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. U.S. Dep't of Justice, 301 F. Supp. 2d 15 (D.D.C. 2004) 20 Carney v. DO.I, 19 F.3d 807 (2d Cir. 1994) 5 CIA v. Sala, 471 U.S. 159 (1985) 4 Conti v. U.S. Dep'I of Homeland Sec., No. 12 Civ. 5827 (AT), 2014 WL 1274517 (S.D.N.Y. Mar. 24, 2014) 22, 23 Crooke,- v. Bureau of Alcohol, Tobacco, an
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
. U.S. Dep't of Justice, 301 F. Supp. 2d 15 (D.D.C. 2004) 20 Carney v. DO.I, 19 F.3d 807 (2d Cir. 1994) 5 CIA v. Sala, 471 U.S. 159 (1985) 4 Conti v. U.S. Dep'I of Homeland Sec., No. 12 Civ. 5827 (AT), 2014 WL 1274517 (S.D.N.Y. Mar. 24, 2014) 22, 23 Crooke,- v. Bureau of Alcohol, Tobacco, an
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
. U.S. Dep't of Justice, 301 F. Supp. 2d 15 (D.D.C. 2004) 20 Carney v. DO.I, 19 F.3d 807 (2d Cir. 1994) 5 CIA v. Sala, 471 U.S. 159 (1985) 4 Conti v. U.S. Dep'I of Homeland Sec., No. 12 Civ. 5827 (AT), 2014 WL 1274517 (S.D.N.Y. Mar. 24, 2014) 22, 23 Crooke,- v. Bureau of Alcohol, Tobacco, an
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
Entities connected to both Conti and Nicholas Tartaglione

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Department of Justice
ORGANIZATIONLeon Black
PERSON
Prince Andrew
PERSON
South
LOCATION
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONTova Noel
PERSON
Julie K. Brown
PERSON
Donald Trump
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
the United States Government
ORGANIZATION
Alan Dershowitz
PERSONMichael Thomas
PERSON
Audrey Strauss
PERSON