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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.
y communications about how to interact with the public may be subject to the deliberative process privilege and concluding, including by relying on the Second Circuit's decision in ACLU, 844 F.3d at 133, that "[a's long as communications are pre-decisional and deliberative, internal agency communications about publ
2 mentions1 same-page
Page ?Same page
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.
y communications about how to interact with the public may be subject to the deliberative process privilege and concluding, including by relying on the Second Circuit's decision in ACLU, 844 F.3d at 133, that "[a's long as communications are pre-decisional and deliberative, internal agency communications about publ
2 mentions1 same-page
Page ?Same page
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.
y communications about how to interact with the public may be subject to the deliberative process privilege and concluding, including by relying on the Second Circuit's decision in ACLU, 844 F.3d at 133, that "[a's long as communications are pre-decisional and deliberative, internal agency communications about publ
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Mutual Connections (230)
Entities connected to both Tova Noel and the Second Circuit's
Jeffrey Epstein
PERSON196 w/ Tova·47 w/ the
MT
Michael Thomas
PERSON133 w/ Tova·3 w/ the
Federal Bureau of Prisons
ORGANIZATION88 w/ Tova·4 w/ the
Special Housing Unit
ORGANIZATION86 w/ Tova·5 w/ the
Department of Justice
ORGANIZATION73 w/ Tova·11 w/ the
Metropolitan Correctional Center
ORGANIZATION67 w/ Tova·5 w/ the
Ghislaine Maxwell
PERSON29 w/ Tova·41 w/ the
United States
LOCATION24 w/ Tova·41 w/ the
Julie K. Brown
PERSON32 w/ Tova·31 w/ the
Prince Andrew
PERSON42 w/ Tova·13 w/ the
the Southern District
LOCATION28 w/ Tova·25 w/ the
FBI
ORGANIZATION40 w/ Tova·10 w/ the
South
LOCATION42 w/ Tova·2 w/ the
LB
Leon Black
PERSON29 w/ Tova·13 w/ the
NT
Nicholas Tartaglione
PERSON36 w/ Tova·5 w/ the
Southern District of New York
ORGANIZATION21 w/ Tova·19 w/ the
Geoffrey S. Berman
PERSON34 w/ Tova·4 w/ the
Southern District
LOCATION28 w/ Tova·8 w/ the
Supreme Court
ORGANIZATION5 w/ Tova·27 w/ the
George W. Bush
PERSON15 w/ Tova·17 w/ the