This study demonstrates that FOIA often serves as a stand-in for administrative discovery where no such procedure exists, or a method to obtain records needed to be able to apply for a particular agency benefit. That is, requesters are often seeking records from the agency in conjunction with a pending proceeding the requester has with the agency itself. Sometimes the records are needed in order to better position the requester in defending against an enforcement action brought by the agency, and other times they are needed to bolster the requester’s attempt to secure benefits the agency administers. Regardless, FOIA in these instances ends up being a parallel agency process the requester must engage to obtain the records on which the agency is relying in an adversarial position or which the requester must produce to secure their position.