v line The Civil War (1990) - Abraham Lincoln: As a nation, we began by declaring that "All men are created equal." We now practically read it, "All men are created equal, except Negroes." Soon, it will read "All men are created equal, except Negroes, and Foreigners and Catholics." When it comes to this, I should prefer emigrating to some country where they make no pretense of loving liberty. To Russia, for instance, where despotism can be taken pure and without the base alloy of hypocrisy.

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VAUGHN INDEX

The term "Vaughn Index" originated from Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1974), wherein the court rejected an agency's conclusory affidavit stating that requested FOIA documents were subject to exemption. Id. at 828. "A Vaughn Index must: (1) identify each document withheld; (2) state the statutory exemption claimed; and (3) explain how disclosure would damage the interests protected by the claimed exemption." Citizens Comm'n on Human Rights v. FDA, 45 F.3d 1325, 1326 n.1 (9th Cir. 1995). This detailed affidavit " 'permit[s] the court system effectively and efficiently to evaluate the factual nature of disputed information.' " John Doe Agency v. John Doe Corp., 493 U.S. 146, 149 n.2 (1989) (quoting Vaughn, 484 F.2d at 826).

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