by statute” if that statute either “(A)(i) requires that the matters be withheld from the public in such a manner as to leave no discretion on the issue; or (A)(ii) establishes particular criteria for withholding or refers to particular types of matters to be withheld.” 5 U.S.C. § 552(b)(3). Here, the CIA principally invokes Section 102A(i)(1) of the National Security Act of 1947, 50 U.S.C. § 3024(f)(1), which provides that “[t]he Director of National Intelligence shall protect intelligence sources and methods from unauthorized disclosure.” Plaintiff does not dispute that the National Security Act satisfies the second criterion mentioned above because it “refers to particular types of matters to be withheld” — namely, “intelligence sources and methods.” See, e.g., ACLU, 628 F.3d at 619 (<HOLDING>). The principal question, then, is whether the
holding one who claims tax exemption has burden of showing entitlement to exemption holding act qualifies as exemption statute under exemption 3 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 that  6103 qualifies as an exemption statute holding that rule 6e qualifies as a statute for purposes of exemption 3