that disclosure under the Privacy Act applies to records located within “a group of records ... from which information is retrieved by the name of the individual or by some identifying number, symbol, or other identifying particular assigned to the individual.”). Plaintiff offers two reasons as to why these documents should nevertheless be disclosed. First, Plaintiff asserts that Defendant failed to invoke any Privacy Act exemptions in “the administrative record,” and therefore is precluded from doing so now. PL’s Reply at 11. This argument fails because there is no requirement that an agency administratively invoke an exemption in order to later rely on it in federal court. See Hodes v. U.S. Dep’t of Housing & Urban Devel., 532 F.Supp.2d 108, 114 n. 2 (D.D.C.2008) (Kollar-Kotelly, J.) (<HOLDING>); Sciba v. Bd. of Governor of Fed. Reserve
holding that an agency carries its burden of proof by providing affidavits to explain why documents are subject to an exemption holding a debtors claim for loss of consortium to be entitled to an exemption under the oklahoma exemption statute and collecting other bankruptcy decisions recognizing a debtor spouses loss of consortium as the basis for allowing an exemption under federal and various state exemption statutes holding act qualifies as exemption statute under exemption 3 holding that an agency could invoke an exemption that was not previously asserted in its letters with the foiaprivacy act requester holding that agency demand letters are not suits