Must a plaintiff facing a motion for summary judgment provide evidence that the movant has acted in bad faith before obtaining discovery under Rule 56(d) in a FOIA case?

QUESTIONS PRESENTED 1. Must a plaintiff facing a motion for summary judgment provide evidence that the movant has acted in bad faith before obtaining discovery under Rule 56(d), where the sole reason that bad faith is being required is that the case arises under the Freedom of Information Act (FOIA)? 2. If there is a FOIJA-specific requirement that a plaintiff provide evidence of agency bad faith before obtaining discovery under Rule 56(d), does the requirement extend to situations in which the government agency has failed to meet its initial burden of proof under the summary judgment standard?