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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
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
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
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
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
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
Entities connected to both Roger and Michael Thomas

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