Epstein Secrets

under which [each] deletion is made"). Failure to meet that burden requires disclosure of the requested documents. See Nat'l Council of La Raza v. Dep't of Justice, 411 F.3d 350, 355-56 (2d Cir. 2005). A court reviews de novo an agency's decision to withhold information from the public. See 5 U.S.C. § 552(a)(4

rcement agency, any BOP 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 Righ

under which [each] deletion is made"). Failure to meet that burden requires disclosure of the requested documents. See Nat'l Council of La Raza v. Dep't of Justice, 411 F.3d 350, 355-56 (2d Cir. 2005). A court reviews de novo an agency's decision to withhold information from the public. See 5 U.S.C. § 552(a)(4

rcement agency, any BOP 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 Righ

is reasonable in a particular case) [hereinafter Dep't of Justice, Attorney General Guidelines]; see also U.S. Dep'

ght of the conference report on Rule 16, compelling disclosure of witness names before trial appears inconsistent with the federal rules. And even if the Ninth Circuit's approach was valid at the time Armstrong was decided, such an approach is no longer valid in light of the CVRA. Rule 57(b) only provides a basis for