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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
998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or. July 1, 2011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? 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
375 F. Supp. 3d 93 (D.D.C. 2019) 20 Knight First Amendment Inst. v. U.S. Dep't of Homeland Sec., 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 21 Kubik v. U.S. Fed. Bureau of Prisons, 2011 U.S. Dist. LEXIS 71300 (D. Or. July 1, 2011) 21 Lawyers Conun. for Human Rights v. INS, 721 F. Supp. 552 (S.D.N.Y. 1989)
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
998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or. July 1, 2011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? 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
375 F. Supp. 3d 93 (D.D.C. 2019) 20 Knight First Amendment Inst. v. U.S. Dep't of Homeland Sec., 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 21 Kubik v. U.S. Fed. Bureau of Prisons, 2011 U.S. Dist. LEXIS 71300 (D. Or. July 1, 2011) 21 Lawyers Conun. for Human Rights v. INS, 721 F. Supp. 552 (S.D.N.Y. 1989)
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
998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or. July 1, 2011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? A
Entities connected to both the D.C. Circuit and U.S. Fed

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIOND.C. Cir
ORGANIZATION
Donald Trump
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Hopkins
ORGANIZATION
Julie K. Brown
PERSON
Human Rights Watch
ORGANIZATIONRobbins Tire & Rubber Co.
ORGANIZATIONFavish
PERSON
Torres
PERSON
George W. Bush
PERSONRadcliffe
PERSONKubik
ORGANIZATION
The New York Times
ORGANIZATIONJudicial Watch, Inc.
ORGANIZATION
Doherty
PERSON