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and Michael Thomas On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and Thomas, they repeatedly failed to
. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Search for Responsive Records 5 III. BOP's Withholdings Were Proper 6 IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. 22 CONCLUSION 23
and Michael Thomas On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and Thomas, they repeatedly failed to
. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Search for Responsive Records 5 III. BOP's Withholdings Were Proper 6 IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. 22 CONCLUSION 23
and Michael Thomas On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and Thomas, they repeatedly failed to
. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Search for Responsive Records 5 III. BOP's Withholdings Were Proper 6 IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. 22 CONCLUSION 23
Entities connected to both Special Housing Unit and Responsive Records

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONNicholas Tartaglione
PERSONTova Noel
PERSONMichael Thomas
PERSON
United States
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATION
Alberto Gonzales
PERSONAnalisa Torres
PERSONthe Acting United States
ORGANIZATION
Audrey Strauss
PERSON
Supreme Court
ORGANIZATION
Sarah Ferguson
PERSONGarcia
PERSON
Urbano Santiago
PERSON
Andrew Cuomo
PERSON
The Washington Post
ORGANIZATIONChristenson
PERSON