Spadaro v. U.S. Customs & Border Prot. (2nd Cir.) -- affirming district court’s decision that the Department of State properly relied on Exemption 3, in conjunction with section 222(f) of Immigration and Nationality Act, to withhold records about government’s revocation of plaintiff’s visa. In a separate summary order, the Second Circuit affirmed the district court’s decision that the FBI properly withheld records pertaining to plaintiff pursuant to Exemption 5’s deliberative process and attorney work-product privileges.

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