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Allan Favish is a Los Angeles-based attorney whose focus is on General Insurance Defense and Litigation Insurance Coverage/Reinsurance & Bad Faith Litigation.  A UCLA graduate, he received his J.D. at Hastings College of Law in 1981.

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Declaration of Darrell M. Joseph


5(a).     Set forth as Exhibits I-1 through 1-4 to this declaration are copies of pre-litigation correspondence between plaintiff and OIC relating to plaintiff's FOIA request. Exhibit I-1 is the initial request from the plaintiff, dated January 6, 1997. Plaintiff seeks "[p]hotographs taken in connection with the investigation into the death of Vincent Foster." Plaintiff’s letter specified what he described as ten categories of requested photographs. Exhibit 1-2 is a copy of OIC's January 24, 1997 letter denying plaintiff's request, pursuant to Exemptions 7(A) and 7(C) of the FOIA, 5 U.S.C. §§ 552(b)(7)(A) and 552(b)(7)(C), while reserving OIC's right to assert the applicability of other relevant exemptions, if warranted. Exhibit I-3 is a copy of plaintiff's appeal letter, dated January 28, 1997. Exhibit 1-4 is a February 19, 1997 letter from John D. Bates, Deputy Independent Counsel, denying plaintiff's appeal, pursuant to Exemptions 7(A) and 7(C) of the FOIA, while reserving OIC’s right to assert other applicable exemptions if the need should arise.

 5(b).    On October 10, 1997, Independent Counsel Kenneth W. Starr submitted his Report on the death of Vincent W. Foster, Jr. ("Report") to the United States Court of Appeals for the District of Columbia Circuit's Division for the purpose of Appointing

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