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

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records at the Stennis Space Center that would satisfy this
request.”). In fact, many of the email documents and
declarations regarding searches at the NASA Centers contain only
a description of which offices in the Center the FOIA requests
was forwarded on to, and a summary answer that no responsive
records were found. See, e.g., Def.’s Supp. Mem., Attach. 6
(Glenn Research Center); Attach. 10 (Johnson Space Center);
Attach. 8 (Goddard Space Center), Attach. 13 (Kennedy Space
Center). These documents and declarations are inadequate to
satisfy defendant’s burden at summary judgment because they fail
to “describe in any detail what records were searched, by whom,
and through what process.” See Steinberg, 23 F.3d at 551-52.
The inadequacy of these documents is highlighted by the
comprehensive responses from two departments – the Marshall Space
Flight Center (“MSFC”) and especially the Jet Propulsion
Laboratory (“JPL”). The declaration regarding the MSFC described
searches for each of the 11 subject areas of the FOIA request, in
particular stating which exact databases were searched and what
search terms were used. See Def.’s Supp. Mem., Attach. 7. The
submission from the JPL is even more detailed, describing the
searches of numerous databases, microfilm rolls, file folders,
and computer files, and further including the search terms used
in these searches. See 1st Roberts Decl., Ex. 6E. Had all of
defendant’s submissions been so detailed, defendant may have been
Case 1:03-cv-02509-EGS Document 45 Filed 03/27/07 Page 15 of 21