Montrose Chemical Corp. v. Train

WILKEY, Circuit Judge:

In an action brought under the Freedom of .Information Act [FOIA]1 Mont-rose Chemical Corporation is seeking to obtain two summaries of evidence developed at a hearing. The Administrator of the Environmental Protection Agency [EPA], the official for whom the summaries were prepared, then William Ruckelshaus, contends that the summaries are exempt from disclosure under the intra-agency memoranda exception of FOIA. Exemption 5 frees from the disclosure requirements “inter-agency or intra-agency memorandums or letters which would not be available by law to a party other…