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

C. Cir. 1998) 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

't of Justice, 726 F. Supp. 851 (D.D.C. 1989), rejected general descriptions of wiretapping and related surveillance methods as too publicly known. Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078- TC, 2011 WL 2619538 (D. Or. July 1, 2011), rejected the withholding of a video of a prison riot and dis

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

mmerce, 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.

1989) (rejecting the government's invocation of Exemption 7(E) where there was "nothing exceptional or secret about the techniques it described"); Kubik v. U.S. Fed. Bureau of Prisons, 2011 U.S. Dist. LEXIS 71300, at *34 (D. Or. July 1, 2011) (holding that tactical maneuvers used during prison riots

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

C. Cir. 1998) 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

't of Justice, 726 F. Supp. 851 (D.D.C. 1989), rejected general descriptions of wiretapping and related surveillance methods as too publicly known. Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078- TC, 2011 WL 2619538 (D. Or. July 1, 2011), rejected the withholding of a video of a prison riot and dis

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

mmerce, 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.

1989) (rejecting the government's invocation of Exemption 7(E) where there was "nothing exceptional or secret about the techniques it described"); Kubik v. U.S. Fed. Bureau of Prisons, 2011 U.S. Dist. LEXIS 71300, at *34 (D. Or. July 1, 2011) (holding that tactical maneuvers used during prison riots

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

C. Cir. 1998) 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

't of Justice, 726 F. Supp. 851 (D.D.C. 1989), rejected general descriptions of wiretapping and related surveillance methods as too publicly known. Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078- TC, 2011 WL 2619538 (D. Or. July 1, 2011), rejected the withholding of a video of a prison riot and dis