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quests pursuant to Department of Justice regulations (known as Touhy regulations). See Christenson DecL ¶ 50; see also United States ex reL Touhy v. Roger:, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. As confidential communications between attorneys and a client for the purpose of obtaining and pro
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.
quests pursuant to Department of Justice regulations (known as Touhy regulations). See Christenson DecL ¶ 50; see also United States ex reL Touhy v. Roger:, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. As confidential communications between attorneys and a client for the purpose of obtaining and pro
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.
quests pursuant to Department of Justice regulations (known as Touhy regulations). See Christenson DecL ¶ 50; see also United States ex reL Touhy v. Roger:, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. As confidential communications between attorneys and a client for the purpose of obtaining and pro
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.
Entities connected to both Roger and Tova Noel

Jeffrey Epstein
PERSONMichael Thomas
PERSONSpecial Housing Unit
ORGANIZATION
Department of Justice
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Prince Andrew
PERSON
Joi Ito
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSONFBI
ORGANIZATION
Lesley Groff
PERSON
Julie K. Brown
PERSONNicholas Tartaglione
PERSON
Geoffrey S. Berman
PERSONthe Southern District
LOCATION
United States
LOCATION
Donald Trump
PERSON
George W. Bush
PERSON
Stephen Hawking
PERSON
Prince Charles
PERSON