FOIA Request
In American Small Bus. League v. US Small Bus. Admin., No. 09-16756, a request under the Freedom of Information Act (FOIA) to compel Defendant United States Small Business Administration (SBA) to produce Verizon Wireless cell phone records that the agency no longer possessed, the court affirmed summary judgment for defendant where 1) the SBA did not actually possess the records in July 2008, and SBA had no obligation either to retain the records or to seek the records once they were no longer in its possession; and 2) Verizon did not maintain the phone records pursuant to a records-management contract with SBA.
Related Resources
- Full Text of American Small Bus. League v. US Small Bus. Admin., No. 09-16756
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