MEMORANDUM & ORDER Plaintiff Center for Popular Democracy brings this action pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. §552 et seq. (Compl. (Dkt. 1).) Plaintiff alleges that Defendant the Board of Governors of the Federal Reserve System (the “Board of Governors” or the “Board”) failed to release documents responsive to Plaintiff’s FOIA request. The parties now cross-move for summary judgment pursuant to Federal Rule of Civil Procedure 56. (Def. Mot. for Summ. J. (“Def. Mot.”) (Dkt. 40); Pl. Mot. for Summ. J. (“Pl. Mot.”) (Dkt. 41).) For the following reasons, Defendant’s motion for summary judgment is GRANTED IN PART and DENIED IN PART, and Plaintiff’s motion for summary judgment is GRANTED IN PART and DENIED IN PART.I. BACKGROUNDA. Factual BackgroundPlaintiff is a non-profit organization focused on economic and racial justice. (Compl. 4.) Plaintiff organizes and directs the national “Fed Up” campaign, the mission of which is to make the Federal Reserve more representative of the public and to encourage the Federal Reserve to adopt pro-worker economic policies. (Id.)The Federal Reserve System (the “Federal Reserve”) is the central bank of the United States. (Id. 6.) The Federal Reserve consists of Defendant Board of Governors, located in Washington, D.C.; and twelve Federal Reserve Banks (“Reserve Banks”), located in Boston, New York, Philadelphia, Cleveland, Richmond, Atlanta, Chicago, St. Louis, Minneapolis, Kansas City, Dallas, and San Francisco. (Id.) The Board of Governors and the Reserve Banks share responsibility for supervising and regulating certain financial institutions and activities. (Id.) Each of the Reserve Banks is responsible for supervising and regulating member banks and bank holding companies within a particular geographic area, or District, of the United States. (Id.)The Board of Governors is comprised of a chair and six members, each of whom are appointed by the President of the United States and confirmed by the United States Senate. (Id. 6). Each of the twelve Reserve Banks is led by a president and a nine-member board of directors. (Id. 9.) Each Reserve Bank president is appointed by the board of directors of that bank, subject to the Board of Governors’ approval. (Id. 8.) Reserve Bank presidents serve for a term of five years, subject to mandatory retirement at age 65, and are eligible for reappointment. (Id.) The terms of all twelve Reserve Bank presidents run concurrently, ending on the last day of February of years ending in the digits 6 or 1. (Id.) A Reserve Bank president who is appointed after a term has already begun serves until completion of that term. (Id.)Each Reserve Bank’s board of directors is comprised of three classes of directors: Class A, Class B, and Class C. (Id. 9.) The three Class A and three Class B directors are elected by the stockholding member banks in the District. (Id. (citing 12 U.S.C. §§302, 304).) The three Class C directors are appointed by the Board of Governors. (Id.) By statute, the three Class A directors are to represent the interests of the stockholding member banks in the District, and the three Class B and three Class C directors are to represent the interests of the public, “with due but not exclusive consideration to the interests of agriculture, commerce, industry, services, labor, and consumers.” (Id. (quoting 12 U.S.C. §302).)B. The FOIA Request and Procedural HistoryOn August 5, 2016, Plaintiff submitted a FOIA request (the “FOIA Request”) to the Board of Governors seeking several categories of documents. (Pl. 56.1 Statement (“Pl. 56.1″) 1; Def. 56.1 Statement (“Def. 56.1″) 1.) The FOIA Request sought the following categories of information:Records relating to the Board of Governors’ reappointment of ten Reserve Bank presidents in February 2016 (see FOIA Request (Dkt. 40-5) at 7-20);Records relating to the Board of Governors’ policies, procedures, guidelines, and practices regarding nomination, appointment, review, and reappointment of Reserve Bank presidents (id. at 21-22);Records relating to the Board of Governors’ policies, procedures, guidelines, and practices regarding its oversight of the nomination and election of Class A and Class B Directors of the Reserve Banks (id. at 22-23);Records relating to the Board of Governors’ policies, procedures, guidelines, and practices regarding appointment of Class C Directors of the Reserve Banks (id. at 23-24); andRecords relating to the Board of Governors’ policies and practices regarding promoting diversity among the Federal Reserve’s leadership (id. at 24-26).Following the receipt of the FOIA Request, Defendant extended its time to respond by the statutory maximum of 10 days, to September 19, 2016, but failed to provide a response by that date. (Pl. 56.1 7.) On October 19, 2016, Plaintiff filed the instant action, seeking to compel the production of the requested records. (Id. 9.) The Board provided three interim responses to the FOIA Request, accompanied by responsive documents, on November 22, 2016, December 13, 2016, and February 8, 2017. (Id. 10.) On March 10, 2017, Defendant provided its “final response,” granting in part and denying in part the FOIA Request, along with additional responsive documents and a request for clarification of Part VI, subparts 5, 6, 7 and 8 of the FOIA Request. (Id. 11.) On April 7, 2017, Plaintiff provided clarification to Defendant. (Id. 12.) On February 8, 2018, Defendant produced an additional 562 pages of documents responsive to Part VI, subparts 5, 6, 7 and 8 of the FOIA Request. (Id. 13.)C. Instant Motions for Summary JudgmentOn August 25, 2017, the parties sought leave from the court to file motions for summary judgment. (Joint Letter re: Summary Judgment (Dkt. 21).) The court granted the parties leave to cross-move for summary judgment and set a briefing schedule. (See Oct. 12, 2017 Min. Entry.) The motions were fully briefed and filed with the court on June 13, 2018. (See Dkts. 40-43.)Defendant contends that it is entitled to summary judgment on the grounds that it conducted an adequate search and provided all reasonably segregable, non-exempt responsive information to Plaintiff. (See Def. Mem. at 1.) Plaintiff disputes that Defendant’s search was adequate and cross-moves for summary judgment. (See Pl. Mot.) Plaintiff asks the court to order Defendant to conduct the following searches and produce the results thereof:Search for all annual assessments of Reserve Bank presidents, all “Annotated Bank Evaluations summaries” by the Board of Governor’s Committee on Federal Reserve Bank Affairs (“BAC”) or similar documents, all meeting minutes or similar documents memorializing annual discussions between the BAC and Reserve Bank chairs and deputy chairs regarding Reserve Bank presidents’ performance, and all documents relating to the foregoing (Pl. Mot. at 2);Search the calendars, emails, and other files of all members of the Board of Governors who held office between 2010 and 2016, using at least the following keyword search terms: the names of the Reserve Bank presidents; the names of the Reserve Bank chairs; the names of the search firms retained by each Reserve Bank to assist with the reappointment process; the names of any other Reserve Bank presidential candidates; “appointment”; “reappointment”; “president”; and “director” (id.); andSearch all agency records at the Reserve Banks for responsive documents (id.).II. LEGAL STANDARDSummary judgment is appropriate only if the parties’ submissions show that there is “no genuine dispute as to any material fact,” and that the movant is therefore “entitled to judgment as matter of law.” Fed. R. Civ. P. 56(a); see also Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247-48 (1986). The movant has the “burden of showing the absence of any genuine dispute as to a material fact.” McLee v. Chrysler Corp., 109 F.3d 130, 134 (2d Cir. 1997). “Once the moving party has met this burden, the party opposing summary judgment must identify specific facts and affirmative evidence that contradict those offered by the moving party to demonstrate that there is a genuine issue for trial.” Ethelberth v. Choice Sec. Co., 91 F. Supp. 3d 339, 349 (E.D.N.Y. 2015) (citing Celotex Corp. v. Catrett, 477 U.S. 317, 324 (1986)). The non-moving party “must offer some hard evidence,” not merely speculation, “showing that [its] version of the events is not wholly fanciful.” Id. (quoting D’Amico v. City of N.Y., 132 F.3d 145, 149 (2d Cir. 1998)). The court must resolve all ambiguities and draw all reasonable inferences in favor of the non-moving party. Kaytor v. Elec. Boat Corp., 609 F.3d 537, 546 (2d Cir. 2010). Where two parties make cross-motions for summary judgment, “each party’s motion must be examined on its own merits, and in each case all reasonable inferences must be drawn against the party whose motion is under consideration.” Morales v. Quintel Entm’t, Inc., 249 F.3d 115, 121 (2d Cir. 2001) (citing Schwabenbauer v. Bd. of Educ., 667 F.2d 305, 314 (2d Cir. 1981)).“Summary judgment is the preferred procedural vehicle for resolving FOIA disputes.” Labella v. Fed. Bureau of Investigation, No. 11-CV-23 (NGG), 2012 WL 948567, at *6 (E.D.N.Y. Mar. 19, 2012) (citation omitted). To secure summary judgment in a FOIA case, the defendant agency must show that it conducted an adequate search and that any withheld documents fall within a FOIA exemption. See Adamowicz v. I.R.S., 402 F. App’x 648, 650 (2d Cir. 2010) (summary order); Carney v. U.S. Dep’t of Justice, 19 F.3d 807, 812 (2d Cir. 1994). An agency conducts an adequate search where its search is “reasonably designed to identify and locate responsive documents.” Davis v. U.S. Dep’t of Homeland Sec., No. 11-CV-203 (ARR), 2013 WL 3288418, at *6 (E.D.N.Y. June 27, 2013) (quoting Garcia v. U.S. Dep’t of Justice, Office of Info. & Privacy, 181 F. Supp. 2d 356, 368 (S.D.N.Y. 2002)); Sussman v. U.S. Dep’t of Justice, No. 03-CV-3618 (DRH), 2006 WL 2850608, at *10 (E.D.N.Y. Sept. 30, 2006) (The adequacy of a search turns on “whether the agency’s search was reasonably calculated to discover the requested documents.”) (citation omitted). An agency is “not expected to take extraordinary measures to find the requested records,” nor is it obligated to “search every record system” or use “all possible variants of a particular name or search term.” Conti v. U.S. Dep’t of Homeland Sec., No. 12-CV-5827 (AT), 2014 WL 1274517, at **11, 15 (S.D.N.Y. Mar. 24, 2014) (citations omitted). Although one location may be the “most likely” to turn up records, “the agency cannot limit its search to only one record system if there are others that are likely to turn up the information requested.” Oglesby v. U.S. Dep’t of Army, 920 F.2d 57, 68 (D.C. Cir. 1990). Similarly, the agency cannot satisfy its FOIA obligations simply by searching only the files of the custodians “‘most likely’ to have responsive records,” Nat’l Day Laborer Org. Network v. U.S. Immigration & Customs Enf’t Agency, 877 F. Supp. 2d 87, 98 (S.D.N.Y. 2012), rather, it must search “all custodians who were reasonably likely to possess responsive documents,” id. at 96 (citing Banks v. U.S. Dep’t of Justice, 700 F. Supp. 2d 9, 15 (D.D.C. 2010)); see id. at 97-98, 101-02 (agency unreasonably failed to search certain offices and custodians despite evidence that they were involved in discussions relevant to the request). “[I]f a review of the record raises substantial doubt, particularly in view of well defined requests and positive indications of overlooked materials, summary judgment is inappropriate.” Valencia-Lecena v. U.S. Coast Guard, 180 F.3d 321, 326 (D.C. Cir. 1999) (quotation marks and citations omitted).Agency affidavits describing the underlying searches are “accorded a presumption of good faith.” Grand Cent. P’ship, Inc. v. Cuomo, 166 F.3d 473, 489 (2d Cir. 1999) (quoting Carney, 19 F.3d at 812). Summary judgment in an agency’s favor, based on its submissions, is “inappropriate ‘where the agency’s response raises serious doubts as to the completeness of the agency’s search, where the agency’s response is patently incomplete, or where the agency’s response is for some other reason unsatisfactory.’” Nat’l Day Laborer Org. Network, 877 F. Supp. 2d at 96 (quoting Exxon Corp. v. Fed. Trade Comm’n, 466 F. Supp. 1088, 1094 (D.D.C. 1978)). Plaintiffs can defeat summary judgment in the agency’s favor by raising “tangible evidence” that the agency’s search was not complete. Carney, 19 F.3d at 812. Plaintiffs must provide specific evidence about a search’s inadequacy; “purely speculative claims about the existence and discoverability of other documents” are not enough. Adamowicz, 402 Fed. App’x at 650 (quoting Grand Cent. P’ship, Inc., 166 F.3d at 489). A district court that finds a search to be inadequate may direct the defendant to conduct additional searches. See, e.g., Immigrant Def. Project v. U.S. Immigration, 208 F. Supp. 3d 520, 527 (S.D.N.Y. 2016); Nat’l Day Laborer Org. Network, 877 F. Supp. 2d at 112.III. DISCUSSIONA. Adequacy of SearchDefendant argues that it is entitled to summary judgment and dismissal of this action because it properly responded to the FOIA Request after having conducted an adequate search for responsive records. (Def. Mem. at 1.) In support its motion, Defendant submits two declarations from David G. Caperton, Special Counsel for Oversight Reviews in the Legal Division of the Board of Governors, one dated May 16, 2017 (the “First Caperton Declaration”) and the other dated July 20, 2017 (the “Supplemental Caperton Declaration, and together with the First Caperton Declaration, the “Caperton Declarations”). (See May 16, 2017 Decl. of David G. Caperton (“First Caperton Decl.”) (Dkt. 40-4); July 20, 2017 Decl. of David G. Caperton (“Suppl. Caperton Decl.”) (Dkt. 40-12).) The First Caperton Declaration describes how Caperton supervised a team of four lawyers and a paralegal, each of whom had experience processing FOIA requests, in searching for and reviewing potentially responsive information over a period of seven months. (First Caperton Decl. 21.) He explains that his team consulted with “subject matter experts on the broad topics covered by the FOIA Request” in three divisions and three offices of the Board of Governors, gathered a wide range of information, reviewed that information, and used it to identify other individuals who might have potentially responsive documents. (Id.
21-22.) He describes the searches that he and his team undertook, and explains that they “followed up on every lead that these [subject-matter] experts offered” and ultimately “concluded that [they] had identified and contacted the most likely sources of responsive records and [] considered it unlikely that responsive records were located in other divisions or offices of the Board.” (Id. 22.) The Supplemental Caperton Declaration contains additional information regarding the search, including why the emails of Governor Brainard and the files of the Reserve Banks were not searched. (Suppl. Caperton Decl.
