on the “pre-existing agreement” reached between the CIA and the SSCI to the effect that all CIA created documents related in any way to a congressional inquiry would be congressional records for FOIA purposes. This argument was discussed and rejected supra at pp. 694-695. 43 . We note that, in the absence of some assertion of congressional control, there would be no question but that these documents were agency records. They are, for the most part, internal agency notations and memoranda, created by the CIA and kept in its files to serve the security, information, and communications purposes of the agency. See Kissinger v. Reporters Committee for Freedom of the Press, supra note 27, 445 U.S. at 157, 100 S.Ct. at 972. 44 . But see Navasky v. CIA, 499 F.Supp. 269, 278 (S.D.N.Y.1980) (<HOLDING>). 45 . The District Court raised this issue sua
holding that municipal court records were admissible under  official records or public documents  exception holding that personnel records or conduct investigative records regarding police officers are exempt from disclosure under virginias freedom of information act which exempts personnel records from disclosure holding that the secretary at a minimum has constructive knowledge of documents generated by va holding that documents generated by the cia at the specific request of congress were exempt from disclosure as congressional records holding that the government must provide the party seeking disclosure with a detailed index describing the documents the government claims are exempt from disclosure under foia