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gically and plausibly explains the relationship between the documents and those pending criminal cases. Plaintiff also relies on a decision by Judge Torres in Noel, but this decision and subsequent proceedings in that case cut against plaintiff's position. The Government has already disclosed to the No
20-cv-00833-PAE Document 41 Filed 01/15/21 Page 3 of 25 TABLE OF AUTHORITIES Page(s) Cases ACLU v. DHS, 243 F. Supp. 3d 393 (S.D.N.Y. 2017) 19 Albuquerque Pub. Co. v. U.S. Dept ofJustice, 726 F. Supp. 851 (D.D.C. 1989) 19 Allard K Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (
gically and plausibly explains the relationship between the documents and those pending criminal cases. Plaintiff also relies on a decision by Judge Torres in Noel, but this decision and subsequent proceedings in that case cut against plaintiff's position. The Government has already disclosed to the No
20-cv-00833-PAE Document 41 Filed 01/15/21 Page 3 of 25 TABLE OF AUTHORITIES Page(s) Cases ACLU v. DHS, 243 F. Supp. 3d 393 (S.D.N.Y. 2017) 19 Albuquerque Pub. Co. v. U.S. Dept ofJustice, 726 F. Supp. 851 (D.D.C. 1989) 19 Allard K Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (
gically and plausibly explains the relationship between the documents and those pending criminal cases. Plaintiff also relies on a decision by Judge Torres in Noel, but this decision and subsequent proceedings in that case cut against plaintiff's position. The Government has already disclosed to the No
20-cv-00833-PAE Document 41 Filed 01/15/21 Page 3 of 25 TABLE OF AUTHORITIES Page(s) Cases ACLU v. DHS, 243 F. Supp. 3d 393 (S.D.N.Y. 2017) 19 Albuquerque Pub. Co. v. U.S. Dept ofJustice, 726 F. Supp. 851 (D.D.C. 1989) 19 Allard K Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (
Entities connected to both Torres and Albuquerque Pub. Co.

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATION
Audrey Strauss
PERSON
Homeland Security
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONGarcia
PERSONNicholas Tartaglione
PERSON
The New York Times
ORGANIZATIONTova Noel
PERSON
Human Rights Watch
ORGANIZATIONAction Review
ORGANIZATIONJudicial Watch, Inc.
ORGANIZATIONKubik
ORGANIZATIONFreedom of the Press
ORGANIZATIONRobbins Tire & Rubber Co.
ORGANIZATIONFavish
PERSON
Larry Summers
PERSONU.S. Fed
ORGANIZATION