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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
BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Capone Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because t
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
1 7.) An autopsy confirmed that he had committed suicide by hanging himself. (Id.) Since then, charges have been brought against Michael Thomas and Tova Noel, both correctional officers on duty at the SHU the night of Epstein's death, who allegedly failed to perform prisoner counts and then signed false
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
BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Capone Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because t
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
1 7.) An autopsy confirmed that he had committed suicide by hanging himself. (Id.) Since then, charges have been brought against Michael Thomas and Tova Noel, both correctional officers on duty at the SHU the night of Epstein's death, who allegedly failed to perform prisoner counts and then signed false
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
BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because they "in
Entities connected to both the D.C. Circuit and Tova Noel

Jeffrey Epstein
PERSONMichael Thomas
PERSONFederal Bureau of Prisons
ORGANIZATION
Department of Justice
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Prince Andrew
PERSONFBI
ORGANIZATIONLeon Black
PERSON
Julie K. Brown
PERSONNicholas Tartaglione
PERSON
United States
LOCATION
Geoffrey S. Berman
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATIONSouthern District
LOCATION
Donald Trump
PERSON
William Barr
PERSON
New York
LOCATION
George W. Bush
PERSON