Epstein Secrets

tuart, 427 U.S. 539, 565 (1976)). Nor is withholding the records the only measure that courts can use to mitigate the adverse effects of publicity. Neb. Press Ass 'n, 427 U.S. at 563-64 (enumerating methods to mitigate the effect of pre- trial publicity including: "change of [a trial] venue," "postponement of the

e documents appear to be largely factual in nature and therefore are not subject to a blanket withholding under Exemption 5. (Pl.'s Br., at 19); see Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473, 482 (2d Cir. 1999) ("Purely factual material not reflecting the agency's deliberative process is not protected.")

tuart, 427 U.S. 539, 565 (1976)). Nor is withholding the records the only measure that courts can use to mitigate the adverse effects of publicity. Neb. Press Ass 'n, 427 U.S. at 563-64 (enumerating methods to mitigate the effect of pre- trial publicity including: "change of [a trial] venue," "postponement of the

e documents appear to be largely factual in nature and therefore are not subject to a blanket withholding under Exemption 5. (Pl.'s Br., at 19); see Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473, 482 (2d Cir. 1999) ("Purely factual material not reflecting the agency's deliberative process is not protected.")

tuart, 427 U.S. 539, 565 (1976)). Nor is withholding the records the only measure that courts can use to mitigate the adverse effects of publicity. Neb. Press Ass 'n, 427 U.S. at 563-64 (enumerating methods to mitigate the effect of pre- trial publicity including: "change of [a trial] venue," "postponement of the

e documents appear to be largely factual in nature and therefore are not subject to a blanket withholding under Exemption 5. (Pl.'s Br., at 19); see Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473, 482 (2d Cir. 1999) ("Purely factual material not reflecting the agency's deliberative process is not protected.")