Epstein Secrets

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.

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

1 7.) An autopsy confirmed that he had committed suicide by hanging himself. (Id.) Since then, charges have been brought against Michael Thomas and Tova Noel, both correctional officers on duty at the SHU the night of Epstein's death, who allegedly failed to perform prisoner counts and then signed false

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

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.

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

1 7.) An autopsy confirmed that he had committed suicide by hanging himself. (Id.) Since then, charges have been brought against Michael Thomas and Tova Noel, both correctional officers on duty at the SHU the night of Epstein's death, who allegedly failed to perform prisoner counts and then signed false

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

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.

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