Epstein Secrets

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

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF

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

Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR S

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

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF

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

Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR S

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

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF