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Requester exhausted remedies before filing suit  (access required)

Where a plaintiff’s initial complaint challenging the government’s response to requests under the Freedom of Information Act was filed more than 20 business days after the request was made, the administrative remedies were exhausted. Background Ayyakkanu Manivannan filed a complaint pursuant to FOIA against the Department of Energy’s National Energy Technology Laboratory, or NETL, alleging that NETL ...