Case 1:12-cv-00127-BJR Document 40 Filed 03/04/15 Page 15 of 22 that are (3) pending or reasonably anticipated.” Citizens for Responsibility & Ethics in Wash. v. Dep’t of Justice, 746 F.3d 1082, 1096 (D.C. Cir. 2014) (internal quotation marks and citations omitted). Here, Defendants assert that “disclosure would identify potential witnesses and other individuals who have cooperated with the investigation, reveal the documentary evidence and other information gathered in the course of the investigation, expose the scope and methods of the investigation, and tip-off subjects and other persons of investigative interest.” 10 Defs.’ Reply at 10. Plaintiff first argues that the release of records concerning individuals who are simply supporting WikiLeaks could not interfere with any pending or reasonably anticipated enforcement proceeding since their activity is legal and protected by the First Amendment. Pl.’s Cross-Mot. at 14. This argument is again premised on Plaintiff’s speculation that the Government’s investigation is targeting innocent WikiLeaks supporters, and, for the reasons previously discussed, the Court finds it lacks merit. Next, Plaintiff argues that litigation surrounding the Twitter Order has already disclosed to the public “[m]any of the techniques used to conduct surveillance on WikiLeaks support[er]s,” and therefore subsequent disclosure can do no further damage. Pl.’s Cross-Mot. at 17. Plaintiff asks that Defendants turn over “any records whose content has already been revealed in the litigation over the Twitter Order, and any generalized information about publicly-known surveillance practices.” Id. at 18. Finally, Plaintiff contends that the Defendants’ investigation is 10 Defendants originally stated that the release of documents would also interfere with the military prosecution of Manning. After supplemental briefing, Defendants acknowledge that Manning has been convicted and sentenced by a military tribunal but maintain that the release of these records would interfere with Manning’s appeal. The Court need not determine whether the appeal of Manning’s sentence is sufficient to warrant Exemption 7(A) protection. Regardless of whether the records interfere with Manning’s prosecution, the Court finds that the records interfere with an active, ongoing law enforcement investigation concerning the unauthorized release of classified materials on the WikiLeaks website. As such, the records qualify for Exemption 7(A) protection. 15