Epstein Secrets

482, the government need not "identify a specific decision" made by the agency to establish the predecisional nature of a particular record. NLRB v. Sears, Roebuck,421 U.S. 132, 151 n.18 (1975); accord Tigue v. U.S. Dep't ofJustice, 312 F.3d 70, 80 (2d Cir. 2002). Rather, so long as the document "was

.4 (2d Cir. 1985), "even commonly known procedures may be protected from disclosure if the disclosure could reduce or nullify their effectiveness," Judicial Watch, Inc. v. U.S. Dep't of Commerce, 337 F. Supp. 2d 146, 181 (D.D.C. 2004). Exemption 7(E) sets a "low bar for the agency to justify withholding," Blackwell

which governmental decisions and policies are formulated." Dep't of Interior v. Klamath Water Users Protective Ass'n, 532 U.S. I, 8 (2001) (quoting Sears, 421 U.S. at 150). But the records withheld are largely not akin to advisory opinions or policy recommendations and do not relate to any policymakin

d 81 (2d Cir. 1991) 19 Human Rights Watch v. Dep't ofJustice & Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) 9 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 375 F. Supp. 3d 93 (D.D.C. 2019) 20 Knight First Amendment Inst. v. U.S. Dep't of Homeland Sec., 407 F. Supp. 3d 334 (

which governmental decisions and policies are formulated." Dep't of Interior v. Klamath Water Users Protective Ass'n, 532 U.S. I, 8 (2001) (quoting Sears, 421 U.S. at 150). But the records withheld are largely not akin to advisory opinions or policy recommendations and do not relate to any policymakin

d 81 (2d Cir. 1991) 19 Human Rights Watch v. Dep't ofJustice & Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) 9 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 375 F. Supp. 3d 93 (D.D.C. 2019) 20 Knight First Amendment Inst. v. U.S. Dep't of Homeland Sec., 407 F. Supp. 3d 334 (