Moye, O'Brien, O'Rourke, Hogan, & Pickert v. National Railroad Passenger Corp.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that audit workpapers that “document the entire body of collaborative work performed by the auditors” in the process of performing the audit are deliberative
• concluding audit workpapers and internal memo-randa were predecisional because they predated and contributed to the final audit report
• explaining that the purpose of Exemption 5’s “deliberative process privilege” is to “allow agencies to freely explore possibilities, engage in internal debates, or play devil’s advocate without fear of public scrutiny” (citation omitted)
• explaining that “materials embodying officials’ opinions are ordinarily exempt from disclosure”
• Amtrak OIG “audit work papers and internal memoranda” that “lower level staff” played a “significant role” in authoring were deliberative
• court holds agency’s audit reports, internal memoranda, notes and work papers were protected under deliberative process privilege

Source: CourtListener parenthetical corpus (CC0).