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hold names like Prince Andrew, Donald Trump, Ken Starr, and Alan Dershowitz, to lesser known individual
black book"— thought to be a diary of his houseguests or people in his social circle, ranging from household names like Prince Andrew, Donald Trump, Ken Starr, and Alan Dershowitz, to lesser known individuals like film producers, fashion executives, magazine editors, and others. See, e.g., Nick Bryant, He
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
hold names like Prince Andrew, Donald Trump, Ken Starr, and Alan Dershowitz, to lesser known individual
black book"— thought to be a diary of his houseguests or people in his social circle, ranging from household names like Prince Andrew, Donald Trump, Ken Starr, and Alan Dershowitz, to lesser known individuals like film producers, fashion executives, magazine editors, and others. See, e.g., Nick Bryant, He
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
ressional intent"); see also Letter from Kenneth Starr, Esq. to John Roth, June 19, 2008 (attached as Ex
of this case fall squarely outside the heartland of those [federal] statutes — in fact, in law, and in congressional intent"); see also Letter from Kenneth Starr, Esq. to John Roth, June 19, 2008 (attached as Exhibit _J. Defense counsel also urged the USAO-SDFL to respect the long-recognized "Petite Policy,"'
ity is "at its most limited when reviewing the Executive's exercise of discretion over charging determinations." Id. In Fokker, the question before the D.C. Circuit was whether the district court had the power to decline to enter a speedy trial waiver because it believed that the terms of the DPA were too lenie
Entities connected to both Ken Starr and the D.C. Circuit

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
Jay Lefkowitz
PERSON
Department of Justice
ORGANIZATIONJack Goldberger
PERSON
United States
LOCATION
Prince Andrew
PERSONRoy Black
PERSON
Bill Clinton
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONGerald Lefcourt
PERSONthe Southern District
LOCATIONJane Doe
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSONMartin Weinberg
PERSON