Epstein Secrets

19 20 21 22 23 24 25 restraints too and gag orders, that there are, as your Honor knows, times when even though what I just said about the Supreme Court's view of gag orders and prior restraints and so forth, that in the Don King case, in the Second Circuit, the circuit upheld restrictions there on wh

ally, the government has demonstrated a rational link between disclosure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government

19 20 21 22 23 24 25 restraints too and gag orders, that there are, as your Honor knows, times when even though what I just said about the Supreme Court's view of gag orders and prior restraints and so forth, that in the Don King case, in the Second Circuit, the circuit upheld restrictions there on wh

ally, the government has demonstrated a rational link between disclosure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government

ns at issue, each of these categories and subcategories of documents could improperly influence witnesses and jurors. Under the approach ratified by the Supreme Court in Robbins Tire, BOP properly withheld these records under Exemption 7(A). B. BOP Properly Withheld Records and Information Pursuant to FOIA Exempti

of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I.

ns at issue, each of these categories and subcategories of documents could improperly influence witnesses and jurors. Under the approach ratified by the Supreme Court in Robbins Tire, BOP properly withheld these records under Exemption 7(A). B. BOP Properly Withheld Records and Information Pursuant to FOIA Exempti

of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I.

ns at issue, each of these categories and subcategories of documents could improperly influence witnesses and jurors. Under the approach ratified by the Supreme Court in Robbins Tire, BOP properly withheld these records under Exemption 7(A). B. BOP Properly Withheld Records and Information Pursuant to FOIA Exempti

of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I.