Epstein Secrets

ictment, Dkt. No. 2, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). Epstein was arrested on July 6, 2019, and thereafter incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone

onably foreseeable at the time of the withholding. See, e.g.,Kay v. F.C.C., 976 F. Supp. 23, 37-38 (D.D.C. 1997) (citing N.L.R.B. v. Robbins Tire & Rubber Co.,437 U.S. 214, 220 (1978)). The government's burden to establish the applicability of Exemption 7(A) is not high; the government need only show that

RELIMINARY STATEMENT Financier Jeffrey Epstein's suicide in August 2019, and subsequent revelations about what Attorney General William Barr called the Metropolitan Correctional Center's (MCC) "failure to adequately secure this prisoner," led to widespread calls for accountability and reform. Ali Watkins, Katie Benner & Danielle Ivo

0-cv-00833-PAE Document 27 Filed 09/10/20 Page 16 of 29 interfere with enforcement proceedings. See 5 U.S.C. § 552(b)(7)(A); NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214, 236 (1978); see also, e.g., Radcliffe v. IRS, 536 F. Supp. 2d 423, 437 (S.D.N.Y. 2008) ("Affidavits must contain more than mere concl

ictment, Dkt. No. 2, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). Epstein was arrested on July 6, 2019, and thereafter incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone

onably foreseeable at the time of the withholding. See, e.g.,Kay v. F.C.C., 976 F. Supp. 23, 37-38 (D.D.C. 1997) (citing N.L.R.B. v. Robbins Tire & Rubber Co.,437 U.S. 214, 220 (1978)). The government's burden to establish the applicability of Exemption 7(A) is not high; the government need only show that

RELIMINARY STATEMENT Financier Jeffrey Epstein's suicide in August 2019, and subsequent revelations about what Attorney General William Barr called the Metropolitan Correctional Center's (MCC) "failure to adequately secure this prisoner," led to widespread calls for accountability and reform. Ali Watkins, Katie Benner & Danielle Ivo

0-cv-00833-PAE Document 27 Filed 09/10/20 Page 16 of 29 interfere with enforcement proceedings. See 5 U.S.C. § 552(b)(7)(A); NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214, 236 (1978); see also, e.g., Radcliffe v. IRS, 536 F. Supp. 2d 423, 437 (S.D.N.Y. 2008) ("Affidavits must contain more than mere concl

ictment, Dkt. No. 2, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). Epstein was arrested on July 6, 2019, and thereafter incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone

onably foreseeable at the time of the withholding. See, e.g.,Kay v. F.C.C., 976 F. Supp. 23, 37-38 (D.D.C. 1997) (citing N.L.R.B. v. Robbins Tire & Rubber Co.,437 U.S. 214, 220 (1978)). The government's burden to establish the applicability of Exemption 7(A) is not high; the government need only show that