Epstein Secrets

dan, 668 F.3d at 1193-94 (noting that an alternative approach, a "rational nexus test" has been adopted by the Third, Ninth, and D.C. Circuits). In Human Rights Watch v. FBI, No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did n

aintiff stating that it was withholding records pursuant to exemptions 3, 5, 6, 7(A), 7(C), 7(D), and 7(E). These documents are not described on the Vaughn Index because that would reveal the number of pages being withheld categorically, and therefore, they are not being specifically discussed in this

other words, Exemption 7(A) in not included in the face of the documents that were processed prior to July 2019, but the Exemption is noted on the Vaughn Index. Seidel Decl. ¶ 48, Ex. EE. After Epstein's arrest, the FBI confirmed that the additional release of responsive material could negatively imp

mmigration Servs., 2020 U.S. Dist. LEXIS 134482 (S.D.N.Y. July 29, 2020) 2 Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473 (2d Cir. 1999). 8 Human Rights Watch v. DOJ Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) 2 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 375 F. Su

eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re

mmigration Servs., 2020 U.S. Dist. LEXIS 134482 (S.D.N.Y. July 29, 2020) 2 Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473 (2d Cir. 1999). 8 Human Rights Watch v. DOJ Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) 2 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 375 F. Su

eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re

mmigration Servs., 2020 U.S. Dist. LEXIS 134482 (S.D.N.Y. July 29, 2020) 2 Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473 (2d Cir. 1999). 8 Human Rights Watch v. DOJ Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) 2 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 375 F. Su

eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re