MEMORANDUM OPINION AND ORDER
JOYCE HENS GREEN, District Judge.
In this action under the Freedom of Information Act, 5 U.S.C. § 552 ("FOIA"), the parties have both moved for summary judgment and the matter is ripe for disposition. Plaintiff, Arthur Andersen & Co. ("Andersen"), is a national public accounting firm, seeking disclosure under 5 U.S.C. § 552(a)(2)
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