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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
nd withholding of the Returned Records have not substantially changed the legal issues to be resolved by the Court. The Supplemental Declaration of Nicole McFarland and the Supplemental Declaration of Kara Christenson also correct and clarify certain information discovered or determined since the Government's A
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
l (`OIG') on or about August 22, 2019," and therefore "the BOP is no longer in possession of the log books" (Christenson Decl. 1 13; Declaration of Nicole McFarland, ECF No. 23 [hereinafter "McFarland Decl."], at ¶ 8). But, as BOP concedes, BOP received a FOIA request from The Times on August 13, 2019, seeking
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
nd withholding of the Returned Records have not substantially changed the legal issues to be resolved by the Court. The Supplemental Declaration of Nicole McFarland and the Supplemental Declaration of Kara Christenson also correct and clarify certain information discovered or determined since the Government's A
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
l (`OIG') on or about August 22, 2019," and therefore "the BOP is no longer in possession of the log books" (Christenson Decl. 1 13; Declaration of Nicole McFarland, ECF No. 23 [hereinafter "McFarland Decl."], at ¶ 8). But, as BOP concedes, BOP received a FOIA request from The Times on August 13, 2019, seeking
Entities connected to both the D.C. Circuit and Nicole McFarland

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Supreme Court
ORGANIZATIOND.C. Cir
ORGANIZATIONNicholas Tartaglione
PERSON
Donald Trump
PERSONLeon Black
PERSON
George W. Bush
PERSON
The New York Times
ORGANIZATION
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Hopkins
ORGANIZATIONJudicial Watch, Inc.
ORGANIZATIONTova Noel
PERSONRadcliffe
PERSONRobbins Tire & Rubber Co.
ORGANIZATION
Doherty
PERSONthe Southern District
LOCATION
Human Rights Watch
ORGANIZATION