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ngtime associates Darren K. Indyke and Richard D. Kahn, whom Epstein named as executors of his will. Se
s in jail in Florida, as well as individuals who remained close to him until the time of his death, such as longtime associates Darren K. Indyke and Richard D. Kahn, whom Epstein named as executors of his will. See Skyler Swisher & Marc Freeman, Jeffrey Epstein's Special Treatment in Jail Was Far More Lenient T
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
ngtime associates Darren K. Indyke and Richard D. Kahn, whom Epstein named as executors of his will. Se
s in jail in Florida, as well as individuals who remained close to him until the time of his death, such as longtime associates Darren K. Indyke and Richard D. Kahn, whom Epstein named as executors of his will. See Skyler Swisher & Marc Freeman, Jeffrey Epstein's Special Treatment in Jail Was Far More Lenient T
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
fendants’ provision of material support to al-Qaeda was knowing or, at the very least, reckless. The reasonableness of this inference is supported by the D.C. Circuit’s judicial review of habeas petitions brought on behalf of Guantanamo Bay detainees. See, e.g., Al Alwi v. Obama, 653 F.3d 11 (D.C. Cir. 2011); Uthman
Page: HOUSE_OVERSIGHT_023396 →ury regarding the designations of Yousef Nada-related entities); R.1762, Ex. 5, p. 10 (October 22, 2003 Testimony of Former National Security Advisor Richard A. Clarke before the U.S. Senate Banking Committee). 2 JA3838-39, 4365, 6208-09, 6236. So JA3724. a1 The pleadings allege that al Rajhi Bank senior of
Page: HOUSE_OVERSIGHT_023413 →Entities connected to both Richard Kahn and the D.C. Circuit

Jeffrey Epstein
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Martha Stewart
PERSON
Alfredo Rodriguez
PERSONLeon Black
PERSON
Prince Andrew
PERSON
John Brennan
PERSON
Alan Dershowitz
PERSON
George Mitchell
PERSON
George W. Bush
PERSON
Eric Trump
PERSON
Woody Allen
PERSON
Donald Trump
PERSON
Ghislaine Maxwell
PERSON
Wilbur Ross
PERSON
United States
LOCATION
FedEx
ORGANIZATION
Samantha Power
PERSON
Joe Biden
PERSON