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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
isclosure of the Records Would Interfere with Pending Criminal Proceedings BOP properly withheld the Tartaglione Records' under Exemption 7(A). The Capone and Supplemental Capone Declarations explain why release of the Tartaglione Records would interfere with the Tartaglione prosecution, wherein the G
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
de, and his mental health; and (7) emails relating to Epstein's death, investigations into Epstein's death, and GOP's response to Epstein's death. (Capone Dec111 12-26.) Those records bear little relationship to the prosecutions of Noel and Thomas for making false statements and for conspiring to defr
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
isclosure of the Records Would Interfere with Pending Criminal Proceedings BOP properly withheld the Tartaglione Records' under Exemption 7(A). The Capone and Supplemental Capone Declarations explain why release of the Tartaglione Records would interfere with the Tartaglione prosecution, wherein the G
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
de, and his mental health; and (7) emails relating to Epstein's death, investigations into Epstein's death, and GOP's response to Epstein's death. (Capone Dec111 12-26.) Those records bear little relationship to the prosecutions of Noel and Thomas for making false statements and for conspiring to defr
Entities connected to both the D.C. Circuit and Capone

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Supreme Court
ORGANIZATION
Donald Trump
PERSONLeon Black
PERSOND.C. Cir
ORGANIZATION
Alan Dershowitz
PERSONSecond Circuit
ORGANIZATION
Prince Andrew
PERSON
Julie K. Brown
PERSONNicholas Tartaglione
PERSONthe Southern District
LOCATIONTova Noel
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATION
Hopkins
ORGANIZATION
George W. Bush
PERSON
Torres
PERSON
Human Rights Watch
ORGANIZATIONJudicial Watch, Inc.
ORGANIZATION