TABLE OF CONTENTS

TABLE OF AUTHORITIES

BRIEF FOR THE PLAINTIFFS-APPELLANTS/CROSS-APPELLEES

QUESTIONS PRESENTED

STATUTE INVOLVED

REFERENCES TO PARTIES AND RULINGS

STATEMENT OF THE CASE

SUMMARY OF ARGUMENT

ARGUMENT

I. THE DISTRICT COURT'S HOLDING, WHICH AFFORDS

BLANKET PROTECTION TO ALL RECORDS WHICH ARE

ALLEGEDLY PART OF AN "OPEN" INVESTIGATORY FILE,

IS CONTRARY TO BOTH THE LANGUAGE AND INTENT OF

EXEMPTION 7(A)

II. THE DISTRICT COURT ERRED IN FAILING TO FOLLOW

THE PROCEDURES MANDATED BY THIS COURT FOR

FOIA CASES

$552(a)(4) (B)

$552(b) (7) (A)

$552(b) (7) (B)

$552(b) (7) (C)

Legislative History

Hearings before the Subcommittees on Adminis-
trative Practice and Procedure and Separa-
tion of Powers of the Committee on the
Judiciary, United States Senate, and
the Subcommittee on Intergovernmental
Relations of the Committee on Government
Operations, 93d Cong., 1st Sess. (Vol.
II) 227 (1973)

H. Doc. 93-383, 93d Cong., 2d Sess. 1 (1974)

Congressional Record:

120 Cong. Rec. S 9315 (daily ed. May 30,
1974)

120 Cong. Rec. S 9329-30 (daily ed. May
30, 1974)

120 Cong. Rec. S 9331 (daily ed. May 30,
1974)

20

Commission on Federal Paperwork (Confidentiality
and Privacy Study), A Report on Government
Secrecy and Its Relation to Paperwork and
Information Policy (March 1, 1977)

*Authorities principally relied upon.

21-656 0-78-46

30, 31