North Dakota ex rel. Olson v. Andrus, 581 F.2d 177, 180 (8th Cir. 1978); Mead Data Cent., Inc. v. United States Dep’t of Air Force, 566 F.2d 242 (D.C. Cir. 1977); Shell Oil Co. v. Internal Revenue Serv., 772 F. Supp. 202 (D. Del. 1991); Wash. Post Co. v. United States Dep’t of Air Force, 617 F. Supp. 602 (D.D.C. 1985) (each discussing FOIA “exemption 5,” which exempts from disclosure “inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with the agency,” 5 U.S.C. § 552(b)(5), and holding that, by analogy to waiver of attorney-client privilege, an agency cannot claim that the information is exempt from disclosure); N.W. Coalition for Alternatives to Pesticides v. Browner, 941 F. Supp. 197, 201 (D.D.C. 1996) (<HOLDING>); Lawyers Comm. for Human Rights v. Immigration
holding that foia exemption 4 did not apply because agency did not meet burden of showing that desired information consisted of trade secrets and commercial or financial information obtained from a person that are privileged or confidential holding that the scope of the trade secrets act is at least coextensive with that of exemption 4 of foia recognizing a legitimate need to protect an employee from disclosing an employers trade secrets or other confidential information to a competitor holding that disclosure during discovery of certain kinds of information including privileged material trade secrets attorney work product or material involving a confidential informant could constitute a material injury of an irreparable nature holding records did not qualify as exempt confidential commercial information under exemption 4 because the information was not actually confidential