ed States, 817 F. Supp. 2d 1337, 1342-45 (SD. Fla. 2011) (recognizing that 1/8 U.S.C. § 3771(a) can apply before formal charges are filed); Jordan v. Dep't of Justice, 173 F. Supp. 3d 44, 52 (S.D.N.Y. 2016) (citing In re Dean, 527 F.3d at 395); United States v. BP Prod. N. Am., Inc., No. H-07-434, 2008 WL 501321, a

is reasonable in a particular case) [hereinafter Dep't of Justice, Attorney General Guidelines]; see also U.S. Dep'

istration of Justice and the Enforcement of Laws: Dep't of Justice Oversight Hearing Before the S. Judiciary Comm.,

under which [each] deletion is made"). Failure to meet that burden requires disclosure of the requested documents. See Nat'l Council of La Raza v. Dep't of Justice, 411 F.3d 350, 355-56 (2d Cir. 2005). A court reviews de novo an agency's decision to withhold information from the public. See 5 U.S.C. § 552(a)(4

s been filed." 23 EFTA00078857 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 24 of 54 In Sieverding v. United States Dep't of Justice, 693 F. Supp. 2d 93 (D.D.C. 2010), the district court discussed a series of claims brought by the Sieverdings, a husband and wife so well known to

under which [each] deletion is made"). Failure to meet that burden requires disclosure of the requested documents. See Nat'l Council of La Raza v. Dep't of Justice, 411 F.3d 350, 355-56 (2d Cir. 2005). A court reviews de novo an agency's decision to withhold information from the public. See 5 U.S.C. § 552(a)(4

ell with sex trafficking offenses under 18 U.S.C. § 1591 (Counts Five and Six) and has dramatically expanded the timeframe of the Mann Act 2 Ex. A (Dep't of Justice, Office of Professional Responsibility, Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of its 2006-

will get everything"; that you were "assured" there was more; and that the country would eventually see "the full Epstein files."6 1 Memorandum from Dep't of Justice and Fed. Bureau of Investigation on Review of Investigative Holdings Relating to Jeffrey Epstein (Jul. 7, 2025), available at https://www.justice.go

will get everything"; that you were "assured" there was more; and that the country would eventually see "the full Epstein files.' 1 Memorandum from Dep't of Justice and Fed. Bureau of Investigation on Review of Investigative Holdings Relating to Jeffrey Epstein (Jul. 7, 2025), available at https://www.justice.go

District of Florida Alex 'Indictment, United States v. Epstein, No. 19 Crim. 490 (S.D.N.Y. July 2, 2019), ECF No. 2. 2 Id. at I. 3 Press Release, Dep't of Justice, U.S. Attorney's Office, S.D.N.Y., Jeffrey Epstein Charged In Manhattan Federal Court With Sex Trafficking Of Minors: Alleged Conduct Occurred in bo

V-MARRAMOHNSON EFTA00208059 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04107/2011 Page 24 of 54 In Sieverding v. United States Dep't of Justice, 693 F. Supp. 2d 93 (D.D.C. 2010), the district court discussed a series of claims brought by the Sieverdings, a husband and wife so well known to

ted States v. John Doe Inc. I, 481 U.S. 102, 109 n.5 (1987); United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983); Lance v. United States Dep't of Justice (In re Grand Jury Investigation), 610 F.2d 202, 213 (5th Cir. 1980). A ruling unsealing the non-prosecution agreement and addendum would not disclo