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age 4 of 30 Ferguson v. FBI, 957 F.2d 1059 (2d Cir. 1992) 8 Ferguson v. FBI, No. 89 Civ. 5071 (RPP), 1995 WL 329307 (S.D.N.Y. June 1, 19 95) 5 Garcia v. U.S. Dept ofJustice, 181 F. Supp. 2d 356 (S.D.N.Y. 2002) 5 Grand Cent. P .ship v. Cuomo, 166 F.3d 473 (2d Cir. 1999) 13, 14 Hopkins v. U.S.
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
age 4 of 30 Ferguson v. FBI, 957 F.2d 1059 (2d Cir. 1992) 8 Ferguson v. FBI, No. 89 Civ. 5071 (RPP), 1995 WL 329307 (S.D.N.Y. June 1, 19 95) 5 Garcia v. U.S. Dept ofJustice, 181 F. Supp. 2d 356 (S.D.N.Y. 2002) 5 Grand Cent. P .ship v. Cuomo, 166 F.3d 473 (2d Cir. 1999) 13, 14 Hopkins v. U.S.
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
age 4 of 30 Ferguson v. FBI, 957 F.2d 1059 (2d Cir. 1992) 8 Ferguson v. FBI, No. 89 Civ. 5071 (RPP), 1995 WL 329307 (S.D.N.Y. June 1, 19 95) 5 Garcia v. U.S. Dept ofJustice, 181 F. Supp. 2d 356 (S.D.N.Y. 2002) 5 Grand Cent. P .ship v. Cuomo, 166 F.3d 473 (2d Cir. 1999) 13, 14 Hopkins v. U.S.
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
. Supp. 2d 100 (D.D.C. 2005) 14 EPA v. Mink, 410 U.S. 73 (1973) 17 Frontier Found. v. U.S Dept of Justice, 739 F.3d 1 (D.C. Cir. 2014) 17, 18 Garcia v. U.S. Dept of Justice, Office of Information and Privacy, 181 F. Supp. 2d 356 (S.D.N.Y. 2002) 15 Halpern v. F.B.I., 181 F.3d 279 (2d Cir. 1999)
withheld Returned Records relates to the circumstances of Epstein's apparent suicide attempt and could reasonably be expected to interfere with the Tartaglione prosecution. See id. ¶¶ 15-16. B. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 6 and 7(C) Each of the Returned R
elease of the Tartaglione Records could reasonably be expected to interfere with any potential penalty-phase hearing required by 18 U.S.C. § 3593 in Tartaglione. Second, plaintiff mischaracterizes the Government's legitimate and reasonable concern about interference with any potential penalty phase of Tarta
. Supp. 2d 100 (D.D.C. 2005) 14 EPA v. Mink, 410 U.S. 73 (1973) 17 Frontier Found. v. U.S Dept of Justice, 739 F.3d 1 (D.C. Cir. 2014) 17, 18 Garcia v. U.S. Dept of Justice, Office of Information and Privacy, 181 F. Supp. 2d 356 (S.D.N.Y. 2002) 15 Halpern v. F.B.I., 181 F.3d 279 (2d Cir. 1999)
withheld Returned Records relates to the circumstances of Epstein's apparent suicide attempt and could reasonably be expected to interfere with the Tartaglione prosecution. See id. ¶¶ 15-16. B. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 6 and 7(C) Each of the Returned R
elease of the Tartaglione Records could reasonably be expected to interfere with any potential penalty-phase hearing required by 18 U.S.C. § 3593 in Tartaglione. Second, plaintiff mischaracterizes the Government's legitimate and reasonable concern about interference with any potential penalty phase of Tarta
. Supp. 2d 100 (D.D.C. 2005) 14 EPA v. Mink, 410 U.S. 73 (1973) 17 Frontier Found. v. U.S Dept of Justice, 739 F.3d 1 (D.C. Cir. 2014) 17, 18 Garcia v. U.S. Dept of Justice, Office of Information and Privacy, 181 F. Supp. 2d 356 (S.D.N.Y. 2002) 15 Halpern v. F.B.I., 181 F.3d 279 (2d Cir. 1999)
withheld Returned Records relates to the circumstances of Epstein's apparent suicide attempt and could reasonably be expected to interfere with the Tartaglione prosecution. See id. ¶¶ 15-16. B. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 6 and 7(C) Each of the Returned R
elease of the Tartaglione Records could reasonably be expected to interfere with any potential penalty-phase hearing required by 18 U.S.C. § 3593 in Tartaglione. Second, plaintiff mischaracterizes the Government's legitimate and reasonable concern about interference with any potential penalty phase of Tarta
tions Division. The Independent (11/05, Cavallier), The Denver Gazette (11/05, McKee), CalCoast Times (11/05, Friedman), Hoodline Las Vegas (11/05, Garcia), KRNV (NBC-4) (11/05, Cruz), KPNX (NBC-12) (11/05, Correa), KYMA (NBC-11) (11/05, Fuhrman, Turisk), KUTV (CBS-2) (11/05, Hoffman), KGET (NBC-17) (1
-trafficking charges in July 2019, Epstein was transferred to the Metropolitan Correctional Center in Manhattan — where he shared a cell with ex-cop Nicholas Tartaglione, who was awaiting trial before being convicted on a quadruple-murder charge. Tartaglione, 57, now claims that Epstein, who died a month after being
Entities connected to both Garcia and Nicholas Tartaglione

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATION
Kenneth Marra
PERSONFederal Bureau of Prisons
ORGANIZATION
George W. Bush
PERSONLeon Black
PERSON
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONthe Southern District
LOCATION
Jay Lefkowitz
PERSONSouthern District
LOCATION
Donald Trump
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONReyes
PERSON
Julie K. Brown
PERSON
Joe Biden
PERSON