 Under Endowment procedures, this application was referred initially to five experts on Chinese history, each of whom is a professor of history at an American university.  Four of these professors submitted written reviews and the fifth provided an oral review and requested that his comments be kept confidential.  Each of the reviewers recommended rejection of the application.  Secondly, the application, along with others, was referred to a panel of outside experts who consult the Endowment on the humanities generally but not necessarily on Chinese history in particular.  This panel recommended rejection of the application.  Next it was referred to a committee of full-time staff members of the Endowment, who reviewed it along with all other applications in the research program.  Thispromptly available to any person.  On complaint, the district court of the United States . . . has jurisdiction to enjoin the agency from withholding agency records and to order the production of any agency records improperly withheld from the complainant.


7
Appellant sought the following information:


8
Records, or portions of records, which contain the refutations of each and all of the Defendants' five China specialists and which have been made by said specialists against complainant's criticisms of Western scholarship in the field of Chinese studies which were included in and were a part of Complainant's application to the Endowment and which application was known under Reference No. Application H-4344 and was dated January 22, 1970.


9
Records or portions of records, which contain all of the facts or evidence which each