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nds of investigatory records .. . would generally interfere with enforcement proceedings." Robbins Tire, 437 U.S. at 236 (quotation marks omitted); Radcliffe v. IRS, 536 F. Supp. 2d 423, 437 (S.D.N.Y. 2008). The government need only demonstrate a "rational link" between the requested public disclosure and
aintiff stating that it was withholding records pursuant to exemptions 3, 5, 6, 7(A), 7(C), 7(D), and 7(E). These documents are not described on the Vaughn Index because that would reveal the number of pages being withheld categorically, and therefore, they are not being specifically discussed in this
other words, Exemption 7(A) in not included in the face of the documents that were processed prior to July 2019, but the Exemption is noted on the Vaughn Index. Seidel Decl. ¶ 48, Ex. EE. After Epstein's arrest, the FBI confirmed that the additional release of responsive material could negatively imp
2020) 9 Neb. Press Ass 'n v. Stuart, 427 U.S. 539 (1976) 4, 5 ii EFTA00105601 Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 4 of 15 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 2 Schiller v. City of New York, 2007 U.S. Dist. LEXIS 4285 (S.D.N.Y. Jan. 19, 2007) 8 Seife v. Dep'
eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re
2020) 9 Neb. Press Ass 'n v. Stuart, 427 U.S. 539 (1976) 4, 5 ii EFTA00071611 Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 4 of 15 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 2 Schiller v. City of New York, 2007 U.S. Dist. LEXIS 4285 (S.D.N.Y. Jan. 19, 2007) 8 Seife v. Dep'
eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re
2020) 9 Neb. Press Ass 'n v. Stuart, 427 U.S. 539 (1976) 4, 5 ii EFTA00088562 Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 4 of 15 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 2 Schiller v. City of New York, 2007 U.S. Dist. LEXIS 4285 (S.D.N.Y. Jan. 19, 2007) 8 Seife v. Dep'
eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re
Entities connected to both Radcliffe and Timothy Dalton Vaughn

Jeffrey Epstein
PERSON
Julie K. Brown
PERSON
United States
LOCATION
Andrew Cuomo
PERSONNicholas Tartaglione
PERSON
Human Rights Watch
ORGANIZATION
THE NEW YORK TIMES COMPANY
ORGANIZATION
Alberto Gonzales
PERSONHomeland Sec
ORGANIZATION
The New York Times
ORGANIZATIONShapiro
PERSOND.C. Cir
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Stephen Hawking
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
George W. Bush
PERSONFederal Bureau of Prisons
ORGANIZATION
Supreme Court
ORGANIZATION
Audrey Strauss
PERSON