without being inhibited by fear of later public disclosure” and must reflect “the ‘give-and-take’ of the deliberative process and contain[] opinions, recommendations, or advice about agency policies”) (emphasis added by plaintiff) (citations omitted); see also Pl.’s Mem. for Mot. to Compel at 27, quoting Pub. Citizen, Inc. v. Office of Mgmt. & Budget, 598 F.3d 865, 875 (D.C.Cir.2009) (“To the extent the documents ... [do not] make recommendations for policy change ... they are not predecisional and deliberative despite having been produced by an agency that generally has an advisory role.”) (emphasis added by plaintiff). Notwithstanding the Committee’s added emphasis on the word “policy lar conclusions. See Judicial Watch v. Dep’t of Homeland Sec., 736 F.Supp.2d 202, 208 (D.D.C.2010) (<HOLDING>); Citizens for Responsibility & Ethics in Wash.
recognizing application of federal deliberative process privilege to internal state communications holding that there is no statutory deliberative process privilege in arizona and declining to create such a privilege under the common law holding that internal emails about how to present an agency decision to the public were covered by the deliberative process privilege holding that deliberations about how to handle press inquiries and other public relations issues are covered by exemption 5 under foia holding that documents concerning how to respond to ongoing inquiries from the press and congress about the entry of a government witness and mexican national into the united states fell under the deliberative process privilege