Epstein Secrets

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

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

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

und his neck. (Id. 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

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

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

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

und his neck. (Id. 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

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

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