drawi and its Treasury Enforcement Communications System (“TECS”), including one document in full and 36 documents with redactions. Id. at 7. ICE also withheld ten responsive documents in full at that time. Id. After receiving a second letter from El Badrawi in November 2007, requesting a more complete response, ICE searched a second database, and located an additional nine responsive records. Id. Shortly thereafter, ICE received 21 pages of responsive documents from the Hartford Correctional Center. Id. at 8. In December 2007, ICE also conducted a search for records related to El Badrawi’s Visa-Revocation Action Lead Referral (“ALR”), and to a March 2004 interview of El Badrawi by ICE officials pursuant to the ALR. Id. These searches yielded additional responsive records, id., as did a search for emails relating to El Badrawi, id. at 9. Consequently, on December 14, 2007, ICE released to El Badrawi an additional 13 documents in full and 29 documents with redactions. Id. It withheld, at that time, 10 documents in their entirety. Id. In January 2008, ICE referred 17 pages of responsive records to CBP. Id. Finally, on February 13, 2008, ICE released to El Badrawi 56 pages of records in full (including 10 that had previously been withheld in full) and 31 pages in redacted form. Id. at 10. It also withheld, at that time, 52 pages of records in full. Id. To date, ICE has located 227 pages of records responsive to El Badrawi’s request. Id. at 1. Of this total, ICE has released to El Badrawi, over the course of numerous responses, 70 pages in full and 95 pages with redactions. Id. at 1-2. It has withheld 62 pages in full. Id. at 2. 5. CIS On October 19, 2006, El Badrawi submitted a FOIA request to CIS requesting “any record held by [CIS] mentioning or concerning [himself].” CIS Mem. at 2. After an initial general search of its Alien File/Central Index System (A-file/CIS), the CIS’s National Records Center (NRC), located in Lee’s Summit, Missouri, could not locate four responsive files it expected to find. Id. at 3. The files were for immigration transactions initiated by El Ba-drawi. Id. Further research revealed that three of the files were at CIS’s Harrison-burg File Facility and that one was at CIS Headquarters in Washington, D.C. Id. The three receipt files from Harrison-burg were received by the NRC in April 2007, and processed along with a copy of El Badrawi’s “alien file.” Id. at 4. These files included 351 pages of responsive documents. Id. Of these, on April 18, 2007, CIS released to El Badrawi 270 pages in full and 45 pages in part. Id. CIS withheld 30 pages in full. Id. Six pages were referred to DOS. Declaration of Brian J. Welsh (“Welsh Decl.”) ¶ 13. The fourth receipt file has not yet been located. CIS Mem. at 4. On May 22, 2007, El Badrawi appealed CIS’s decision to withhold certain information. Id. As a result of the appeal, on March 18, 2008, CIS fully released to El Badrawi two pages which had previously been released in redacted form, and released to El Badrawi information previously redacted from nine pages withheld in part. Id. Further, as a result of this appeal, CIS referred to DOS one page previously withheld in full, making a total of seven records referred to DOS. Id. Defendants’ submissions are unclear as to the disposition of these seven documents. III.ANALYSIS A. Adequacy of Agency Searches All five agencies have moved for summary judgment on the adequacy of the searches they undertook in response to El Badrawi’s FOIA requests. FOIA mandates that in responding to “... a request for records, an agency shall make reasonable efforts to search for the records.... ” 5 U.S.C. § 552(a)(3)(C). To prevail on summary judgment when the adequacy of an agency’s search is at-issue, “the defending agency must show beyond material doubt that it has conducted a search reasonably calculated to uncover all relevant documents.” Morley v. CIA, 508 F.3d 1108, 1114 (D.C.Cir.2007) (internal quotations omitted). “In adjudicating the adequacy of the agency’s identification and retrieval efforts, the trial court may be warranted in relying upon agency affidavits.” Id. at 1116 (citation omitted). The Second Circuit has adopted the D.C. Circuit position that such reliance is only appropriate, however, when agency affidavits are “... relatively detailed and nonconclusory, and submitted in good faith.” Grand Cent. P’ship., Inc. v. Cuomo, 166 F.3d 473, 488-9 (2d Cir.1999) (citing SafeCard Servs., Inc. v. SEC, 926 F.2d 1197, 1200 (D.C.Cir.1991)). In other words, “[a] district court in a FOIA case may grant summary judgment in favor of an agency on the basis of agency affidavits if they contain reasonable specificity of detail rather than merely conclusory statements, and if they are not called into question by contradictory evidence in the record or by evidence of agency bad faith.” Id. at 478 (emphasis in Grand Cent. P’ship., Inc.) (internal quotations omitted). The agencies have each submitted affidavits describing their respective searches. The question before the court is whether these affidavits are “relatively detailed and nonconclusory, and submitted in good faith.” Id. Because “[affidavits submitted by an agency are accorded a presumption of good faith,” Carney, 19 F.3d at 812, this court’s initial inquiry necessarily focuses on whether the defendants’ affidavits meet the “relatively detailed and nonconclusory” standard. “A reasonably detailed affidavit, setting forth the search terms and the type of search performed, and averring that all files likely to contain responsive materials (if such records exist) were searched, is necessary to afford a FOIA requester an opportunity to challenge the adequacy of the search and to allow the district court to determine if the search was adequate in order to grant summary judgment.” Tarullo v. United States DOD, 170 F.Supp.2d 271 (D.Conn.2001) (quoting Oglesby v. United States Dep’t of Army, 920 F.2d 57, 67 (D.C.Cir.1990)). Affidavits should “ ‘identify the searched files and describe at least generally the structure of the agency’s file system’ which renders any further search unlikely to disclose additional relevant information.” Katzman v. CIA, 903 F.Supp. 434, 438 (E.D.N.Y.1995) (quoting Church of Scientology v. IRS, 792 F.2d 146, 151 (D.C.Cir.1986), aff'd, 484 U.S. 9, 108 S.Ct. 271, 98 L.Ed.2d 228 (1987)). Moreover, “[a]n affidavit from an agency employee responsible for supervising a FOIA search is all that is needed to satisfy Rule 56(e); there is no need for the agency to supply affidavits from each individual who participated in the actual search.” Carney, 19 F.3d at 814. As Carney makes clear, however, the agency employee submitting an affidavit must have some personal involvement in supervising the FOIA search. See id. (noting that the employees who prepared the declarations in question “personally supervised [plaintiffs] requests and reviewed the withheld documents,” and were “personally involved in processing [plaintiffs] requests”). Finally, it bears noting that, even if an agency has met its burden by submitting, in good faith, relatively detailed and nonconclusory affidavits, “the requester may nonetheless produce countervailing evidence, and if the sufficiency of the agency’s identification or retrieval procedure is genuinely in issue, summary judgment is not in order.” Motley, 508 F.3d at 1116. In other words, after the burden has shifted, “the plaintiff must make a showing of bad faith on the part of the agency sufficient to impugn the agency’s affidavits of declarations, or provide some tangible evidence that ... summary judgment is otherwise inappropriate.” Carney, 19 F.3d at 812. 1. CBP In his October 19, 2006 FOIA request to CBP, El Badrawi sought “access to and copies of any record held by [CBP] mentioning or concerning [himself] ... including but not limited to any record found in the Treasury Enforcement Communications System (TECS), Interagency Border, National Automated Immigration Lookout System (NAILS), or Computer Linked Application Information Management System (CLAIMS) databases.” Exhibit B to the Declaration of Shari Suzuki (“Suzuki Decl.”). CBP moves for summary judgment as to the adequacy of the search it undertook in response to this request. In support of its Motion for Summary Judgment (Doc. No. 15), CBP submitted the declaration of Shari Suzuki, Chief of CBP’s Freedom of Information Act Appeals, Policy, and Litigation Branch (“FAPLB”) in Washington, D.C. Suzuki notes that as Chief, she is responsible for “overall supervision and management of the FAPLB,” including, inter alia, the following responsibilities: “1) giving guidance and instructions to the personnel in CBP regarding the processing of FOIA requests; 2) adjudicating administrative appeals that concern FOIA requests; and 3) overseeing all CBP activities related to information disclosure.” Suzuki Decl. at 1. Suzuki has held her current position since April 2, 2006. Id. Suzuki states that she is “familiar with [El Badrawi’s] request for information from CBP, pursuant to the FOIA,” and that all information contained in her declaration is based upon information furnished to her in her official capacity. Id. at 2. Suzuki avers that the statements she makes in her declaration are based upon her personal knowledge, which includes knowledge acquired through, and agency files reviewed in course of, her official duties. Id. Regarding the search itself, Suzuki states that: CBP’s record search in response to plaintiffs request comprised of searching records retained in the TECS system, a computer based telecommunications system containing investigative and law enforcement information per-tabling to individuals, business, conveyances, and the importation and exportation of merchandise. TECS is the principal information system supporting the border management and law enforcement mission of CBP and is the sole interface to the CBP records concerning the interaction of the CBP officers with persons entering the United States. Further, it is the only database that would reasonably contain the information requested in [El Badrawi’s] FOIA request. Id. at 5. Suzuki then provides a description of the types of records contained in TECS, and concludes that “[a]ny and all information created by CBP regarding plaintiff would be maintained in TECS.” Id. The declaration continues: There are no other CBP records from NAILS or CLAIMS databases [the other databases specifically referenced in El Badrawi’s FOIA request]. In January 2005, all data that was contained in NAILS database was merged into TECS, and NAILS ceased to exist. Thus there are no NAILS records responsive to plaintiffs request. CLAIMS database is maintained by [CIS]; it is not a CBP system of records. CBP has no access to search CLAIMS database; therefore, that database was not searched. Id. at 6. The Suzuki declaration is insufficient on two grounds. It fails to meet the “relatively detailed and nonconclusory” standard because: 1) it does not “describe at least generally the structure of the agency’s file system” which renders any further search unlikely to disclose additional relevant information, Church of Scientology v. IRS, 792 F.2d 146, 150 (D.C.Cir.1986); Katzman, 903 F.Supp. at 438; and 2) because it does not justify searching only the TECS database. First, it must be noted that this court, other courts in this Circuit, and the D.C. Circuit, have all held that affidavits describing a search “must detail files searched and the general scheme of the agency file system.” Fisher v. FBI, 94 F.Supp.2d 213, 218 n. 2 (D.Conn.2000); see also Church of Scientology v. IRS, 792 F.2d 146, 150 (D.C.Cir.1986); Dinsio v. FBI, 445 F.Supp.2d 305, 312 (W.D.N.Y. 2006); Rabin v. United States Dep’t of State, CIA, 980 F.Supp. 116, 120 (E.D.N.Y. 1997). Without at least an elementary description of the general scheme of an agency’s file system, a FOIA requester has no basis upon which to dispute an agency’s assertion that “any further search [is] unlikely to disclose additional relevant information.” Katzman, 903 F.Supp. at 438. The Suzuki declaration does not contain such a description. It merely describes the TECS database — the database actually searched — and explains why two other databases referenced by El Badrawi’s FOIA request were not searched. It makes no attempt to describe the general scheme of CBP’s file system. Such a description might include, for example, a list of databases to which CBP has access and a delineation of what types of records each database contains. The lack of such disclosure stymies El Badrawi’s ability to advocate his position and does not meet the “relatively detailed and noneonelusory” standard adopted by the Second Circuit. Grand Cent. P’ship., Inc., 166 F.3d at 489. In addition, the Suzuki declaration is insufficiently detailed because it fails to explain why CBP chose to search only the TECS database. Suzuki’s statements that “[TECS] is the only database that would reasonably contain the information requested in [El Badrawi’s] FOIA request,” Suzuki Decl. at 5, and that “[a]ny and all information created by CBP regarding plaintiff would be maintained in TECS,” Id. at 6, are conclusory. The declaration offers no detail to support these statements, other than a cursory description of the TECS database. Further, in a declaration submitted on September 12, 2008 in support of CBP’s Motion for Summary Judgment, Valerie Isbell notes that she, as Executive Director of CBP’s Passenger Systems Programs Office (PSPO), “is responsible for the development and operational management of over 44 systems that support more than 70,000 users from over 20 Federal agencies that are responsible for traveler processing and border security services.” Isbell Decl. at 1. Isbell gives no indication, however, that these 44 systems were searched, or in the alternative, that a decision was specifically taken not to search them. CBP’s failure to give detailed justifications for not searching these databases, and any other databases it may own or have access to, falls below the standard for “relatively detailed and non-conclusory” affidavits required to legitimate a summary judgment ruling. Grand Cent. P’ship., Inc., 166 F.3d at 489. Consequently, CBP has not met its burden of proving that it conducted a reasonable search as a matter of law. Its Motion for Summary Judgment (Doc. No. 15) is denied as to the adequacy of its search. When agency affidavits and Vaughn in-dices fail to meet standards, a “district court will have a number of options for eliciting further detail from the government. It may require supplemental Vaughn affidavits or may permit appellant further discovery.” Halpern, 181 F.3d at 295. When the courts have permitted discovery in FOIA cases, it is generally limited to the scope of the agency’s search. See Weisberg v. DOJ, 627 F.2d 365, 371 (D.C.Cir.1980). Further, courts have consistently held that “a court should not, of course, cut off discovery before a proper record has been developed; for example, where the agency’s response raises serious doubts as to the completeness of the agency’s search, where the agency’s response is patently incomplete, or where the agency’s response is for some other reason unsatisfactory.” Exxon Corp. v. FTC, 466 F.Supp. 1088, 1094 (D.D.C.1978). The court finds that CBP’s response as to the adequacy of its search is patently incomplete. Therefore, El Badrawi is permitted limited discovery on this issue. 2. DOS On October 19, 2006, El Badrawi submitted a FOIA request to DOS seeking: Access to and copies of ... any record held by [DOS] mentioning or concerning [himself] ... including but not limited to: 1) any record concerning the issuance of Mr. El Badrawi’s Hl-B Visa on December 29, 1999; 2) any record concerning the issuance of Mr. El Badrawi’s Hl-B Visa in May of 2003; 3) any record concerning the issuance of any other Visa to Mr. El Badrawi; 4) any record concerning the revocation of Mr. El Ba-drawi’s Hl-B visa on October 2, 2003; 5) any record concerning Mr. El Ba-drawi’s purported ineligibility to receive a visa under Section 212(a)(3) of the Immigration & Nationality Act; and 6) any record concerning Mr. El Badrawi found in the Consular Lookout and Support System (CLASS), National Security Entry/Exit Registration System (NSEERS), Consolidated Consular Database (CCD), or TIPOFF databases. Exhibit 1 to Declaration of Margaret P. Grafeld (“Grafeld Decl.”)• DOS moves for summary judgment as to the adequacy of the search it undertook in response to this request. In support of its Motion for Summary Judgment (Doc. No. 20), DOS submitted the declaration of Margaret P. Grafeld, DOS’s Information and Privacy Coordinator and Director of DOS’s Office of Information Programs and Services (“IPS”). Grafeld states that she is “the [DOS] official immediately responsible for responding to requests under [FOIA], the Privacy Act ... and other applicable records access provisions.” Id. at 1. Grafeld further avers that she “makes [the statements contained in the declaration] based upon [her] personal knowledge, which in turn is based on a personal review of the records in the case file established for the processing of [El Badrawi’s] request, and upon information furnished to [her] in the course of [her] official duties.” Id. at 2. She notes that she has “read the complaint filed by [El Badrawi], and [is] familiar with the efforts of [DOS] personnel to process the ... request.” Id. With regard to the search itself, Grafeld states that DOS’s “search for records responsive to [El Badrawi’s] request was designed to uncover all responsive records. When a FOIA request is received, IPS evaluates the request and determines which offices, overseas posts, or other records systems within [DOS] may reasonably be expected to contain the information requested. This determination is based on the description of records set forth in the request letter.” Id. at 8. “In [El Badrawi’s] case,” Grafeld continues, “IPS conducted a search of the Central File that was intended to identify any documents relating to [El Badrawi].” Id. at 9. She notes that “the Central File is [DOS’s] most comprehensive and authoritative compilation of documents [and] it is by far the most frequently searched in response to FOIA requests.” Id. In paragraph 16, Grafeld describes the Central File. Id. at 8. Grafeld also states that: In addition to the Central File, [DOS] has decentralized records systems maintained in the Department’s domestic offices and at foreign service posts overseas. These records generally are concerned with specialized and unique activities and programs of the Department rather than with general foreign policy issues. Decentralized records systems include, among other things, personnel, security, medical and consular records. Id. at 10. “In this case,” she notes, “based on the information provided by plaintiff, in addition to the search of the Central File described above, searches were also conducted of the records maintained by the Office of Visa Services, the American Embassy in Damascus, and the Bureau of Intelligence and Research.” Id. at 11. Grafeld provides descriptions of these three additional searches, including the types of documents typically maintained by each office, the databases searched, and the search methods used. Id. at 11-13. The Grafeld declaration is insufficient, however, in that it does not address records maintained by the American Embassy in Beirut, Lebanon, a DOS overseas post likely to contain records responsive to El Badrawi’s request. DOS was on notice that the Embassy in Beirut is likely to contain responsive records for at least two reasons. First, on or about January 11, 2005, El Badrawi met with officials at the American Embassy in Beirut to discuss why his Hl-B Visa had been revoked. Badrawi Decl. ¶ 17. DOS was aware of this visit, and this visit likely resulted in the creation of records. Second, at least three documents generated by DOS in response to El Badrawi’s FOIA request contained telegrams or portions of telegrams from the Embassy in Beirut to DOS headquarters. Grafeld Decl. at 26, 28. These telegrams are not insubstantial — together they contain approximately seven pages of information withheld in full — and suggest that other records pertaining to El Ba-drawi may still be in Beirut. Given the likelihood that the Embassy in Beirut holds responsive records, any declaration that does not address that Embassy does not meet the requisite level of detail. DOS has not explained — by way of a relatively detailed affidavit — why its search is adequate without including the Embassy in Beirut. Because it lacks such an explanation, and it appears on the current record that the Embassy in Beirut should have been searched, DOS has not met its burden of proving that it conducted a reasonable search as a matter of law. Therefore, its Motion for Summary Judgment is denied as to the adequacy of its search and El Badrawi is permitted limited discovery on this issue. 3. FBI By letter dated October 19, 2006, El Badrawi submitted a request for: Access to and copies of any record held by the FBI mentioning or concerning [himself], including, but not limited to: 1) information contained in the National Crime Information Center (NCIC); 2) information relating to any investigation of a purported connection between [El Badrawi] and international terrorism; and 3) any other information provided to the [DOS] regarding [El Badrawi] prior to the revocation of his visa on October 2, 2003. Exhibit A to the Declaration of David M. Hardy (“Hard Decl.”). The FBI moves for summary judgment as to the adequacy of the search it undertook in response to this request. In support of its Motion for Summary Judgment (Doc. No. 25), the FBI submitted the declaration of David M. Hardy, Section Chief of the Record/Information Dissemination Section (“RIDS”), Records Management Division (“RMD”), at FBI headquarters (“FBIHQ”) in Washington, D.C. In his declaration, Hardy states that he supervises “approximately 208 employees who staff a total of ten FBIHQ units and a field operational service center unit whose collective mission is to effectively plan, develop, direct, and manage responses to requests for access to FBI records and information pursuant to [FOIA].... ” Hardy Decl. at 2. Hardy further states that “the statements contained in [his] declaration are based upon [his] personal knowledge, upon information provided to [him] in his official capacity, and upon conclusions and determinations reached and made in accordance therewith.” Id. He also notes that “due to the nature of [his] official duties, [he is] familiar with the procedures followed by the FBI in responding to requests for information from its files pursuant to the provisions of FOIA. Specifically, [he] is aware of the treatment of the FOIA request of [El Ba-drawi] for access to records pertaining to himself at FBIHQ.” Id. Regarding the FBI’s search in response to El Badrawi’s FOIA request, Hardy states that “the FBI has conducted a search reasonable [sic] designed to yield documents responsive to plaintiffs request directed to FBIHQ.” Id. at 9. Specifically, Hardy avers that, “by letter dated November 21, 2006, FBIHQ advised [El Badrawi] that a search of the automatic indices to the Central Records System (‘CRS’) at FBIHQ located no records responsive to his FOIA request....” Id. at 3. Hardy goes on to explain that: This ‘no records’ response to [El Ba-drawi] was given due to the fact that [he] did not specifically ask for a search of ‘cross-references’ in his initial October 19, 2006 request. In the absence of a specific request for a search of ‘cross-references’ at the initial administrative level, the FBI’s current policy is to search for and identify only ‘main’ files responsive to FOIA requests. The FBI identified no ‘main’ files responsive to [El Badrawi’s] request. Subsequent to the filing of the complaint [in the instant case], the FBI conducted a second search of FBIHQ for records responsive to [El Badrawi’s] request by searching the indices of the FBIHQ CRS for cross-references. Id. n. 3. Hardy then gives a detailed description of the CRS, the multiple interfaces used to access records in the CRS, and the terms used to search the CRS in response to El Badrawi’s FOIA request. Id. at 4-8. Hardy concludes his explanation of the search by noting that, “[although all files can be accessed through the CRS, each field office is responsible for maintaining its own files which are retrieved by a search in the CRS. FOIA requesters are required to submit their requests directly to the field office(s) they believe possess responsive records.” Id. at 9. The Hardy declaration is insufficient. It fails to meet the “relatively detailed and nonconclusory” standard because it does not justify searching only the CRS database. Specifically, Hardy’s statement that, “the FBI has conducted a search reasonable [sic] designed to yield documents responsive to plaintiffs request directed to FBIHQ” is conclusory. Id. at 9. The declaration offers no detail to support this statement, other than a mere description of the CRS database. Further, as discussed earlier, El Badrawi has identified — and the government has acknowledged — at least one responsive record located in another FBI database, the NCIC. See, supra, Part 11(B)(3) at 9. The FBI’s failure to give detailed justifications for not searching the NCIC, or any other databases it may own or have access to, falls below the standard for “relatively detailed and nonconclusory” affidavits required to legitimate a summary judgment ruling on the adequacy of an agency’s search. Consequently, FBI has not met its burden of proving that it conducted a reasonable search as a matter of law, and El Badrawi is permitted limited discovery on that issue. 4. ICE By letter dated October 19, 2006, El Badrawi submitted a request for: Access to and copies of any record held by ICE mentioning or concerning [himself], including, but not limited to: 1) Mr. El Badrawi’s investigations file; 2) records concerning his arrest on a warrant issued on October 28, 2004; 3) records concerning treatment and detention between his arrest and his hearing before an administrative law judge on November 10, 2004; 4) records concerning treatment and detention between the issuance of a notice of voluntary departure on November 20, 2004 and his removal from the United States; and 5) the prosecutor’s file used in any and all of his immigration proceedings, including removal and custody proceedings. Exhibit B to the Declaration of Gloria Marshall (“Marshall Deck”). ICE moves for summary judgment as to the adequacy of the search it undertook in response to this request. In support of its Motion for Summary Judgment (Doc. No. 39), ICE submitted the declaration of Gloria L. Marshall, Unit Chief of the Information Disclosure Unit (“IDU”), Mission Support Division, Office of Investigations (“OI”), GS-15, ICE within DHS. In her declaration, Marshall states that her official duties and responsibilities “include the general management, oversight, and supervision of the IDU, which includes the Freedom of Information Act/Privacy Act (“FOIA/PA”) Section.” Marshall Decl. at 2. She states that she is “familiar with [El Badrawi’s] request for information from ICE, pursuant to the FOIA,” and that “the statements contained in [her] declaration are based on [her] personal knowledge and experience, review of documents kept in the course of business, and information conveyed to [her] by other ICE employees in the course of [her] official duties.” Id. Regarding ICE’s search for documents responsive to El Badrawi’s request, Marshall declares that: The searches ICE conducted in this case were reasonably designed and conducted to uncover the records responsive to [El Badrawi’s] FOIA request. ICE personnel with knowledge of the investigation of [El Badrawi] and his subsequent detention and removal assisted in identifying relevant files. All files likely to contain responsive records were searched using methods which were reasonably expected to produce the information requested. Id. at 11. Marshall also provides a time line of events relating to ICE’s search, beginning with a FOIA request submitted to ICE by El Badrawi’s counsel as part of a separate matter, and ending with ICE’s February 13, 2008 second supplemental release of documents to El Badrawi. Id. at 4-11. This time line references two databases searched by ICE, TECS and NSEERS, and notes a series of other lines of inquiry undertaken by ICE, including a search for records related to El Badrawi’s ALR and a request for documents from the Hartford Correctional Center. Id. The Marshall declaration is insufficient on two grounds. It fails to meet the “relatively detailed and nonconclusory” standard because: 1) it does not “describe at least generally the structure of the agency’s file system” which renders any further search unlikely to disclose additional relevant information, Church of Scientology, 792 F.2d at 150; Katzman, 903 F.Supp. at 438; and 2) because it does not justify searching only the TECS and NSEERS databases. First, as discussed above, agency affidavits describing a search “must detail files searched and the general scheme of the agency file system.” Fisher v. FBI, 94 F.Supp.2d 213, 218 n. 2 (D.Conn.2000); see also Dinsio v. FBI, 445 F.Supp.2d 305, 312 (W.D.N.Y.2006); Rabin v. United States Dep’t of State, CIA, 980 F.Supp. 116, 120 (E.D.N.Y.1997). The Marshall declaration contains no description of ICE’s general filing scheme whatsoever, only a time line of events related to the processing of El Badrawi’s FOIA case. In fact, if a requester were to attempt to discern ICE’s record maintenance system by relying solely on the time line recounted in the Marshall declaration, the requester would have no choice but to conclude that ICE has no system. Clearly, El Badrawi has no basis upon which to dispute ICE’s assertion that any further search is unlikely to disclose additional relevant information. See Katzman, 903 F.Supp. at 438. This lack of disclosure impedes El Badrawi’s ability to advocate his position and falls well short of the “relatively detailed and nonconclusory” standard adopted by the Second Circuit. Grand Cent. P’ship., Inc., 166 F.3d at 489. Second, the Marshall declaration is insufficiently detailed because it fails to explain why, of all its potentially relevant databases, ICE chose to search only TECS and NSEERS. An “agency cannot limit its search to only one record system if there are others that are likely to turn up the information requested.” Oglesby, 920 F.2d at 68. The declaration offers only a cursory description of TECS, followed by a passing mention of NSEERS. Id. at 5-7. The declaration does not aver that these are the only ICE databases likely to contain responsive documents, nor does it offer any evidence that would justify such a conclusion. Moreover, El Badrawi has identified at least one other ICE database likely to have records mentioning El Ba-drawi. Specifically, the Deportable Alien Control System (“DACS”) is a DHS case management system that contains biographical and immigration court proceeding information, and is used to track an alien’s immigration case through the removal process. Plaintiffs Mem. in Opp. to ICE at 14. ICE has never described DACS in any of its submissions, nor has it justified its failure to search this database for responsive records. ICE’s failure to give detailed justifications for not searching the DACS database, and any other databases it may own or have access to, falls below the standard for relatively detailed and nonconclusory affidavits required to legitimate a summary judgment ruling. In sum, Marshall’s assurance that “all files likely to contain responsive records were searched using methods which were reasonably expected to produce the information requested” is conclusory and unsupported by the remainder of the declaration. ICE has not met its burden of proving that it conducted a reasonable search as a matter of law, and consequently its Motion for Summary Judgment is denied as to the adequacy of its search. El Badrawi is permitted limited discovery on the issue. 5. CIS In his October 19, 2006 FOIA request to CIS, El Badrawi sought: Access to and copies of any record held by [CIS] mentioning or concerning [himself] ... including but not limited to: 1) Mr. El Badrawi’s complete Alien File (“A-File”); 2) any and all files related to a petition for an Hl-B visa submitted on Mr. El Badrawi’s behalf, valid from 12/28/1999 to 10/01/2002 ...; 3) any and all files related to a petition for an Hl-B visa submitted on Mr. El Badrawi’s behalf, valid from 5/26/2003 to 5/1/2004 ...; 4) any and all files related to any other petition for an Hl-B visa submitted on Mr. El Badrawi’s behalf ...; 5) any and all files related to any application for an extension of Mr. El Ba-drawi’s Hl-B visa dated March 31, 2004 ...; 6) any and all files related to the revocation of Mr. El Badrawi’s visa on October 2, 2003; and 7) any information contained in the National Automated Immigration Lookout System. Exhibit A to the Declaration of Brian J. Welsh (“Welsh Deck”). CIS moves for summary judgment as to the adequacy of the search it undertook in response to this request. In support of its Motion for Summary Judgment (Doc. No. 57), CIS submitted the declaration of Brian J. Welsh, Assistant Center Director in the Freedom of Information and Privacy Acts (“FOIA/PA”) Unit, CIS National Records Center (“NRC”) in Lee’s Summit, Missouri. In his declaration, Welsh states that, “as a FOIA Officer for the NRC since 2006, [he has] supervised the performance of over 100 access professionals in the processing of more than 100,000 FOIA/PA requests received by the USCIS on average annually.” Welsh Decl. at 2. In his official capacity as Assistant Center Director, inter alia, Welsh supervises the personnel “responsible for the orderly processing of all public, congressional, judicial, and inter-/intra-agency requests or demands for access to USCIS records and information pursuant to the FOIA ...” Id. Welsh further states that he is “familiar with [El Badrawi’s] current civil action under the FOIA and all events leading to the same.” Id. Welsh makes the statements in his declaration “based upon [his] personal knowledge, upon information made available to [him] in [his] official capacity, and upon conclusions and determinations reached in accordance therewith.” Id. With regard to the CIS search itself, Welsh states that “[b]ased upon plaintiffs name, alien number, and description of requested records, on October 27, 2006, the NRC conducted a general search for responsive records in the agency’s system of records referred to as Alien File/Central Index System (‘A-File/CIS’)....” Id. at 4. According to the Welsh declaration, “the A-file/CIS is a centralized and consolidated electronic system of records through which A-files are stored, maintained, updated, tracked, and received.” Id. at 2 n. 2. Moreover, “all official records generated or held by U.S. immigration authorities pertaining to INA transactions involving [El Badrawi] should, as a matter of course, be consolidated in an A-file maintained under, and retrievable by reference to, [El Badrawi’s] name, alien registration number, and date of birth, or a combination thereof.” Id. Welsh also gives a brief description of the Computer Linked Application Information Management System (“CLAIMS”), a CIS database that assigns unique receipt numbers to documents filed with CIS. Id. at 5 n. 3. These receipt files are often incorporated into the filer’s A-file. Id. In response to El Badrawi’s FOIA request, CIS “expected to find at least four separate receipt files incorporated into [his] A-file by virtue of his initiation of certain immigration transactions, as described in his initial FOIA request letter, as well as due to certain notations found in [his] A-file.” Id. CIS located three receipt files, but despite “conducting a diligent search to locate” the fourth file, to date CIS has not found it. Id. at 5. The Welsh declaration is insufficient on two grounds. It fails to meet the “relatively detailed and nonconclusory” standard because: 1) it does not “describe at least generally the structure of the agency’s file system” which renders any further search unlikely to disclose additional relevant information, Church of Scientology, 792 F.2d at 150; Katzman, 903 F.Supp. at 438; and 2) because it does not justify searching only the A-file/CIS and CLAIMS databases. As previously noted, agency affidavits describing a search “must detail files searched and the general scheme of the agency file system.” Fisher v. FBI, 94 F.Supp.2d 213, 218 n. 2 (D.Conn.2000); see also Dinsio v. FBI, 445 F.Supp.2d 305, 312 (W.D.N.Y.2006); Rabin v. United States Dep’t of State, CIA, 980 F.Supp. 116, 120 (E.D.N.Y.1997). The Welsh declaration lacks such detail. That is, while Welsh provides a cursory description of the path an application/petition takes through the CLAIMS and A-file/CIS databases, he does not declare — nor does he suggest— that these are the only two databases owned by CIS. See id. at 4-5. Welsh’s statement that “all official records generated or held by [CIS] ... involving [El Badrawi] should, as a matter of course, be consolidated in an A-file,” is simply not enough detail. It is impossible to conclude, based on this statement, that no CIS database save A-file/CIS or CLAIMS contains records responsive to El Badrawi’s request. In other words, El Badrawi has no basis upon which to dispute CIS’s assertion that any further search is unlikely to disclose additional relevant information. See Katzman, 903 F.Supp. at 438. As a result, neither El Badrawi nor this court can fairly assess the adequacy of the CIS search. Second, the Welsh declaration fails because it does not explain why, of all its potentially relevant databases, CIS chose to search only A-file/CIS and CLAIMS. As previously discussed, an “agency cannot limit its search to only one record system if there are others that are likely to turn up the information requested.” Oglesby, 920 F.2d at 68. The Welsh declaration offers an extremely brief survey of A-file/CIS, and devotes only one sentence to CLAIMS. Id. at 5-7. More importantly, the declaration does not aver that these are the only CIS databases likely to contain responsive documents, nor does it offer any evidence that would justify such 'a conclusion. Quite the contrary, Welsh notes that, in fact, “for a myriad of reasons, not all adjudicated receipts will be incorporated into A-files.” Id. at 5 n. 5. CIS’s inability to locate the fourth receipt file relating to El Badrawi is further evidence that not all responsive documents are contained in the A-file/CIS or CLAIMS databases, casting further doubt on the Welsh declaration’s conclusory assertion that “all official records [pertaining to El Badrawi] should ... be consolidated in an A-file.” See id. at 4-5. For these reasons, CIS has not met its burden of proving that it conducted a reasonable search as a matter of law, and therefore is not entitled to summary judgment on the adequacy of its search. El Badrawi is permitted limited discovery on the issue. B. Reasonableness of Referrals to Originating Agencies The agencies have, as discussed above, referred certain documents to one another for review and direct response to El Ba-drawi. See, supra, Part 11(B) at 6-8, 11-12. In each case of referral, the referring agency determined that the record was responsive, but that the information contained in the record originated with another agency. See, e.g., ICE Mem. at 15-16. Referred documents have essentially been treated by the originating agencies in much the same way as that agency’s other records: some were released in full, some were released in part, and some were withheld. See, supra, Part 11(B) at 6-7, 11-12. The defendants have moved for summary judgment as to the reasonableness of these referrals; When an agency receives a FOIA request for documents in its possession, it “cannot simply refuse to act on the ground that the documents originated elsewhere.” McGehee v. C.I.A., 697 F.2d 1095, 1110 (D.C.Cir.1983). An agency may, however, adopt procedures by which documents in the agency’s possession, but which originated with another agency, may be referred to the originating agency for review and direct response to the requester. See id. The legal status of such procedures is “best determined on the basis of their consequences.” Id. In other words, “a system adopted by an agency for dealing with documents of a particular kind constitutes ‘withholding’ of those documents if its net effect is significantly to impair the requester’s ability to obtain the records or significantly to increase the amount of time he must wait to obtain them.” Id. There is no indication that the defendants’ referral of documents to the documents’ originating agencies “impaired [El Badrawi’s]' ability to obtain the records” or “significantly increased the amount of time” he waited to obtain them. Id. Aside from the unavoidable delay presumably caused by transferring records from one agency to another, there is no indication that referral itself has prejudiced El Badrawi. In other words, to the extent El Badrawi claims his ability to obtain the referred records has been impaired, his claim is based on the insufficiency of the originating agencies’ Vaughn affidavits and their improper invocation of FOIA’s statutory exemptions. He has not alleged that the referrals per se constitute an improper withholding, nor has he offered any evidence that would suggest as much. In fact, it appears that El Badrawi does not contest the reasonableness of the defendants’ referrals at all. Consequently, the defendants are granted summary judgment as to the propriety and reasonableness of their referrals of certain records to the records’ originating agencies. C. Exemptions The defendants have moved for summary judgment on the propriety of their withholdings under a number of the nine statutory exemptions to FOIA’s general rule of disclosure. See 5 U.S.C. § 552(b). The disposition of these Motions necessarily involves two questions: 1) have the agencies provided sufficient detail and explanation for their withholdings so that the plaintiff and the court can evaluate the propriety of the application of the exemptions invoked?; and if so, 2) have the agencies properly applied the exemptions in question? During the course of ordinary litigation, “the facts relevant to a dispute are more or less equally available to adverse parties.” Vaughn v. Rosen, 484 F.2d 820 (D.C.Cir.1973). “In a case arising under the FOIA,” however, “this is not true ... and hence the typical process of dispute resolution is impossible.” Id. Consequently, “affidavits submitted by a governmental agency in justification for its exemption claims must therefore strive to correct, however, imperfectly, the asymmetrical distribution of knowledge that characterizes FOIA litigation.” King v. United States Dep’t of Justice, 830 F.2d 210, 218 (D.C.Cir.1987). “[W]hen an agency seeks to withhold information, it must provide a relatively detailed justification, specifically identifying the reasons why a particular exemption is relevant and correlating those claims with the particular part of a withheld document to which they apply.” Morley v. CIA, 508 F.3d 1108, 1122 (D.C.Cir.2007) (internal quotations omitted). This justification typically takes the form of a Vaughn index, named for the case that introduced it. See Vaughn, 484 F.2d at 820 (“an agency’s response to a FOIA request must include an index of all material withheld in whole or in part”). “The Vaughn index must explain specifically which of the