Epstein Secrets

§ 552(b)(4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice's ("Department") consideration of this matter. We note further that, since the Confidential Material constitutes investigatory records obtained by t

ot be subject to production. If you have any questions, do not hesitate to contact me at the above-referenced number. Enclosure See, e.g., NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978). 2 See Dept of Justice v. Reports Comm. For Freedom of Press, 489 U.S. 749 (1989). 3 See. e.g., Chrysler Corp. v. Brown, 441

§ 552(bX4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice's ("Department") consideration of this matter. We note further that, since the Confidential Material constitutes investigatory records obtained by t

iates, representatives, agents, auditors, or counsel and (b) employees of the Department (or any other government agency). 2 3 See, e.g., NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978). See Dept of Justice v. Reports Comm. For Freedom of Press, 489 U.S. 749 (1989). See, e.g., Chrysler Corp. v. Brown, 441 U.S.

' In October 2020, the parties reached an agreement to resolve plaintiff's challenge to the adequacy of BOP's search for records, pursuant to which the Department of Justice Office of the Inspector General ("OIG") returned to BOP electronic copies of records BOP had provided to OIG in connection with the investigation into the

07 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or. July 1, 2011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 11, 13, 14 New York Times Co. v. Dep't of Justice, No. 1

l, Epstein Was Left Alone for Hours; Guard Was Substitute, N.Y. Times (Aug. 12, 2019), https://nyti.ms/2F9mXzs. The Federal Bureau of Investigation, the Department of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has suggested that Epstein was "killed

Raza v. Dep't ofJustice, 411 F.3d 350 (2d Cir. 2005) 6 iv EFTA00071627 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 5 of 29 NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214, 227 (1978) 9, 10 NRDC v. EPA, 2019 U.S. Dist. LEXIS 124353 (S.D.N.Y. July 25, 2019) 20 Pratt v. Webster, 673 F.2d 408 (D.C. Cir

§ 552(b)(4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice's ("Department") consideration of this matter. We note further that, since the Confidential Material constitutes investigatory records obtained by t

ephone the undersigned rather than rely upon the United States mail for such notice. If the Department is not satisfied that the See, e.g., NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978). 2 See Dept of Justice v. Reports Comm. For Freedom of Press, 489 U.S. 749 (1989). 3 See, e.g., Chrysler Corp. v. Brown, 441

' In October 2020, the parties reached an agreement to resolve plaintiff's challenge to the adequacy of BOP's search for records, pursuant to which the Department of Justice Office of the Inspector General ("OIG") returned to BOP electronic copies of records BOP had provided to OIG in connection with the investigation into the

07 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or. July 1, 2011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 11, 13, 14 New York Times Co. v. Dep't of Justice, No. 1

l, Epstein Was Left Alone for Hours; Guard Was Substitute, N.Y. Times (Aug. 12, 2019), https://nyti.ms/2F9mXzs. The Federal Bureau of Investigation, the Department of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has suggested that Epstein was "killed

Raza v. Dep't ofJustice, 411 F.3d 350 (2d Cir. 2005) 6 iv EFTA00088704 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 5 of 29 NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214, 227 (1978) 9, 10 NRDC v. EPA, 2019 U.S. Dist. LEXIS 124353 (S.D.N.Y. July 25, 2019) 20 Pratt v. Webster, 673 F.2d 408 (D.C. Cir

§ 552(bX4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice's ("Department") consideration of this matter. We note further that, since the Confidential Material constitutes investigatory records obtained by t

tial Material; or (2) refer to any conference, meeting, telephone conversation, or interview between (a) our client's current or See, e.g., NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978). 2 See Dept of Justice v. Reports Comm. For Freedom of Press, 489 U.S. 749 (1989). 3 See, e.g., Chrysler Corp. v. Brown, 441

§ 552(b)(4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice's ("Department") consideration of this matter. We note further that, since the Confidential Material constitutes investigatory records obtained by th

activities of JPMorgan, its employees, and its clients and their employees and agents, and not to the activities of any federal See, e.g., NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978). Confidential Treatment Requested by JP Morgan Chase JPM-SDNY-CL-007-0002 EFTA00096343 WILMERHALE September 2, 2020 Page

' In October 2020, the parties reached an agreement to resolve plaintiff's challenge to the adequacy of BOP's search for records, pursuant to which the Department of Justice Office of the Inspector General ("OIG") returned to BOP electronic copies of records BOP had provided to OIG in connection with the investigation into the

07 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or. July 1, 2011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 11, 13, 14 New York Times Co. v. Dep't of Justice, No. 1