Epstein Secrets

lawyers on Epstein's legal team, including Reid Weingarten, Martin G. Weinberg, and Michael Miller, have be

ssected. The names of 15 EFTA00071644 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 22 of 29 lawyers on Epstein's legal team, including Reid Weingarten, Martin G. Weinberg, and Michael Miller, have been widely publicized. See, e.g., Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show H

P records qualify as law enforcement records. But, as the Government cannot help but acknowledge, courts in this circuit—like the Ninth Circuit and the D.C. Circuit—have squarely rejected that per se approach, instead requiring a rational nexus to enforcement of a federal law. See Human Rights Watch v. Dep't of

lawyers on Epstein's legal team, including Reid Weingarten, Martin G. Weinberg, and Michael Miller, have be

ssected. The names of 15 EFTA00088721 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 22 of 29 lawyers on Epstein's legal team, including Reid Weingarten, Martin G. Weinberg, and Michael Miller, have been widely publicized. See, e.g., Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show H

P records qualify as law enforcement records. But, as the Government cannot help but acknowledge, courts in this circuit—like the Ninth Circuit and the D.C. Circuit—have squarely rejected that per se approach, instead requiring a rational nexus to enforcement of a federal law. See Human Rights Watch v. Dep't of

ir. 1995) 11 iii EFTA00103712 United States v. Scharton, 285 U.S. 518 (1932) 5, 9 United States v. Valle, 807 F.3d 508 (2d Cir. 2015) 15 Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) passim Statutes 18 U.S.C. § 2422 2, 16, 17 18 U.S.C. § 2423 2, 17 18 U.S.C. § 3237(a) 13 18 U.

entails" the identified conduct can it be said to be an "offense involving" that conduct. Kawashima, 565 U.S. at 484. In United States v. Morgan, the D.C. Circuit used this approach in interpreting 18 U.S.C. § 3237(a), a venue statute that applies to "[a]ny offense involving the use of the mails, transportati

relevant to the employment relationship. Thus, as the D.C. Circuit has observed, ‘‘an employer’s right to silence is

st be rejected. Similarly, the statement in U.S. Postal Service, 241 N.L.R.B. 141, 152 (1979), regarding affirmative notice obligations is limited to Weingarten rights, and, in any event, does not suggest that notice of NLRA rights may never be required. Communications Workers v. Beck, above, violates Sectio