2 . Both the district court and Respondents claim that the Fifth Circuit has recognized only an executive privilege, not a law enforcement privilege. Consequently, they argue, Petitioner’s claim to a law enforcement privilege is not supported by this Circuit’s law. However, they provide no basis for why the privilege should be labeled "executive” instead of “law enforcement" or how that label impacts the substance of the privilege. Like other circuits using the law enforcement moniker, the purpose of the privilege in the Fifth Circuit is to protect from release documents relating to an ongoing criminal investigation. The term “law enforcement privilege” ap pears to have evolved over time out of the same concept. Compare Black v. Sheraton, 564 F.2d 531, 545-46 (D.C.Cir.1977) (<HOLDING>) with Landry v. FDIC, 204 F.3d 1125, 1135
recognizing the law enforcement investigatoiy privilege holding that state attorney general as member of executive department may assert claim of executive privilege recognizing in the context of discussing executive privilege that law enforcement documents disclosing investigative techniques or sources should be minimized recognizing privilege recognizing as a matter of law executive privilege for governor