Kean v. NASA, 1:03-cv-02509

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Plaintiff argues that the overly broad scope of NASA’s search
demonstrates that it was random or haphazard and not reasonably
calculated. Plaintiff also argues that the supervision of
Roberts and McConnell was inadequate. Regardless of these
issues, however, plaintiff’s central argument is that the
submitted descriptions of the searches are inadequate as a matter
of law because they do not sufficiently describe the records
searched, the methodology used, and the search terms employed.
Most of defendant’s declarations and descriptions of its
searches are inadequate under FOIA. For instance, many of the
descriptions do not contain any details regarding which databases
or records were searched, and what methodology or search terms
were used. See, e.g., Def.’s Supp. Mem., Attach. 2, at 16
(Office of Space Flight reports that it conducted an “extensive”
search and “did not find any records on file at Headquarters
documenting the 11 items asked for in the request”), 22 (Office
of General Counsel checked the box stating “a search was
conducted and no responsive records were located”), 37 (Ames
Research Center reported simply, “no records here at Ames”); 1st
Roberts Decl., Ex. 6C (Glenn Research Center reported that
several offices conducted searches, and that “no records were
found”), Ex. 6F (Johnson Space Center reported that a “‘no
records’ response was received from all” its offices), Ex. 6H
(Langley Research Center reports same), Ex. 6J (“We find no
Case 1:03-cv-02509-EGS Document 45 Filed 03/27/07 Page 14 of 21