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https://www.law.cornell.edu/supct/cases/421us132.htm

…and also referred to 'the circumstances of the case" which were not set out and about which Sears was ignorant. The General Counsel contended that all of the documents were exempt from disclosure as 'intra-agency' memoranda within the coverage of 5 U.S.C. § 552(b)(5) ; and that t…