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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
re expected to testify, and information and documents prepared by potential trial witnesses. See Supplemental Declaration of Russell Capone ("Supp. Capone Decl.") ¶¶ 6-14. In addition, information contained in two of the withheld Returned Records relates to the circumstances of Epstein's apparent suicide at
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
f 18 U.S.C. § 371, and one count of sex trafficking, in violation of 18 U.S.C. § 1591. (See Declaration of Russell Capone, ECF No. 22 [hereinafter "Capone Decl."], at ¶ 4.) On July 6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated at the MCC. (Id.) On July 10, 2019, Eps
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
re expected to testify, and information and documents prepared by potential trial witnesses. See Supplemental Declaration of Russell Capone ("Supp. Capone Decl.") ¶¶ 6-14. In addition, information contained in two of the withheld Returned Records relates to the circumstances of Epstein's apparent suicide at
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
f 18 U.S.C. § 371, and one count of sex trafficking, in violation of 18 U.S.C. § 1591. (See Declaration of Russell Capone, ECF No. 22 [hereinafter "Capone Decl."], at ¶ 4.) On July 6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated at the MCC. (Id.) On July 10, 2019, Eps
Entities connected to both the D.C. Circuit and Capone Decl

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Donald Trump
PERSONLeon Black
PERSOND.C. Cir
ORGANIZATION
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSON
Hopkins
ORGANIZATION
George W. Bush
PERSON
William Barr
PERSONRadcliffe
PERSON
Doherty
PERSON
Torres
PERSON
The New York Times
ORGANIZATION
Human Rights Watch
ORGANIZATIONU.S. Fed
ORGANIZATIONKubik
ORGANIZATION
THE NEW YORK TIMES COMPANY
ORGANIZATION