JERRY E. SMITH, Circuit Judge:
During an investigation into alleged fraud by a United States government contractor, Veterans Administration (VA) officials surreptitiously taped a series of conversations among undercover government agents, employees of the contractor, and third parties. In response to a request under the Freedom of Information Act (FOIA), 5 U.S.C. § 552, for transcripts of the tapes, the government released copies of the transcripts from which...
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