155However, in so far as the possibility of relying on general presumptions has the effect not only of restricting the fundamental principle of transparency laid down in Article 11 TEU, Article 15 TFEU and Regulation No 1049/2001, but also, and of necessity, of limiting in practice access to the documents at issue, the use of such presumptions must be founded on solid and convincing reasons (see, to that effect, Opinion of Advocate General Wathelet in Joined Cases LPN and Finland v Commission, C‑514/11 P and C‑605/11 P, EU:C:2013:528, point 57).
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