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f 25 reasonable explanations are closely tethered to the purpose of Exemption 5 and indeed are similar in kind and specificity to anticipated harms the D.C. Circuit has held support withholdings under Exemption 5. See Elec. Frontier Found., 739 F.3d at 6, 13. D. BOP Properly Withheld Information Pursuant to FO
gically and plausibly explains the relationship between the documents and those pending criminal cases. Plaintiff also relies on a decision by Judge Torres in Noel, but this decision and subsequent proceedings in that case cut against plaintiff's position. The Government has already disclosed to the No
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
ey had not done so. (The focus of those prosecutions is on the false certifications they are alleged to have signed.) A June 9, 2020 order by Judge Torres, denying Thomas's motion to compel "disclosure of `reports generated by 7 The Government's vague allegations of the impact of disclosure on juror te
f 25 reasonable explanations are closely tethered to the purpose of Exemption 5 and indeed are similar in kind and specificity to anticipated harms the D.C. Circuit has held support withholdings under Exemption 5. See Elec. Frontier Found., 739 F.3d at 6, 13. D. BOP Properly Withheld Information Pursuant to FO
gically and plausibly explains the relationship between the documents and those pending criminal cases. Plaintiff also relies on a decision by Judge Torres in Noel, but this decision and subsequent proceedings in that case cut against plaintiff's position. The Government has already disclosed to the No
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
ey had not done so. (The focus of those prosecutions is on the false certifications they are alleged to have signed.) A June 9, 2020 order by Judge Torres, denying Thomas's motion to compel "disclosure of `reports generated by 7 The Government's vague allegations of the impact of disclosure on juror te
f 25 reasonable explanations are closely tethered to the purpose of Exemption 5 and indeed are similar in kind and specificity to anticipated harms the D.C. Circuit has held support withholdings under Exemption 5. See Elec. Frontier Found., 739 F.3d at 6, 13. D. BOP Properly Withheld Information Pursuant to FO
gically and plausibly explains the relationship between the documents and those pending criminal cases. Plaintiff also relies on a decision by Judge Torres in Noel, but this decision and subsequent proceedings in that case cut against plaintiff's position. The Government has already disclosed to the No
Entities connected to both the D.C. Circuit and Torres

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Prince Andrew
PERSON
Julie K. Brown
PERSON
Donald Trump
PERSON
Ghislaine Maxwell
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSON
George W. Bush
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
Michigan
LOCATION
Joe Biden
PERSON
Michael Cohen
PERSON
Supreme Court
ORGANIZATION
George Mitchell
PERSON
Bloomberg L.P.
ORGANIZATION
Marc Rich
PERSON
Stephen Hawking
PERSON