WIGGINS, Circuit Judge:
This case is a consolidation of three cases arising in the Central District of California. In each case, the Church of Scientology International ("Church") requested that the Exempt Organization division ("EO") of the Internal Revenue Service ("IRS") disclose certain documents pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552 (1988). The IRS responded to each request by disclosing some documents and claiming that others...
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