Case 1:14-cv-09763-VM Document 44 Filed 08/28/15 Page 7 of 35 had demonstrated a "reasonable likelihood that of in the Attachment targets of particular ite entirety law enforcement target of could disclosure inform investigations, current including the Government's ongoing the inquiry in this action, as well as, potentially future targets, as to certain types of records and other materials the Government seeks through NSLs." Id. otherwise national at 317. security In so investigations finding, the Court innocuous bits and pieces of data, together, could inform current and employing noted that when pieced potentially future targets of the investigation as to the types of records and other materials sought by the government. After the Court poe __"I:y_, decided Merril 1 and the Government reached an agreement under which Merrill could identify himself Ashcroft, No. as the 04-cv-2614 recipient (S.D.N.Y.), of the Dkt. NSL. No. (Doe 204 ("July 30, 2010 Stip. and Order of Dismissal").) And in 2014, parties reached an agreement that discuss most aspects of the NSL, its target, but he could ~O.~ Merrill could v. the freely including the identity of discuss the Attachment identifying certain types of records the FBI sought, except for those disclosure portions in Doe IV. of the Attachment (Doe__ ~~E.!!9!9.ft, - 7 - identified No. for 04-cv-2614

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