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F 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. FOIA and the Summ
f the TRULINCS system, as Epstein apparently did not send or receive emalls on that system, see id.1 37. In addition to these searches conducted by the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland,
F 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. FOIA and the Summ
f the TRULINCS system, as Epstein apparently did not send or receive emalls on that system, see id.1 37. In addition to these searches conducted by the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland,
F 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. FOIA and the Summ
f the TRULINCS system, as Epstein apparently did not send or receive emalls on that system, see id.1 37. In addition to these searches conducted by the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland,
Entities connected to both Michael Thomas and the Central Office

Jeffrey Epstein
PERSONTova Noel
PERSONFederal Bureau of Prisons
ORGANIZATION
Department of Justice
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
South
LOCATIONFBI
ORGANIZATIONLeon Black
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONNicholas Tartaglione
PERSONAgoura Hills
LOCATION
George W. Bush
PERSONthe Southern District
LOCATIONNew York Field Office
LOCATIONthe Inspector General Act
ORGANIZATIONAnalisa Torres
PERSON
Justin Trudeau
PERSON
Audrey Strauss
PERSON