Epstein Secrets

vacy, 181 F. Supp. 2d 356 (S.D.N.Y. 2002) 15 Halpern v. F.B.I., 181 F.3d 279 (2d Cir. 1999) 15 Hopkins v. HUD, 929 F.2d 81 (2d Cir. 1991) 12 Human Rights Watch v. BOP, No. 13-CV-7360 (JP0), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) 7, 21 EFTA00071586 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Pag

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

N.Y. 2002) 5 Grand Cent. P .ship v. Cuomo, 166 F.3d 473 (2d Cir. 1999) 13, 14 Hopkins v. U.S. Dept of Housing and Urban Dev., 929 F.2d 81 13 Human Rights Watch v BOP, No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) 9, 10, 11, 20 In re County of Erie, 473 F.3d 413 (2d Cir. 2 007) 14, 17

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.

nny Crim. Investigation Command, 742 F. Supp. 2d 68 (D.D.C. 2010) 9 Hopkins v. U.S. Dep't of Hous. & Urban Dev., 929 F.2d 81 (2d Cir. 1991) 19 Human Rights Watch v. Dep't ofJustice & Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) 9 Judicial Watch, Inc. v. U.S. Dep't of Commer

1 7.) An autopsy confirmed that he had committed suicide by hanging himself. (Id.) Since then, charges have been brought against Michael Thomas and Tova Noel, both correctional officers on duty at the SHU the night of Epstein's death, who allegedly failed to perform prisoner counts and then signed false

N.Y. 2002) 5 Grand Cent. P .ship v. Cuomo, 166 F.3d 473 (2d Cir. 1999) 13, 14 Hopkins v. U.S. Dept of Housing and Urban Dev., 929 F.2d 81 13 Human Rights Watch v BOP, No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) 9, 10, 11, 20 In re County of Erie, 473 F.3d 413 (2d Cir. 2 007) 14, 17

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.

vacy, 181 F. Supp. 2d 356 (S.D.N.Y. 2002) 15 Halpern v. F.B.I., 181 F.3d 279 (2d Cir. 1999) 15 Hopkins v. HUD, 929 F.2d 81 (2d Cir. 1991) 12 Human Rights Watch v. BOP, No. 13-CV-7360 (JP0), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) 7, 21 EFTA00088607 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Pag

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

nny Crim. Investigation Command, 742 F. Supp. 2d 68 (D.D.C. 2010) 9 Hopkins v. U.S. Dep't of Hous. & Urban Dev., 929 F.2d 81 (2d Cir. 1991) 19 Human Rights Watch v. Dep't ofJustice & Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) 9 Judicial Watch, Inc. v. U.S. Dep't of Commer

1 7.) An autopsy confirmed that he had committed suicide by hanging himself. (Id.) Since then, charges have been brought against Michael Thomas and Tova Noel, both correctional officers on duty at the SHU the night of Epstein's death, who allegedly failed to perform prisoner counts and then signed false

N.Y. 2002) 5 Grand Cent. P .ship v. Cuomo, 166 F.3d 473 (2d Cir. 1999) 13, 14 Hopkins v. U.S. Dept of Housing and Urban Dev., 929 F.2d 81 13 Human Rights Watch v BOP, No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) 9, 10, 11, 20 In re County of Erie, 473 F.3d 413 (2d Cir. 2 007) 14, 17

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.

vacy, 181 F. Supp. 2d 356 (S.D.N.Y. 2002) 15 Halpern v. F.B.I., 181 F.3d 279 (2d Cir. 1999) 15 Hopkins v. HUD, 929 F.2d 81 (2d Cir. 1991) 12 Human Rights Watch v. BOP, No. 13-CV-7360 (JP0), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) 7, 21 EFTA00099600 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Pag

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