Epstein Secrets

2019). In support of its withholding under Exemption 7(A), the BOP has cited two pending prosecutions—one of Nicholas Tartaglione and the other of Tova Noel and Michael Thomas—as proceedings that could be disrupted by the disclosure of the withheld documents. As discussed at argument, however, the BOP's

argument, the Court directs the BOP to provide to the Court, for in camera review, the withheld records identified in Exhibit 1 to the supplemental Christenson declaration. Dkt. 39-1; see also 5 U.S.C. § 552(a)(4)(B); Intl Bhd. of Elec. Workers v. NLRB, 845 F.2 1177, 1180 (2d Cir. 1988) (propriety of in cam

ally, the government has demonstrated a rational link between disclosure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government

9KNEWM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I'd like to respectfully direct this Court to the Christenson declaration submitted by the government, and that's Document No. 24, specifically, paragraphs 49(a) through 49(s). In these paragraphs, the governm

ally, the government has demonstrated a rational link between disclosure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government

9KNEWM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I'd like to respectfully direct this Court to the Christenson declaration submitted by the government, and that's Document No. 24, specifically, paragraphs 49(a) through 49(s). In these paragraphs, the governm

BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Capone Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because t

applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8-10. Specifically, the Christenson and Supplemental Christenson declarations explain how the records were compiled to help BOP take "proactive steps designed to prevent criminal activ

of 30 TABLE OF 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.

termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00071562 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req

of 30 TABLE OF 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.

termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00075445 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req

BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Capone Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because t

applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8-10. Specifically, the Christenson and Supplemental Christenson declarations explain how the records were compiled to help BOP take "proactive steps designed to prevent criminal activ

of 30 TABLE OF 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.

termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00088679 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req

r of nolle prosequi against Epstein. See Nolle Prosequi, Dkt. No. 52, United States v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019,

ts withheld in full or in part under Exemption 7(A), including those reflected on the index prepared by BOP and attached to the declaration of Kara Christenson (the "BOP index"). All of these records fall within the scope of Exemption 7(A). 14. Public disclosure of the records withheld under Exemption 7(A)

paragraphs 1 through 27 of this Indictment as though fully set forth herein. 32. On or about August 9, 2019, in the Southern District of New York, TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, an

r of nolle prosequi against Epstein. See Nolle Prosequi, Dkt. No. 52, United States v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019,

ts withheld in full or in part under Exemption 7(A), including those reflected on the index prepared by BOP and attached to the declaration of Kara Christenson (the "BOP index"). All of these records fall within the scope of Exemption 7(A). 14. Public disclosure of the records withheld under Exemption 7(A)

paragraphs 1 through 27 of this Indictment as though fully set forth herein. 32. On or about August 9, 2019, in the Southern District of New York, TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, an