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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.
92), but lbJecause the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice,331 F.3d 918, 926 Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal
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.
92), but lbJecause the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice,331 F.3d 918, 926 Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal
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.
92), but lbJecause the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice,331 F.3d 918, 926 Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal
Entities connected to both Tova Noel and Nat'l Sec

Jeffrey Epstein
PERSONMichael Thomas
PERSONSpecial Housing Unit
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONNicholas Tartaglione
PERSONthe Southern District
LOCATION
United States
LOCATION
George W. Bush
PERSONAnalisa Torres
PERSON
Audrey Strauss
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATIONChristenson
PERSONJudicial Watch, Inc.
ORGANIZATIONRobbins Tire & Rubber Co.
ORGANIZATION
The New York Times
ORGANIZATION
Human Rights Watch
ORGANIZATION
Doherty
PERSONthe Tenth Circuit's
ORGANIZATION
Hopkins
ORGANIZATIONRadcliffe
PERSON