Epstein Secrets

o BOP FOIA Officer (Aug. 12, 2019) 8 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And H

orrectional Setting — Lessons Learned (Dec 2011) 21 FOIA Request from Paul D. Kamenar, Counsel for NLPC, to BOP FOIA Officer (Aug. 12, 2019) 8 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019) 15 EFTA00071628 Case 1:20-cv-

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

Brown v. Maxwell, — F.3d — (2019) 2019 WL 2814839 Only the Westlaw citation is currently available. United States Court of Appeals, Second Circuit. J

n v. Maxwell, — F.3d — (2019) 2019 WL 2814839 Only the Westlaw citation is currently available. United States Court of Appeals, Second Circuit. Julie BROWN, Miami Herald Company, Intervenors-Appellants, v. Ghislaine MAXWELL, Defendant-Appellee, v. MM. Plaintiff-Appellee. . r owitz, Michael Cern

ates v. Amodeois We have since clarified, however, that this sentence was based on a "quotation from a partial concurrence and partial dissent in the D.C. Circuit ... [and] is thus not the considered decision of either this court or the D.C. Circuit."17 In fact, we have expressly rejected the proposition tha

o BOP FOIA Officer (Aug. 12, 2019) 8 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And H

orrectional Setting — Lessons Learned (Dec 2011) 21 FOIA Request from Paul D. Kamenar, Counsel for NLPC, to BOP FOIA Officer (Aug. 12, 2019) 8 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019) 15 EFTA00088705 Case 1:20-cv-

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

489 U.S. 726 (1989) 15 Food and Drug Admin. v. Brown & Williamson Tobacco Corp., 529 U.S. 120 (2000)

entails" the identified conduct can it be said to be an "offense involving" that conduct. Kawashima, 565 U.S. at 484. In United States v. Morgan, the D.C. Circuit used this approach in interpreting 18 U.S.C. § 3237(a), a venue statute that applies to "[a]ny offense involving the use of the mails, transportati

ity.") (citation omitted); Liggett Group Inc., v. Brown & Williamson Tobacco Corp. , 116 F.R.D. 205, 210

01386 , 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City , 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privileged. Nor does the general p

DC, Daniel T. Hartnett, Royal B. Martin, Martin Brown & Sullivan, Ltd., Chicago, IL, for Interested Par

, public disclosure of the carve out names will not reveal nimmatter[s] before the grand juryem within the protection of Rule 6(e). FN5 FN5. Indeed, the D.C. Circuit in In re Sealed Case went on to note with approval the Fifth Circuit's observation that % em[a] discussion of actions taken by government attorneys

lity.") (citation omitted); Liggett Group Inc., I Brown & Williamson Tobacco Corp. , 116 F.R.D. 205, 210

-01386 , 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States I Legal Servs. for New York City , 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privileged. Nor does the general p

ty.") (citation omitted); Liggett Group Inc., v. Brown & Williamson Tobacco Corp., 116 F.R.D. 205, 210 (

91-01386, 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City, 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privileged. Nor does the general

relevant to the employment relationship. Thus, as the D.C. Circuit has observed, ‘‘an employer’s right to silence is

agency “may not exercise its authority ‘in a manner that is inconsistent with the administrative structure that Congress enacted into law.’’’ FDA v. Brown & Williamson Tobacco Corp., 529 U.S. 120, 125(2000) (quoting ETSI Pipeline Project v. Missouri, 484 U.S. 495, 517(1988)). Further, the statute at issue