destruction of evidence, or the creation of false alibis. Goodrich Corp. v. EPA, 593 F.Supp.2d 184, 193-94 (D.D.C.2009). However, courts also recognize that examples of “interference” include “prematurely revealing the Government’s case” before formal discovery in law enforcement proceedings or revealing the direction, scope, and limits of the investigation. Barney, 618 F.2d at 1273; see also Ranter v. IRS, 433 F.Supp. 812, 818 (N.D.Ill.1977). Analysis Sufficiency of the Declaration Defendant offers the Declaration of Mark Smith, the EPA Region 7 Air Permitting and Compliance Branch Chief, in support of its motion for summary judgment. The sworn declarations from Smith provide adequate additional information to explain why the documents should be exempt. See Miller, 779 F.2d at 1387 (<HOLDING>); Gannon Intern., Ltd., 684 F.3d at 792
holding that an agency carries its burden of proof by providing affidavits to explain why documents are subject to an exemption holding that a party failed in meeting its burden that documents were work product because the party resisting discovery failed to present affidavits or other evidentiary support for its contention that the documents were prepared in anticipation of litigation holding that pursuant to the best evidence rule trial testimony relying on documents was inadmissible without submission of such documents or an explanation as to why the documents were unavailable recognizing that to meet its burden the government may need to explain the exemptions relevance in addition to simply statfing which exemption the agency claims for each withheld document holding one who claims tax exemption has burden of showing entitlement to exemption