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it is time to fix it so that the people who need protection get it." DO) Fights To Keep Secret Memo Clearing Trump In Russia Probe. EFTA00161559 The New York TiMPi (5/25, Savage, 20.6M) reports the Administration is fighting "a legal battle to keep secret most of a Trump-era Justice Department memo related to A
jail guards who admitted to falsifying records on the night Jeffrey Epstein killed himself on their watch." The deal ends the criminal case against Tova Noel and Michael Thomas and lets them avoid prison. According to Reuters, they instead "will serve six months of supervised release and complete 100 hou
sion with handwritten labels that included the descnption: "young [name] + [name]' .bq Epstein implied that he had blackmail material when he told a New York Times reporter in 2018, off the record, that he had dirt on powerful people, including information about their sexual proclivities and recreational drug u
e of Epstein's death.13131 On November 19, 2019, federal prosecutors in New York charged Metropolitan Correctional Center guards Michael Thomas and Tova Noel with creating false records, and with conspiracy, after video footage obtained by prosecutors revealed that Epstein had, against regulation, been in
011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 11, 13, 14 New York Times Co. v. Dep't of Justice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711 (S.D.N.Y. Aug. 18, 2016) 6, 8, 10 New York Times Co. v. Nat'l Aeronautics & Spac
BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Capone Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because t
t's ongoing or prospective investigations or proceedings. See Crooke,. v. Bureau ofAlcohol, Tobacco, and Firearms, 789 F.2d 64, 67 (D.C. Cir. 1986); New York Times Co. v. Dep't opustice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711, at *7 (S.D.N.Y. Aug. 18, 2016) ("NY Times"). Moreover, Exemption 7(A) permits the c
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.
t's ongoing or prospective investigations or proceedings. See Crooke,. v. Bureau ofAlcohol, Tobacco, and Firearms, 789 F.2d 64, 67 (D.C. Cir. 1986); New York Times Co. v. Dep't opustice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711, at *7 (S.D.N.Y. Aug. 18, 2016) ("NY Times"). Moreover, Exemption 7(A) permits the c
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.
011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 11, 13, 14 New York Times Co. v. Dep't of Justice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711 (S.D.N.Y. Aug. 18, 2016) 6, 8, 10 New York Times Co. v. Nat'l Aeronautics & Spac
BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Capone Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because t
t's ongoing or prospective investigations or proceedings. See Crooke,. v. Bureau ofAlcohol, Tobacco, and Firearms, 789 F.2d 64, 67 (D.C. Cir. 1986); New York Times Co. v. Dep't opustice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711, at *7 (S.D.N.Y. Aug. 18, 2016) ("NY Times"). Moreover, Exemption 7(A) permits the c
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.
011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 11, 13, 14 New York Times Co. v. Dep't of Justice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711 (S.D.N.Y. Aug. 18, 2016) 6, 8, 10 New York Times Co. v. Nat'l Aeronautics & Spac
BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because they "in
Entities connected to both The New York Times and Tova Noel

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSONMichael Thomas
PERSON
United States
LOCATION
Prince Andrew
PERSON
George W. Bush
PERSONFederal Bureau of Prisons
ORGANIZATION
Julie K. Brown
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
New York
LOCATIONSpecial Housing Unit
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Virginia Giuffre
PERSON
Joe Biden
PERSON
Stephen Hawking
PERSON
Bill Clinton
PERSONFBI
ORGANIZATIONthe Southern District
LOCATION