JUSTICE APPLETON delivered the opinion of the court:

In March 2004, plaintiff, Goodrich Corporation (Goodrich), filed a cause of action under the Freedom of Information Act(FOIA) (5 ILCS 140/1 through 11 (West 2002)) against defendant, J.Anthony Clark, Director of the Illinois Department of Insurance,demanding documents concerning Kemper Insurance Company (Kemper). After the initiation of the cause of action, the Illinois Department of Insurance became the Division of Insurance under theDepartment of Financial and Professional Regulation (Division), andDeirdre K. Manna replaced J. Anthony Clark as acting Director. TheDivision appeals the circuit court's two respective December 2004orders (1) denying the Division's motion to vacate the trialcourt's order to index Goodrich's tenth FOIA request and (2)granting Goodrich's partial summary judgment motion requiring theDivision to turn over to Goodrich the records requested inGoodrich's tenth FOIA request as well as the "nonexamination"documents the Division identified in the first 26 pages of an indexit created in response to Goodrich's FOIA request. The Divisionargues the court erred in ordering the Division to index documentsresponsive to Goodrich's tenth FOIA request and in grantingGoodrich's partial summary judgment motion ordering the Division torelease documents requested in Goodrich's tenth FOIA request andother "nonexamination" documents because disclosure of the recordsis prohibited by law. Goodrich argues (1) this court does not havejurisdiction to review the circuit court's order refusing to vacatethe trial court's indexing order and whether the indexing order wasproper and (2) the trial court did not err in granting Goodrich'smotion for partial summary judgment. We dismiss appeal No. 4-05-0040. We affirm in part, vacate in part, and remand appeal No. 4-05-0148.

In December 2003, Goodrich served the Division with anFOIA request, seeking copies of records in 20 specified categories. Later that month, the Division responded to the request, stating itwas unable to locate any records in response to seven of Goodrich'srequests but would make some of the documents requested in eight ofGoodrich's requests available for inspection. However, theDivision informed Goodrich that the remaining records responsive tothe eight requests and all documents responsive to five otherGoodrich requests were exempt from public disclosure. Goodrichfiled an administrative appeal of the Division's nondisclosuredeterminations. In February 2004, the Director of the Divisionaffirmed the Division's decision.

In March 2004, Goodrich filed suit under the FOIA,seeking declaratory and injunctive relief against the Division. InJuly 2004, the Division agreed to provide Goodrich with a document-by-document index of the documents the Division had found exemptfrom disclosure for all but Goodrich's tenth FOIA request.

At a July hearing before the trial court, the Divisionargued it had no obligation to index or even disclose the existenceof documents responsive to Goodrich's tenth FOIA request. TheDivision contended it was statutorily prohibited by section 35A-50of the Insurance Code (Code) (215 ILCS 5/35A-50 (West 2002)) fromeither confirming or denying the existence of corrective orders orrisk-based capital plans that might be responsive to Goodrich'stenth FOIA request. The court disagreed and ordered the Divisionto prepare and provide to Goodrich an index of all the documentsresponsive to Goodrich's tenth request by August 2, 2004.

On August 2, 2004, the Division supplied Goodrich with anindex of the documents Goodrich asked for in its FOIA request,including a list of some documents responsive to Goodrich's tenthFOIA request that the Division determined did not fall within thepurview of section 35A-50(a) of the Code (215 ILCS 5/35A-50(a) West2002)). However, with regard to any other documents the Divisionpossibly possessed responsive to Goodrich's tenth FOIA request, theDivision filed a motion to reconsider and vacate the trial court'sindexing order.

On August 26, 2004, Goodrich filed a motion for partialsummary judgment and for an expedited in camera review, requestingthe trial court order the Division (1) to disclose all documentslisted on pages 1 through 26 of its FOIA index, which the Divisionlabeled as "nonexamination" documents, and all nonindexed documentsresponsive to Goodrich's tenth FOIA request and (2) submit a cross-section of 50 of what the Division labeled as "examination"documents listed on pages 27 through 115 of the Division's FOIAindex for in camera review. Goodrich also filed a memorandum inopposition to the Division's motion to reconsider and vacate and insupport of its motion for partial summary judgment and expedited incamera review.

On December 13, 2004, the trial court entered an orderdenying the Division's motion to reconsider and vacate the court'sorder requiring the Division to index documents responsive toGoodrich's tenth FOIA request. Judge Graves signed and dated thisorder on December 8, 2004. In addition, on December 13, 2004, thecourt entered another order granting Goodrich's (1) motion forpartial summary judgment ordering the Division to turn over toGoodrich all documents listed on the first 26 pages of its FOIAindex and any documents responsive to Goodrich's tenth FOIA requestand (2) motion for expedited in camera review of 50 documentslisted in pages 27 through 115 of the Division's FOIA index.

On January 12, 2005, the Division filed a notice ofinterlocutory appeal, No. 4-05-0040, under Supreme Court Rule307(a) (188 Ill. 2d R. 307(a)), from the trial court's two ordersfiled on December 13, 2004. On February 1, 2005, Goodrich filed amotion to dismiss the Division's interlocutory appeal in thiscourt. In the motion, Goodrich argued the appeal is time-barred,jurisdictionally barred, and frivolous. On February 7, 2005, theDivision filed a motion for leave to file a late notice ofinterlocutory appeal if this court determines the trial court'sorder requiring the Division to index any documents responsive toGoodrich's tenth FOIA request was entered on December 8, 2004,instead of December 13, 2004, which was the date the order was filestamped. On February 16, 2005, the Division filed an objection toGoodrich's motion to dismiss the Division's interlocutory appeal. That same day, Goodrich filed a memorandum in opposition to theDivision's motion for leave to file late notice of interlocutoryappeal, arguing not only that the appeal was untimely but alsojurisdictionally barred. This court has taken both of thesemotions with the case. Goodrich is no longer pursuing theuntimeliness argument pursuant to its appellee's brief. As aresult, we need not address the Division's motion for leave to filea late notice of appeal because that issue has been abandoned byGoodrich.

On or about February 7, 2005, the Division filed a motionfor entry of a Supreme Court Rule 304(a) (155 Ill. 2d R. 304(a))finding in the trial court with regard to the court's December 13,2004, order granting Goodrich's motion for partial summary judgmentand expedited in camera review. On February 15, 2005, the courtentered a Rule 304(a) finding with regard to its December 13, 2004,order granting Goodrich's motion for partial summary judgment andexpedited in camera review.

On February 16, 2005, the Division filed its secondnotice of appeal, No. 4-05-0148, seeking to challenge the partialsummary judgment order pursuant to Rule 304(a). On February 18,2005, the Division filed motions with this court to (1) extend thebriefing schedule in its first appeal and (2) consolidate the twoappeals. This court granted both of those motions as well as theDivision's motion for a stay pending appeal.

A. Jurisdiction Over Appeal No. 4-05-0040

In its motion to dismiss the Division's interlocutoryappeal, Goodrich argues this court does not have jurisdiction overthe trial court's decision not to vacate its indexing order andthat this appeal is frivolous. The Division filed its appealregarding the trial court's refusal to vacate its indexing orderpursuant to Rule 307(a)(1). Rule 307(a)(1) states:

"An appeal may be taken to the AppellateCourt from an interlocutory order of thecourt:

(1) granting, modifying, refusing, dissolving, or refusing to dissolve or modify aninjunction[.]" 188 Ill. 2d R. 307(a)(1).

When determining jurisdiction under Rule 307, a motion to vacate aninjunction is treated as the equivalent of a motion to dissolve aninjunction. Doe v. Department of Professional Regulation, 341 Ill.App. 3d 1053, 1058, 793 N.E.2d 119, 123 (2003).

However, according to Goodrich, the trial court'sindexing order was not "injunctive" within the meaning of Rule 307. Goodrich argues that an order requiring an FOIA defendant toproduce an index provided for under section 11(e) of the FOIA (5ILCS 140/11(e) (West 2002)) is purely "ministerial" and "administrative." Goodrich claims the indexing order was a "proceduralruling, much like an order compelling the production of a privilegelog, or any other routine discovery order; it does not adjudicateany rights, or alter or affect the legal relationship between theparties."

Goodrich cites Hinton v. Department of Justice, 844 F.2d126, 129-30 (3d Cir. 1988), for the proposition that an FOIA indexis only "a simple means to an end" and that it does not accord arequestor any of the substantive relief he seeks, nor does itprotect the substance of the matter, in the usual injunctive senseof preserving the status quo. Instead, the index is a tool fordetermining the requestor's substantive rights. Hinton, 844 F.2dat 130. Goodrich argues if an order to produce an FOIA index isenough to qualify as an injunction, then any administrative ordiscovery order would qualify for an immediate interlocutoryappeal. Discovery orders ordinarily are not subject to interlocutory appeal because they only regulate the procedural aspects ofthe case before the court. In re A Minor, 127 Ill. 2d 247, 261-62,537 N.E.2d 292, 298 (1989).

The Division argues the trial court's indexing orderregarding Goodrich's tenth FOIA request went beyond the proceduralaspects of this case. Citing Coastal States Gas Corp. v. Department of Energy, 644 F.2d 969 (3d Cir. 1981), the Division contendsthe court's order requiring the Division to prepare an index willhave irreparable consequences and can only be effectively challenged by immediate appeal. According to the Division, turning theindex over to Goodrich would effectively give information toGoodrich that it seeks through its FOIA request.

To determine if an order is injunctive for purposes ofRule 307, we look to the substance, not the form, of the order. AMinor, 127 Ill. 2d at 260, 537 N.E.2d at 297. Courts broadlyconstrue the meaning of the word "injunction" for Rule 307(a)(1)purposes. A Minor, 127 Ill. 2d at 260-61, 537 N.E.2d at 298. Oursupreme court has described an injunction as a:

"'judicial process, by which a party is required to do a particular thing, or to refrainfrom doing a particular thing, according tothe exigency of the writ, the most common sortof which operate as a restraint upon the partyin the exercise of his real or supposedrights.'" A Minor, 127 Ill. 2d at 261, 537N.E.2d at 298, quoting Wangelin v. Goe, 50Ill. 459, 463 (1869).

However, our supreme court has also stated that orders properlycharacterized as "ministerial" or "administrative" cannot be thesubject of an interlocutory appeal because they only concern theprocedural details of the case before the court. A Minor, 127 Ill.2d at 262, 537 N.E.2d at 298.

We find we do not have jurisdiction over the trialcourt's indexing order under Rule 307(a). The court's indexingorder only concerned the procedural aspects of this case. Toappeal the court's indexing order, the Division could have waiteduntil a final judgment had been entered, obtained a Rule 304(a)finding concerning the indexing order from the court, or been foundin contempt of court. The Division did not do any of these things. Therefore, we grant Goodrich's motion to dismiss appeal No. 4-05-0040.

However, even if we had jurisdiction, we would not havefound the trial court erred in ordering the Division to prepare anindex of any documents it possessed with regard to Goodrich's tenthFOIA request. Goodrich's tenth FOIA request asked for thefollowing:

"All [r]ecords that constitute, refer to, orrelate to the commutation or termination ofreinsurance agreements between Kemper andaffiliates of Berkshire Hathaway Inc., asannounced in the June 23, 2003[,] pressrelease of Kemper."

The Division did index nine records responsive to this request.However, the Division argued section 35A-50 of the Code precludesthe Division from confirming or denying the existence of risk-basedcapital reports (RBC Reports), risk-based capital plans (RBCPlans), or corrective orders that would be responsive to thisrequest if they existed. The dispute over the indexing order inthis case is whether the Division has to confirm or deny theexistence of the above-mentioned categories of RBC-related recordsby indexing the records, if they have any.

Section 35A-50(a) of the Code states as follows:

"All RBC Reports, to the extent theinformation therein is not required to be setforth in a publicly available annual statementschedule, and RBC Plans, including the resultsor report of any examination or analysis of aninsurer performed under this [a]rticle and any[c]orrective [o]rder issued by the Directorpursuant to the examination or analysis, withrespect to any domestic insurer or foreigninsurer that are filed with the Directorconstitute information that might be damagingto the insurer if made available to itscompetitors and shall be kept confidential bythe Director. This information shall not bemade public or be subject to subpoena, otherthan by the Director and then only for thepurpose of enforcement actions taken by theDirector under this Code or other provisionsof the insurance laws of this [s]tate." 215ILCS 5/35A-50(a) (West 2002).

The Division misinterprets the language of section 35A-50of the Code in arguing that section 35A-50 contains an exception tothe indexing requirements established in section 11(e) of the FOIA(5 ILCS 140/11(e) (West 2002)). Courts have rejected the idea thatan agency can determine for itself what to withhold pursuant to theFOIA. See Cooper v. Department of the Lottery, 266 Ill. App. 3d1007, 1024, 640 N.E.2d 1299, 1310 (1994). Section 11(e) of theFOIA (5 ILCS 140/11(e) (West 2002)) states:

"On motion of the plaintiff, prior to orafter in camera inspection, the court shallorder the public body to provide an index ofthe records to which access has been denied. The index shall include the following:

(i) A description of the nature orcontents of each document withheld, or eachdeletion from a released document, provided,however, that the public body shall not berequired to disclose the information which itasserts is exempt; and

(ii) A statement of the exemption orexemptions claimed for each such deletion orwithheld document."

The cardinal rule of statutory construction is toascertain and give effect to the true intention and meaning of thelegislature. State Farm Fire & Casualty Co. v. Yapejian, 152 Ill.2d 533, 540-41, 605 N.E.2d 539, 542 (1992). The language of thestatute is the best indicator of that intent, and aids forconstruing a statute will only be resorted to if the language ofthe statute is not clear. Solich v. George & Anna Portes CancerPrevention Center of Chicago, Inc., 158 Ill. 2d 76, 81, 630 N.E.2d820, 822 (1994).

Based on the plain language of section 35A-50, we findthe statute does not make the mere existence of RBC Reports, RBCPlans, and corrective orders confidential. Section 35A-50(a) onlymakes the information contained in RBC Reports confidential "to theextent the information therein is not required to be set forth ina publicly available annual statement schedule." 215 ILCS 5/35A-50(a) (West 2002). Likewise, the section only makes information inRBC Plans confidential "including the results or report of anyexamination or analysis of an insurer performed under this[a]rticle and any [c]orrective [o]rder issued by the Directorpursuant to the examination or analysis." 215 ILCS 5/35A-50(a)(West 2002). Contrary to the Division's assertion, section 35A-50applies equally to RBC Reports and RBC Plans. The Division hasadmitted the existence of RBC Reports is not confidential becausethe Code requires "every domestic insurer" to prepare and file anRBC Report each year (see 215 ILCS 5/35A-10(a) (West 2002)). Wefind section 35A-50 also did not intend to make the mere existenceof RBC Plans or corrective orders confidential.

The documents themselves are also not per se exempt underGoodrich's tenth FOIA request. Our supreme court has stated:

"When a public body receives a properrequest for information, it must comply withthat request unless one of the narrowstatutory exemptions applies. [Citation.] *** If the public body seeks to invoke one ofthe exemptions in section 7 as grounds forrefusing disclosure, it is required to givewritten notice specifying the particularexemption claimed to authorize the denial. [Citations.] If the requesting partysubsequently challenges the denial in circuitcourt [citation], the public body has theburden of proving that the records in questionfall within the exemption it has claimed. [Citation.]

Most of the exemptions set forth insection 7 of the Act [citation] are specific,identifying the particular public records thatare not subject to disclosure. Where thepublic body claims that a requested documentfalls within one of these specificallyenumerated categories and is able to provethat claim, no further inquiry by the court isnecessary. The documents 'shall be exemptfrom inspection and copying.' [Citation.] This per se rule applies to the specificexemptions set forth in the subsections ofsection 7(1)(b) of the Act [citation], whichpertains to '[i]nformation that, if disclosed,would constitute a clearly unwarrantedinvasion of personal privacy,' just as it doesto the other exemptions in section 7." Lieberv. Board of Trustees of Southern IllinoisUniversity, 176 Ill. 2d 401, 407-08, 680N.E.2d 374, 377 (1997).

The Division relies on Roulette v. Department of CentralManagement Services, 141 Ill. App. 3d 394, 490 N.E.2d 60 (1986),and Smith v. Cook County Probation Department, 151 Ill. App. 3d136, 502 N.E.2d 1157 (1986), to support its argument that thedocuments are per se exempt pursuant to section 35A-50 of the Code,which is incorporated by section 7(1)(a) of the FOIA (5 ILCS140/7(1)(a) (West 2002)). However, the situation in the case atbar is distinguishable from the situations in Roulette and Smith.

In Roulette, the plaintiff demanded pursuant to the FOIAthat the defendant produce two records, an interviewingpsychologist's handwritten notes from the psychologist's interviewwith plaintiff and the psychologist's evaluation of the plaintiff'sMinnesota Multiphasic Personality Inventory (MMPI), that were partof his application for state employment. Roulette, 141 Ill. App.3d at 395-96, 490 N.E.2d at 61. The trial court ordered thedefendant and the psychologist to release this material to theplaintiff. Roulette, 141 Ill. App. 3d at 396, 490 N.E.2d at 61. The appellate court reversed, finding the documents requested werenot subject to disclosure because "'test questions, scoring keys[,]and other examination data used to administer an academicexamination or determine the qualifications of an applicant for alicense or employment'" are exempt pursuant to section 7(j) of theFOIA. Roulette, 141 Ill. 2d at 396, 490 N.E.2d at 61, quoting Ill.Rev. Stat., 1984 Supp., ch. 116, par. 207(j) (now 5 ILCS 140/7(j)(West 2002)). In essence, the Roulette court found the records perse exempt because the records requested fell within the scope ofthe exemption.

In Smith, the issue on appeal was "whether the trialcourt erred in granting [the] defendants' motion to dismiss on theground that probation records held by the Cook County probationdepartment *** are exempt from disclosure under the FOIA." Smith,151 Ill. App. 3d at 137, 502 N.E.2d at 1157. The appellate courtaffirmed, finding that section 7 of the FOIA:

"specifically exempts from inspection andcopying '[i]nformation specifically prohibitedfrom disclosure by [f]ederal or [s]tate law orrules and regulations adopted pursuantthereto.' With respect to the facts of thiscase, section 12 of 'An Act providing for asystem of probation ***' of the Code ofCriminal Procedure of 1963 (the Probation Act)[citation], is the [s]tate law whichspecifically prohibits disclosure of probationrecords except for 'inspection by any judge orby any probation officer pursuant to order ofcourt' or by further 'order of court' andexpressly states that probation records arenot public records." Smith, 151 Ill. App. 3dat 138, 502 N.E.2d at 1158.

The Smith court found the records per se exempt because the recordswere not only within the scope of a statutory exemption butmirrored a statutory exemption.

In the case at bar, Goodrich's tenth FOIA request neithermirrors nor falls within the scope of the exemptions listed insection 35A-50 of the Code. Because Goodrich's tenth request doesnot fall within the scope of the exemptions listed in section 35A-50 of the Code, the Division must identify and prove the records itpossesses responsive to this request are exempt from disclosure. The Division must identify these records, including any RBC-relatedrecords, and fulfill its burden of proving the records are exempt. See Lieber, 176 Ill. 2d at 408, 680 N.E.2d at 377.

B. Appeal No. 4-05-0148

The Division filed its second appeal, No. 4-05-0148,seeking to challenge the trial court's partial summary judgmentorder pursuant to Rule 304(a). In its partial summary judgmentorder, the court ordered the Division to (1) turn over all of the"nonexamination" records listed on the first 26 pages of theDivision's 115-page index, (2) turn over to Goodrich all documentsresponsive to Goodrich's tenth FOIA request, and (3) submit to thecourt a specified sampling of the "examination" records listed onpages 27 through 115 of the Division's index. The Division arguesthe court erred in granting summary judgment with regard to the"nonexamination documents" and the documents responsive toGoodrich's tenth FOIA request. The Division does not appeal thecourt's order to submit a specified sampling of the "examination"documents. As a result, we do not consider the merits of thatparticular order.

Regarding the turnover orders at issue, the trial courtstated that it agreed with Goodrich that (1) the Division had notborne its "burden of providing a proper and sufficiently detailedfactual showing" to justify its nondisclosures and (2) "theDivision's interpretation and application of the statutory[e]xemptions on which it has relied is demonstrably invalid andmisreads the statutory provisions in question."

Appellate courts review an order granting summaryjudgment de novo. Illinois Education Ass'n v. Illinois State Boardof Education, 204 Ill. 2d 456, 459, 791 N.E.2d 522, 524 (2003). Summary judgment is only appropriate when no genuine issue ofmaterial fact exists and the moving party is entitled to judgmentas a matter of law. Travelers Insurance Co. v. EljerManufacturing, Inc., 197 Ill. 2d 278, 292, 757 N.E.2d 481, 491(2001). Summary judgment is only proper when the moving party'sright to judgment is clear and free from doubt. Outboard MarineCorp. v. Liberty Mutual Insurance Co., 154 Ill. 2d 90, 102, 607N.E.2d 1204, 1209 (1992). The trial court must construe the recordbefore it strictly against the party moving for judgment. Baudinv. City of Crystal Lake, 192 Ill. App. 3d 530, 536, 548 N.E.2d1110, 1114 (1989). "Summary judgment is a drastic remedy and, assuch, must be granted only when the movant's right to judgment asa matter of law is clear and free from doubt." Baudin, 192 Ill.App. 3d at 536, 548 N.E.2d at 1114. However, "[t]o survive amotion for summary judgment, the nonmoving party must come forwardwith evidentiary material that establishes a genuine issue offact." Weil, Freiburg & Thomas, P.C. v. Sara Lee Corp., 218 Ill.App. 3d 383, 394, 577 N.E.2d 1344, 1352 (1991). The nonmovingparty cannot simply deny the moving party's factual allegations. Purdy Co. of Illinois v. Transportation Insurance Co., 209 Ill.App. 3d 519, 529, 568 N.E.2d 318, 324 (1991).

We address the trial court's turnover orders regardingthe "nonexamination" documents listed on pages 1 through 26 of theDivision's index and the records responsive to Goodrich's tenthFOIA request in turn.

1. "Nonexamination" Records

The Division failed to come forward with any evidentiarymaterial to establish a question of fact. While the Division triesto rely on its FOIA index, we cannot take the index intoconsideration because it is not admissible evidence. See HarrisBank Hinsdale, N.A. v. Caliendo, 235 Ill. App. 3d 1013, 1025, 601N.E.2d 1330, 1338 (1992). Not only are most of the index entriesinsufficient to describe what is being withheld, the Division didnot swear to the accuracy of the index. As a result, the indexamounts to inadmissible evidence.

The only evidence the Division presented in opposition toGoodrich's motion for summary judgment were the affidavits of JackMessmore, the Division's Chief Deputy Director, and Susan Anders,the Division's FOIA officer and paralegal. Messmore's affidavitdoes not discuss the index or any of the documents the Divisionwithheld. It only addresses why the Division should not have toindex documents responsive to Goodrich's tenth FOIA request. Anders's affidavit also does not aid the Division's argument, as itonly discusses the length of time and manpower it took the Divisionto create the index.

Because the Division failed to come forward with anyadmissible evidence creating a question of fact, the trial courtdid not err in granting Goodrich's motion for partial summaryjudgment concerning the "nonexamination" documents listed on pages1 through 26 of the Division's index.

2. Goodrich's Tenth FOIA Request

The trial court filed its order denying the Division'smotion to vacate the indexing order on the same day it filed anorder granting Goodrich's motion for partial summary judgment,ordering the Division to turn all responsive documents not listedon the Division's FOIA index to Goodrich. This would include thedocuments responsive to Goodrich's tenth request. By filing theorder requiring the turnover of the documents responsive toGoodrich's tenth request on the same day it denied the Division'smotion to vacate the court's earlier order to index, the court didnot give the Division an opportunity to begin the process ofbearing its burden of providing a proper and sufficient factualshowing to justify its nondisclosures of any records it possessedresponsive to this request by indexing those documents. As aresult, we vacate this portion of the court's partial summaryjudgment order.

On remand, the Division must create an index of thedocuments requested in Goodrich's tenth FOIA request pursuant tothe court's indexing order unless the Division appeals the orderthrough one of the methods of appeal described above. As a result,we take this opportunity to remind the Division what is required inan FOIA index.

Our supreme court has stated that an agency must providea detailed justification for its refusal to turn over the requesteddocument or documents. Illinois Education Ass'n v. Illinois StateBoard of Education, 204 Ill. 2d 456, 464, 791 N.E.2d 522, 527(2003). The index must address requested documents specificallyand in a manner that allows for adequate adversary testing. Baudinv. City of Crystal Lake, 192 Ill. App. 3d 530, 537, 548 N.E.2d1110, 1114 (1989). The index should include the following: (1) thetitle of the document or the category of documents, (2) the datethe document was created or at least an estimate thereof, (3) thename of the author and recipient, (4) a detailed factualdescription, and (5) the claimed statutory exemption. Seegenerally Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973); 1 J.O'Reilly, Federal Information Disclosure