Case 1:10-cv-01165-HHK Document 12 Filed 01/21/11 Page 1 of 15

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
____________________________________
)
)
VERN McKINLEY, )
)
Plaintiff. )
)
) Case No: 10-CV-01165
v. ) Judge Henry H. Kennedy, Jr.
)
)
FEDERAL HOUSING FINANCE )
AGENCY, )
)
Defendant. )
)
____________________________________)

REPLY IN SUPPORT OF DEFENDANT’S SUMMARY JUDGMENT MOTION

AND IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT

TONY WEST
Assistant Attorney General

RONALD C. MACHEN, JR.

United States Attorney, District of Columbia

JOHN TYLER
Assistant Branch Director, Federal Programs
Branch

BRADLEY H. COHEN
Trial Attorney, Department of Justice, Civil
Division, Federal Programs Branch
Post Office Box 883
Washington, D.C. 20044
Tel: (202) 305-9855
Fax: (202) 616-8470
[email protected]

Attorneys for Defendant Federal Housing

Finance Agency
 Case 1:10-cv-01165-HHK Document 12 Filed 01/21/11 Page 2 of 15

PRELIMINARY STATEMENT

In this Freedom of Information Act case, Plaintiff Vern McKinley seeks documents

related to the September 7, 2008 announcement by the Federal Housing Finance Agency

(“FHFA”) and the U.S. Department of the Treasury that FHFA would place the Federal National

Mortgage Association (“Fannie Mae”) and the Federal National Home Loan Mortgage

Corporation (“Freddie Mac”) into conservatorship. FHFA found three documents responsive to

Plaintiff’s request in its Office of General Counsel and withheld all three in their entirety

pursuant to Exemption 5.

Plaintiff does not challenge the adequacy of the search and agrees that Document 1 is

protected by the attorney-client privilege, but challenges whether the attorney work product

doctrine and deliberative process privilege apply to Documents 2 and 3. These two documents

were created in the period preceding the FHFA’s September 7, 2008 decision. Both address the

possible implementation of a conservatorship or receivership and also various legal steps that

FHFA might be required to undertake as a result of its ultimate policy decision.

After conceding that Documents Numbers 2 and 3 were prepared when reasonably

anticipated legal challenges existed, and that parts of Document Number 2 address this

anticipated litigation, Plaintiff makes two arguments. Plaintiff first claims that these two

documents primarily focus on implementation of the policy of conservatorship or receivership

rather than potential litigation, so that the attorney work product doctrine should not apply.

Second, Plaintiff claims that, even if the attorney work product doctrine applies in part, the Court

should require Defendant to withhold only those portions of the responsive records that fall

within the doctrine.

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This Court should reject both lines of argument. First, the existence of multiple purposes

behind the two documents, including the policy question from which the litigation purpose

arises, does not defeat the attorney work product claim. The party claiming protection of the

work product doctrine need not show that a document was used “primarily to assist in” litigation;

rather, the agency need only establish that the document was prepared or obtained “because of”

the prospect of litigation. The Vaughn index and Pollard Declaration clearly describe the legal

actions (both defensive and affirmative) that were anticipated and the sections of the document

that address these anticipated legal steps. Moreover, if a document is prepared “because of”

reasonably anticipated litigation, any portion of the document, not just the portion concerning

opinions, legal theories, and the like is exempt from disclosure under Exemption 5. Hence,

FHFA properly withheld both documents in whole.

In addition, Plaintiff argues that FHFA has a burden to show that there will be harm to

the decision-making process in order to establish that the documents are protected by the

deliberative process privilege. This argument is simply wrong, as the only requirement for

establishing the application of the deliberative process privilege is to demonstrate that the

document(s) were both predecisional and deliberative. Moreover, Plaintiff is well aware that

there is no additional showing required, given that Plaintiff unsuccessfully made this same

argument before this Court in other litigation, where it was rejected as a mischaracterization of

controlling D.C. Circuit authority. See McKinley v. FDIC, No. 09-1263, 2010 WL 3833667, at

*9-10 (D.D.C. Sept. 29, 2010) (agency need only establish that withheld documents were

predecisional and deliberative, not that disclosure would cause harm to the decision-making

process). Notwithstanding Plaintiff’s misstatement of the law, FHFA’s Vaughn index and

affidavits overwhelmingly support its assertion that the documents are predecisional and

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deliberative. Lastly, because all of Plaintiff’s arguments can easily be addressed based on the

affidavits, the Court need not conduct an in camera review and should grant summary judgment

in favor of FHFA.

ARGUMENT

I. FHFA’S EXEMPTION 5 ASSERTIONS ARE PROPER

A. Documents 2 and 3 Were Both Prepared Because of Anticipated Legal

Challenges to FHFA’s Contemplated Decision

Plaintiff concedes that Documents 2 and 3 were “prepared at a time when the possibility

of legal challenges by the Board of Directors and management of Fannie Mae and Freddie Mac

existed.” Pl. Br. at 6. Plaintiff also “does not contest” that discussion in Document 2 of what

FHFA “could expect in terms of judicial review of a legal challenge” is exempt from disclosure

pursuant to the attorney work product doctrine. Id.

Plaintiff has thus admitted that litigation was reasonably foreseeable and that at least

portions of the documents implicate the work product doctrine. Plaintiff’s main complaint is that

these two documents, as described in the Vaughn index, “primarily focus” on the policy of

conservatorship over receivership, rather than its “litigation implications,” and thus, in Plaintiff’s

view, they should not fall within the protection of the attorney work product doctrine. Pl. Br. at

7. In addition, to the extent the work product doctrine applies, Plaintiff asks that only “limited

portion[s]” of the documents be withheld. Id. at 6.

There are several problems with Plaintiff’s argument. First, the dual purposes underlying

the documents (policy advice and preparation for litigation) are neither contradictory nor

mutually exclusive. Moreover, the existence of the policy rationale serves as the basis for the

litigation preparation and thus does not undermine the attorney work product claim. See

Delaney, Migdail & Young Chartered v. IRS, 826 F.2d 124, 126-27 (D.C. Cir. 1987) (work

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product claim sustained where documents in question had the policy-making purpose of helping

the IRS decide whether to adopt a proposed system of statistical sampling for its corporate audit

program, but also had a litigation purpose of addressing expected litigation that would result

from adoption of the program). In addition, the D.C. Circuit does not require that the document

be used “primarily to assist in” litigation, see, e.g., United States v. El Paso Co., 682 F.2d 530,

543 (5th Cir. 1984), but rather simply that the document must have been prepared “because of”

reasonably foreseeable litigation. See Senate of Puerto Rico v. U.S. Dep’t of Justice, 823 F.2d

574, 587 n. 42 (D.C. Cir. 1987) (attorney work product doctrine applies if “the document can

fairly be said to have been prepared or obtained because of the prospect of litigation.”)

(emphasis added); United States v. Adlman, 134 F.3d 1194, 1198-1202 (2d Cir. 1998)

(explaining that the “primarily to assist in” litigation test has been rejected in many Circuits,

including the D.C. Circuit in Delaney).

Thus, “the ‘testing question’ for the work product privilege ... is whether in light of the

nature of the document and the factual situation in the particular case, the document can fairly be

said to have been prepared or obtained because of the prospect of litigation.” In re Sealed Case,

146 F.3d 881, 884 (D.C. Cir. 1998). To meet this standard, a party “must at least have had a

subjective belief that litigation was a real possibility, and that belief must have been objectively

reasonable” in the circumstances. Id.

Applying this test to the contents of the documents as reflected in the Vaughn index and

Declarations, the two withheld documents were drafted by attorneys in the Office of General

Counsel based on a pressing concern that some sort of legal action (either affirmative or

defensive) would have to be taken in response to FHFA’s decision. In the absence of this

specific concern about reasonably anticipated litigation, legal counsel would not have been asked

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to prepare a chart and memorandum analyzing the effects of the contemplated decision. See,

e.g., Equal Rights Ctr. v. Post Properties, Inc., 247 F.R.D. 208, 210-11 (D.D.C. 2008)

(application of “because of” litigation test involves analyzing whether the document in question

would have been prepared irrespective of the anticipated litigation). As explained by FHFA’s

General Counsel, both documents were created for meetings with senior executives, who were

seeking advice regarding the litigation consequences of whichever policy they chose:

All three documents were prepared because of anticipated legal challenges to

FHFA’s contemplated decision. Specifically, FHFA was aware that the Board of
Directors and management of the Enterprises had a statutory right to bring a legal
challenge of a conservatorship. The Board and management could have
challenged FHFA’s cease and desist order through administrative litigation. If
FHFA instituted a conservatorship or receivership, the Board and management
could have challenged the conservatorship in federal court, arguing either that
FHFA failed to comply with its authorizing statute or violated the Constitution.

Pollard Decl., ¶ 14. Thus, although portions of these documents are focused on assisting

policymakers in their policy decision-making process, the documents themselves were prepared

due to reasonably anticipated litigation resulting from any of the contemplated courses of action.

Hence, the attorney work product doctrine applies to both documents.

Second, Plaintiff’s assertion that parts of the documents (all of which clearly reflect

predecisional deliberations1) should be disclosed ignores explicit case law on the scope of

attorney work product protection. Attorney work product protection extends to the entire

document identified as attorney work product, including factual material appearing within the
1
As discussed in Defendant’s opening brief, should the Court determine that the attorney
work product doctrine does not apply to one or both of these documents, FHFA reserves the right
to undertake such a review to determine whether withheld factual material would reveal FHFA’s
deliberative process. See, e.g., Horowitz v. Peace Corps, 428 F.3d 271, 277 (D.C. Cir. 2005)
(protecting requested document where decisionmaker’s “thought processes are woven into
document to such an extent” that any attempt at segregating out information would reveal agency
deliberations); Rein v. U.S. Patent & Trademark Office, 553 F.3d 353, 375 (4th Cir. 2009)
(protecting factual portions of document because such information, when viewed as part of a
larger document “would reveal the very predecisional and deliberative material Exemption 5
protects.”).

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document, and thus, segregability is not required. See Judicial Watch, Inc. v. Dep’t of Justice,

432 F.3d 366, 371 (D.C. Cir. 2005); see also Martin v. Office of Special Counsel, 819 F.2d 1181,

1185-86 (D.C. Cir. 1987) (unlike the deliberative process privilege, the work product protection

encompasses factual materials that are contained in an otherwise privileged document).

Although Document 2 contains sections which analyze “the features, strengths, and

weaknesses of two alternate approaches of issuing a consent order or instituting a

conservatorship,” see Wright Decl., Attachment A, the author’s role was to inform the decision-

maker not just of the merits of respective policy positions, but also of the potential for judicial

review and what options FHFA might have in court. Id. The attorney’s thoughts and mental

impressions about the rationale behind FHFA’s policy decision and its effect on anticipated

litigation (including the assembling of relevant facts) would be compromised by revealing the

document as a whole. Hence, the D.C. Circuit has explicitly advised that “factual material is

itself privileged when it appears within documents that are attorney work product.” Judicial

Watch, 432 F.3d at 371. The attorney work product is thus designed to protect “[a]ny part of [a

document] prepared in anticipation of litigation, not just the portions concerning opinions, legal

theories, and the like ….” McKinley v. FDIC, 2010 WL 3833667 at *10 (internal quotation and

citation omitted).

Likewise, Document 3 contains discussion of affirmative litigation by FHFA, namely

“the ability of FHFA to seek a cease and desist order to effect changes in the Enterprises.”

Wright Decl., ¶ 17. While Plaintiff points to portions of Document 3 that discuss the

ramifications of choosing conservatorship or receivership and the factors that would support

either choice, Plaintiff neglects to mention that a portion of the document addresses the

alternatives to conservatorship or receivership, namely the “possibility of an informal order or

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cease and desist order.” See Wright Decl., Attachment A. The fact that these contemplated legal

steps were not ultimately undertaken does not remove the protection of the attorney work

product doctrine. See FTC v. Grolier, Inc., 462 U.S. 19, 28 (1983) (“[W]e hold that under

Exemption 5, attorney work-product is exempt from mandatory disclosure without regard to the

status of the litigation for which it was prepared.”).

As long as the document as a whole was prepared because of litigation, sections of the

document do not cease being exempt because they do not explicitly discuss the formulation of

legal arguments. See, e.g., Hanson v. U.S. Agency for Int’l Development, 372 F.3d 286, 293 (4th

Cir. 2004) (describing the attorney’s role as not just formulating legal arguments, but as

“analyzing the causes of project delays, [and] recommend[ing] an appropriate settlement

amount.”). In Hanson, the Fourth Circuit addressed the intersection between attorney work

product and deliberative process. In that case, the author of the withheld document was advising

the agency about a construction dispute regarding a USAID-funded project in Egypt. Id. at 289.

In doing so, he sought to both inform the agency’s policy deliberations over whether to approve

material changes to its development project and bolster its legal defense in resolving a

construction dispute on favorable terms. Id. at 289, 292. The court pointed out that the

document involved the “direct application of his legal skills” and the attorney had to “sift

through the facts with an eye to the legally relevant.” Id. at 293. Specifically, the author had to

“monitor[] settlement negotiations, exercise[] legal judgment in assessing the positions of the

parties, recommend[] a settlement amount for the dispute, and advise[] USAID on how it should

change the dynamics of the negotiation process.” Id. Likewise, in this case, the attorney

author(s) were required to advise FHFA about the strengths and weaknesses of instituting a

conservatorship, but also to exercise legal judgment regarding how this decision would

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ultimately be challenged, either through administrative litigation or litigation in federal court.

Moreover, if FHFA undertook an alternative to conservatorship, it needed to be prepared for

other types of legal action (e.g., issuing an informal order or cease and desist order). Because

both documents were obtained or prepared as a result of this reasonably anticipated litigation,

FHFA properly declined to produce this material as attorney work product.

B. FHFA is Not Required to Show “Harm” to the Decision-Making Process

Plaintiff’s second argument is that FHFA is required to show that the material withheld

pursuant to the deliberative process privilege would actually harm the agency’s decision-making

process if it were disclosed to the public. See Pl. Br. at 10-11. This is simply a misstatement of

relevant D.C. Circuit authority.

Curiously, Plaintiff neglects to mention that this very same argument raised by him in

another case was explicitly rejected by this Court. See McKinley v. FDIC, 2010 WL 3833667, at

*10 (“Having established that the withheld documents were both ‘predecisional’ and

‘deliberative,’ defendant is not also required to establish that the release of the withheld

documents or material would cause ‘harm’ to the decision-making process.”). In McKinley,

Plaintiff argued that the following statement from Mead Data Ctr. v. U.S. Dep’t of the Air Force

required a showing of harm: “An agency cannot meet its statutory burden of justification by

conclusory allegations of possible harm. It must show by specific and detailed proof that

disclosure would defeat, rather than further, the purpose of FOIA.” 566 F.2d 242, 258 (D.C. Cir.

1977). Judge Huvelle explained that this statement from Mead was taken out of context because

the court was referring in passing to the agency’s negotiation proceedings with an outside party,

i.e., to material that was indisputably not part of the agency’s internal deliberative process. 2010

WL 3833667 at *9 (citing Mead, 566 F.2d at 257-258). The Mead Court’s legal analysis of

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which material fell within the deliberative process privilege under Exemption 5 still relied upon

whether the documents were both “predecisional” and “part of the deliberative process.” Id.

(citing Mead, 566 F.2d at 257-258). Thus, Judge Huvelle reiterated that no showing of harm to

the decision-making process is legally required. Id.2

Notwithstanding this Court’s rejection of this argument, Plaintiff again takes out of

context quotes from various D.C. Circuit cases in an attempt to craft a new legal standard that

contravenes controlling precedent. It should be roundly rejected. Plaintiff’s inference from

these cases that an agency must show harm to its decision-making process in order to sustain a

claim of deliberative process privilege is simply wrong. Plaintiff points to Formaldehyde

Institute v. Dep’t of Health and Human Services and the Court of Appeal’s acknowledgment that

the factual record in that case established that disclosure of reviewers’ comments would

seriously harm the deliberative process. 889 F.2d 1118, 1124 (D.C. Cir. 1989). But nowhere

does the Court of Appeals state that an agency is required to show such harm to establish the

privilege. Instead, the Court held: “[w]e find that the Review Letter was both ‘predecisional’

and a part of the agency’s ‘deliberative process.” Therefore, we hold that, pursuant to Exemption

5, HHS may withhold the Review Letter from disclosure under FOIA.” Id. at 1125 (emphasis

added). Likewise, Plaintiff points to government witness testimony in Horowitz v. Peace Corps.,

428 F.3d 271, 276-77 (D.C. Cir. 2005), that in the witness’s “opinion,” disclosing deliberative

materials would discourage officials from creating these documents, see Pl. Br. at 11. Plaintiff

infers from this statement that the Court of Appeals was somehow announcing a new legal

requirement. However, the Court’s holding was as follows:

2
Plaintiff has appealed this decision, which is currently pending before the D.C. Circuit
Court of Appeals. See McKinley v. FDIC, No. 09-1263, 2010 WL 3833667 (D.D.C. Sept. 29,
2010), appeal docketed, No. 10-5353 (D.C. Cir. Oct. 22, 2010).

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After evaluating the witnesses' testimony and credibility, the district court
concluded Giron had not made a final decision about separating Horowitz. The
document was prepared as an aid for Giron's decision-making process and for
consultation with other Peace Corps officials. Hence, the document qualified as
deliberative and predecisional.

Id. at 277 (emphasis added). Thus, as this Court is well aware, to come within the deliberative

process privilege under Exemption 5, FHFA need only show that the withheld material was

“predecisional” and “deliberative.” Public Citizen, Inc. v. Office of Management and Budget,

598 F.3d 865, 874 (D.C. Cir. 2010). This standard is easily met here.

Both documents challenged by Plaintiff are “predecisional” (i.e., they were created prior

to FHFA’s September 6, 2008 decision to place Fannie Mae and Freddie Mac into

conservatorship). See Pollard Decl., ¶¶ 12, 13. Moreover, both specifically are labeled as

“drafts” and no final version of either of the documents has been located, id., leaving open the

possibility of later modification and refinement of policy. See, e.g., Pub. Employees for Envt’l

Responsibility v. Bloch, 532 F. Supp. 2d 19, 22 (D.D.C. 2008) (holding that “draft texts [of

position statements] considered along the way” fall within Exemption 5). The Office of General

Counsel created these documents, rather than the FHFA Director, who, by statute, has the actual

legal authority to institute the conservatorship. See 12 U.S.C. § 4617(a). If the author lacks

“legal decision authority,” the document should be considered predecisional. Pfeiffer v. CIA, 721

F. Supp. 337, 339 (D.D.C. 1989) (finding document “predecisional” where author lacked

authority “to speak finally and officially for the agency”); Tax Analysts v. IRS, 152 F. Supp. 2d 1,

24-25 (D.D.C. 2001) (protecting memoranda “written by a component office without

decisionmaking authority to a different component office” that had such authority), aff’d in part,

rev’d in part on other grounds and remanded, 294 F.3d 71 (D.C. Cir. 2002).

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These documents also reflect communications that are “deliberative” in that they involve

counsel describing a host of legal and policy options to address the deteriorating condition of

Fannie Mae and Freddie Mac. See Wright Decl., ¶ 15 (describing the various policy options

being considered by FHFA); Pollard Decl., ¶¶ 12-13 (explaining with whom the documents were

shared). These documents were not shared with anyone outside of FHFA and FHFA’s outside

counsel. Wright Decl., ¶ 15. Rather, they were used to discuss the strengths and weaknesses of

the various courses of agency action, including the potential effects of instituting a

conservatorship or receivership and/or challenges of issuing a consent order or cease and desist

order. Id., ¶ 17. Documents 2 and 3 were created for meetings with senior executives at FHFA

to discuss various policy options that the agency could take with regard to the Enterprises and

were provided to these senior policymakers in order to assist their decision-making. Pollard

Decl., ¶¶ 12, 13. These are precisely the sort of deliberations meant to be protected by the

privilege. See Mead, 566 F.2d at 257 (“Discussions among agency personnel about the relative

merits of various positions which might be adopted ... are as much a part of the deliberative

process as the actual recommendations and advice which are agreed upon.”); Lewis-Bey v. DOJ,

595 F. Supp. 2d 120, 133 (D.D.C. 2009) (material considered “deliberative” where it reflects

“candid discussions of the strengths and weaknesses” of the agency’s case and disclosure “would

have the effect of inhibiting the free flow of recommendations and opinions.”).

These combined features indicate that the documents in question were “prepared in order

to assist an agency decisionmaker in arriving at his decision.” Renegotiation Bd. v. Grumman

Aircraft Eng’g Corp., 421 U.S. 168, 184 (1975). Accordingly, FHFA properly withheld these

documents under Exemption 5.

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C. In Camera Review of the Documents is Not Necessary in this Case

A district court should only conduct in camera review of documents withheld under a

FOIA exemption under two circumstances. First, if the affidavits submitted by the parties are

conclusory, or if they do not describe the documents in sufficient detail so as to determine

whether the claimed exemption applies, then the court may conduct in camera review. See

Carter v. U.S. Dep’t of Commerce, 830 F.2d 388, 392 (D.C. Cir. 1987). Second, if there is

evidence of agency bad faith, then in camera inspection may be required. However, there “must

be tangible evidence of bad faith,” for without such evidence, “the court should not question the

veracity of agency submissions.” Id. at 393.

Plaintiff makes no claim of agency bad faith. Plaintiff has been able to sufficiently test

FHFA’s claim of attorney work product and deliberative process privilege by describing in detail

the contents of both Documents 2 and 3 and the agency’s justification for each withholding,

based on the affidavits submitted by the agency. See, e.g., Pl. Br. at 7-8. Based on the detailed

affidavits, see Wright Decl., ¶¶ 17-18, Attachment A, and Pollard Decl., ¶¶ 12-14, this Court

may easily conclude that these affidavits “sufficiently describe the documents and set forth

proper reasons for invoking an exemption,” so that in camera inspection of those documents is

unnecessary. Juarez v. U.S. Dep’t of Justice, 518 F.3d 54, 60 (D.C. Cir. 2008). The Court

should thus act within its “broad discretion by declining to conduct such a review.” Id. (internal

quotation and citation omitted).

CONCLUSION

For the foregoing reasons, this Court should grant FHFA’s motion for summary

judgment.

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Dated: January 21, 2011 TONY WEST

Assistant Attorney General

RONALD C. MACHEN, JR.

United States Attorney, District of Columbia

JOHN R. TYLER
Assistant Director,
Federal Programs Branch

s/ Bradley H. Cohen

BRADLEY H. COHEN (DC Bar No. 495145)

Trial Attorney
Federal Programs Branch
U.S. Department of Justice, Civil Division
Telephone: (202) 305-9855
Fax: (202) 318-0486
Email: [email protected]

Mailing Address:
Post Office Box 883
Washington, D.C. 20044

Courier Address:
20 Massachusetts Ave, N.W.
Washington, D.C. 20001

ATTORNEYS FOR DEFENDANT

FEDERAL HOUSING FINANCE AGENCY

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CERTIFICATE OF SERVICE

I hereby certify that on January 21, 2011, a copy of the foregoing pleading was filed

electronically via the Court’s ECF system, which sent notification of such filing to counsel of record.

s/ Bradley H. Cohen
BRADLEY H. COHEN
Trial Attorney
Federal Programs Branch
U.S. Department of Justice, Civil Division
Telephone: (202) 305-9855
Fax: (202) 318-0486
Email: [email protected]

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