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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
nment 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 has clearly explain
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
nment 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 has clearly explain
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
F 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. FOIA and the Summ
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
F 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. FOIA and the Summ
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
F 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. FOIA and the Summ
Entities connected to both Supreme Court and Michael Thomas

Jeffrey Epstein
PERSON
Donald Trump
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONLeon Black
PERSON
Julie K. Brown
PERSON
George W. Bush
PERSON
Prince Andrew
PERSON
Scarlett Johansson
PERSON
Wilbur Ross
PERSON
Ghislaine Maxwell
PERSON
Virginia Giuffre
PERSON
Joe Biden
PERSON
Bill Clinton
PERSON
Colorado
LOCATIONthe Southern District
LOCATION
Michael Cohen
PERSON
Stephen Hawking
PERSON
Bloomberg L.P.
ORGANIZATION
Samantha Power
PERSON