Whether publicly-known, purely factual content selected, organized, and recited in an agency's records can be fully withheld from disclosure under the deliberative process privilege in Exemption 5 of the Freedom of Information Act, 5 U.S.C. § 552(b)(5)

QUESTIONS PRESENTED The questions presented are: 1. Whether publicly-known, purely factual content selected, organized, and recited in an agency’s records can be fully withheld from disclosure under the deliberative process privilege in Exemption 5 of the Freedom of Information Act, 5 U.S.C. § 552(b)(5). 2. Whether the presumption of good faith attached to an agency’s representation that it released all “reasonably segregable portion[s] of a record” otherwise withheld from disclosure under the deliberative process privilege, 5 U.S.C. §§ 552(b) & (b)(5), is rebutted by evidence that would warrant a belief by a reasonable person that segregable portions instead were withheld.