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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
. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Search for Responsive Records 5 III. BOP's Withholdings Were Proper 6 IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. 22 CONCLUSION 23
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
. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Search for Responsive Records 5 III. BOP's Withholdings Were Proper 6 IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. 22 CONCLUSION 23
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
. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Search for Responsive Records 5 III. BOP's Withholdings Were Proper 6 IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. 22 CONCLUSION 23
Entities connected to both Alberto Gonzales and Responsive Records

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSONthe Southern District
LOCATION
Supreme Court
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Sarah Ferguson
PERSON
The New York Times
ORGANIZATIONGarcia
PERSON
The Washington Post
ORGANIZATION
Andrew Cuomo
PERSONCarney
PERSONShapiro
PERSONNicholas Tartaglione
PERSONSpecial Housing Unit
ORGANIZATION
Human Rights Watch
ORGANIZATIONthe Second Circuit's
ORGANIZATION
H.R.
PERSON
Audrey Strauss
PERSOND.C. Cir
ORGANIZATION