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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
ure 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 explained how SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EF
e the government has put Tartaglione front and center here, I'm entitled to probe. Let me try this: Has a single document here been withheld under Tartaglione that relates to the events of August 10th? MR. KOCHEVAR: So, in some sense, yes, in that I believe -- and I want to be careful here because I don
ething that would reflect essentially which entries, and within the entries which documents, are being withheld, at least in part, on the basis of Tartaglione? MR. KOCHEVAR: No, other than -- well, other than the descriptions of the documents given in the declarations supporting the withholding, no, we
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
ure 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 explained how SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EF
e the government has put Tartaglione front and center here, I'm entitled to probe. Let me try this: Has a single document here been withheld under Tartaglione that relates to the events of August 10th? MR. : So, in some sense, yes, in that I believe -- and I want to be careful here because I don't have
ething that would reflect essentially which entries, and within the entries which documents, are being withheld, at least in part, on the basis of Tartaglione? MR. : No, other than -- well, other than the descriptions of the documents given in the declarations supporting the withholding, no, we don't h
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
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
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
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
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
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
m" the commencement of removal proceedings. The government says this requires tossing four of the claims. But Prado said that argument ignores both the Supreme Court's 2018 decision in Jennings v. Rodriguez, "which made clear the limited scope" of the statute in question as well as "recent decisions by judges in th
f Arizona. 9 EFTA00095864 SDNY News Clips, Tuesday, August 20, 2019 White Plains Tartaglione Jail guards threatening former Epstein cell mate Nicholas Tartaglione: lawyer NY Post By Emily Saul 8/20/19 Jeffrey Epstein's former Manhattan cell mate says guards at the lockup have been threatening him since the
e been the 66-year-old's first suicide attempt, on July 23. The two were separated before Epstein hanged himself on Aug. 10. "The clear message Mr. Tartaglione has received is that if he conveys information about the facility or about [Epstein's] recent suicide, there will be a price to pay," Barket's lette
m" the commencement of removal proceedings. The government says this requires tossing four of the claims. But Prado said that argument ignores both the Supreme Court's 2018 decision in Jennings v. Rodriguez, "which made clear the limited scope" of the statute in question as well as "recent decisions by judges in th
r 2:19-mj-01179, in the U.S. District Court for the District of Arizona. White Plains Tartaglione Jail guards threatening former Epstein cell mate Nicholas Tartaglione: lawyer NY Post By Emily Saul 8/20/19 Jeffrey Epstein's former Manhattan cell mate says guards at the lockup have been threatening him since the
e been the 66-year-old's first suicide attempt, on July 23. The two were separated before Epstein hanged himself on Aug. 10. "The clear message Mr. Tartaglione has received is that if he conveys information about the facility or about [Epstein's] recent suicide, there will be a price to pay," Barket's lette
at the Seventh Circuit puts few limits on conspiracy charges. Black noted that if a split does materialize, it could make an attractive question for the U.S. Supreme Court to weigh in on, given the court's interest in statutory interpretation and harmonizing criminal law in the circuits. The Hoskins case, with all the
Epstein to get himself transferred to a different facility after he was denied bail on the sex-trafficking charges, officials said at the time. But Tartaglione's lawyer Bruce Barket told NBC News that the day before Epstein's death, officials at the MCC informed him in an email that the internal investigati
at the Seventh Circuit puts few limits on conspiracy charges. Black noted that if a split does materialize, it could make an attractive question for the U.S. Supreme Court to weigh in on, given the court's interest in statutory interpretation and harmonizing criminal law in the circuits. The Hoskins case, with all the
Epstein to get himself transferred to a different facility after he was denied bail on the sex-trafficking charges, officials said at the time. But Tartaglione's lawyer Bruce Barket told NBC News that the day before Epstein's death, officials at the MCC informed him in an email that the internal investigati
Entities connected to both Supreme Court and Nicholas Tartaglione

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