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ned to prevent criminal activity and maintain security." Id. at *5 (quotation marks and ellipses omitted); see also Opinion and Order, Dkt. No. 59, Gonzalez v. ICE, No. 19-cv-2911 (JGK) (S.D.N.Y. July 29, 2020), slip op. at 27-28 (requiring a "rational nexus" between withheld records and an agency's law
overnment need only show that "disclosure of particular kinds 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 "rat
hese categories and subcategories of documents could improperly influence witnesses and jurors. Under the approach ratified by the Supreme Court in Robbins Tire, FBI properly withheld these records under Exemption 7(A). C. The FBI's Application of Exemption 7(A) Was Timely It is well-established law that a
ned to prevent criminal activity and maintain security." Id. at *5 (quotation marks and ellipses omitted); see also Opinion and Order, Dkt. No. 59, Gonzalez v. ICE, No. 19-cv-2911 (JGK) (S.D.N.Y. July 29, 2020), slip op. at 27-28 (requiring a "rational nexus" between withheld records and an agency's law
overnment need only show that "disclosure of particular kinds 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 2 For the records withheld in full by B
hese categories and subcategories of documents could improperly influence witnesses and jurors. Under the approach ratified by the Supreme Court in Robbins Tire, BOP properly withheld these records under Exemption 7(A). B. BOP Properly Withheld Records and Information Pursuant to FOIA Exemption 5 i. Exempt
ned to prevent criminal activity and maintain security." Id. at *5 (quotation marks and ellipses omitted); see also Opinion and Order, Dkt. No. 59, Gonzalez v. ICE, No. 19-cv-2911 (JGK) (S.D.N.Y. July 29, 2020), slip op. at 27-28 (requiring a "rational nexus" between withheld records and an agency's law
overnment need only show that "disclosure of particular kinds 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 2 For the records withheld in full by B
hese categories and subcategories of documents could improperly influence witnesses and jurors. Under the approach ratified by the Supreme Court in Robbins Tire, BOP properly withheld these records under Exemption 7(A). B. BOP Properly Withheld Records and Information Pursuant to FOIA Exemption 5 i. Exempt
ned to prevent criminal activity and maintain security." Id. at *5 (quotation marks and ellipses omitted); see also Opinion and Order, Dkt. No. 59, Gonzalez v. ICE, No. 19-cv-2911 (JGK) (S.D.N.Y. July 29, 2020), slip op. at 27-28 (requiring a "rational nexus" between withheld records and an agency's law
overnment need only show that "disclosure of particular kinds 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 2 For the records withheld in full by B
hese categories and subcategories of documents could improperly influence witnesses and jurors. Under the approach ratified by the Supreme Court in Robbins Tire, BOP properly withheld these records under Exemption 7(A). B. BOP Properly Withheld Records and Information Pursuant to FOIA Exemption 5 i. Exempt
Entities connected to both Alberto Gonzales and Robbins Tire

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PERSON
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LOCATION
George W. Bush
PERSONthe Southern District
LOCATION
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ORGANIZATION
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ORGANIZATIONGarcia
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PERSONCarney
PERSONShapiro
PERSONNicholas Tartaglione
PERSONSpecial Housing Unit
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Audrey Strauss
PERSON
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PERSONthe Second Circuit's
ORGANIZATIONRadcliffe
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