Epstein Secrets

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

20-cv-00833-PAE Document 41 Filed 01/15/21 Page 3 of 25 TABLE OF AUTHORITIES Page(s) Cases ACLU v. DHS, 243 F. Supp. 3d 393 (S.D.N.Y. 2017) 19 Albuquerque Pub. Co. v. U.S. Dept ofJustice, 726 F. Supp. 851 (D.D.C. 1989) 19 Allard K Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (

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

20-cv-00833-PAE Document 41 Filed 01/15/21 Page 3 of 25 TABLE OF AUTHORITIES Page(s) Cases ACLU v. DHS, 243 F. Supp. 3d 393 (S.D.N.Y. 2017) 19 Albuquerque Pub. Co. v. U.S. Dept ofJustice, 726 F. Supp. 851 (D.D.C. 1989) 19 Allard K Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (

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 Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because they "in

20-cv-00833-PAE Document 41 Filed 01/15/21 Page 3 of 25 TABLE OF AUTHORITIES Page(s) Cases ACLU v. DHS, 243 F. Supp. 3d 393 (S.D.N.Y. 2017) 19 Albuquerque Pub. Co. v. U.S. Dept ofJustice, 726 F. Supp. 851 (D.D.C. 1989) 19 Allard K Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (