[Exhibit 83] PLAINTIFF'S BRIEF IN BALDWIN V. FINNEY UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT Nos. 76-1186, 77-1237 ROY BALDWIN, et al., Plaintiffs-Appellants, JERVIS FINNEY, et al., Defendants-Appellees. No. 76-1182 ROY BALDWIN, et al., Plaintiffs-Appellees, V. JERVIS FINNEY, et al., Defendants-Appellants. On Appeal from the United States District Court The undersigned, counsel of record for plaintiffsappellants/cross-appellees, certifies that the following listed parties appeared below: Roy Baldwin Bruce Feder (Appellants in Nos. 76-1186 and 77-1237, and Jervis Finney, U.S. Attorney for the District Edward Levi, Attorney General of the United Department of Justice (Appellees in Nos. 76-1186 and 77-1237, and Appellants in No. 76-1182) These representations are made in order that the Judges of this Pursuant to Rule 25(d), Fed. R. Civ. P., Attorney General Griffin Bell is automatically substituted herein as a party defendant. or recusal. -2 Miane B. Cohn Diane B. Cohn Attorney of Record for Plaintiffs- Suite 700 2000 P Street, N.W. Washington, D.C. 20036 TABLE OF CONTENTS I. THE DISTRICT COURT'S HOLDING, WHICH AFFORDS BLANKET PROTECTION TO ALL RECORDS WHICH ARE ALLEGEDLY PART OF AN "OPEN" INVESTIGATORY FILE, Neither The Government Nor The District Court Has Provided A Sufficiently De- tailed Identification Of The Nature of The Requested Records Or Explanation Of The District Court Committed Irreparable Error By Engaging In Contacts With De- fendants, Ex Parte, And Outside The Record, i |