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port of its withholding under Exemption 7(A), the BOP has cited two pending prosecutions—one of Nicholas Tartaglione and the other of Tova Noel and Michael Thomas—as proceedings that could be disrupted by the disclosure of the withheld documents. As discussed at argument, however, the BOP's declarations in sup
argument, the Court directs the BOP to provide to the Court, for in camera review, the withheld records identified in Exhibit 1 to the supplemental Christenson declaration. Dkt. 39-1; see also 5 U.S.C. § 552(a)(4)(B); Intl Bhd. of Elec. Workers v. NLRB, 845 F.2 1177, 1180 (2d Cir. 1988) (propriety of in cam
nment has demonstrated a rational link between disclosure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government has clearly explain
9KNEWM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I'd like to respectfully direct this Court to the Christenson declaration submitted by the government, and that's Document No. 24, specifically, paragraphs 49(a) through 49(s). In these paragraphs, the governm
nment has demonstrated a rational link between disclosure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government has clearly explain
9KNEWM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I'd like to respectfully direct this Court to the Christenson declaration submitted by the government, and that's Document No. 24, specifically, paragraphs 49(a) through 49(s). In these paragraphs, the governm
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
termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00071562 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req
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
termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00075445 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req
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
termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00088679 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req
/20, Staff Writer). California Man Sentenced for Distributing Meth, One Hundred Thousand Fentanyl Pills KELO (CW-11) (11/20, Johnson) reported that Michael Thomas, a 51-year-old California man, has been sentenced to 21 years in prison for conspiring to distribute meth and fentanyl. According to the article, Th
taining that the indictment was properly reviewed by the grand jury. Additional reporting was provided by NPR (11/20, Melton), New York Post (11/20, Christenson), The New York Times (11/20, French), and Bloomberg (11/20, Strohm). Continued Reporting: An Bt-Olympian, a Violent Drug Ring and a $15 Million Rew
icers responded to an emergency call and found Epstein on the floor of his cell with a strip of bedsheet around his neck. See Noel Indictment 1 11. Michael Thomas, a correctional officer at the MCC and one of the defendants in the Noel case, was one of the MCC officials who responded to this incident. See id.
Page: EFTA00015439 →ts withheld in full or in part under Exemption 7(A), including those reflected on the index prepared by BOP and attached to the declaration of Kara Christenson (the "BOP index"). All of these records fall within the scope of Exemption 7(A). 14. Public disclosure of the records withheld under Exemption 7(A)
Page: EFTA00015442 →icers responded to an emergency call and found Epstein on the floor of his cell with a strip of bedsheet around his neck. See Noel Indictment 1 11. Michael Thomas, a correctional officer at the MCC and one of the defendants in the Noel case, was one of the MCC officials who responded to this incident. See id.
Page: EFTA00031026 →ts withheld in full or in part under Exemption 7(A), including those reflected on the index prepared by BOP and attached to the declaration of Kara Christenson (the "BOP index"). All of these records fall within the scope of Exemption 7(A). 14. Public disclosure of the records withheld under Exemption 7(A)
Page: EFTA00031029 →Entities connected to both Michael Thomas and Christenson

Jeffrey Epstein
PERSONTova Noel
PERSON
Department of Justice
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Prince Andrew
PERSON
Donald Trump
PERSON
Julie K. Brown
PERSONLeon Black
PERSONFBI
ORGANIZATION
Joe Biden
PERSON
Virginia Giuffre
PERSON
Bloomberg L.P.
ORGANIZATION
United States
LOCATION
Ghislaine Maxwell
PERSON
Geoffrey S. Berman
PERSON
South
LOCATIONNicholas Tartaglione
PERSONReyes
PERSON