3
Shared Docs
3
Same-Page
3 / 3
Mentions
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
y communications about how to interact with the public may be subject to the deliberative process privilege and concluding, including by relying on the Second Circuit's decision in ACLU, 844 F.3d at 133, that "[a's long as communications are pre-decisional and deliberative, internal agency communications about publ
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
y communications about how to interact with the public may be subject to the deliberative process privilege and concluding, including by relying on the Second Circuit's decision in ACLU, 844 F.3d at 133, that "[a's long as communications are pre-decisional and deliberative, internal agency communications about publ
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
y communications about how to interact with the public may be subject to the deliberative process privilege and concluding, including by relying on the Second Circuit's decision in ACLU, 844 F.3d at 133, that "[a's long as communications are pre-decisional and deliberative, internal agency communications about publ
Entities connected to both Michael Thomas and the Second Circuit's

Jeffrey Epstein
PERSONTova Noel
PERSONFederal Bureau of Prisons
ORGANIZATION
Department of Justice
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Metropolitan Correctional Center
ORGANIZATION
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATIONFBI
ORGANIZATIONLeon Black
PERSON
Geoffrey S. Berman
PERSON
George W. Bush
PERSON
South
LOCATIONSouthern District
LOCATION
Virginia Giuffre
PERSON
Stephen Hawking
PERSON
Scarlett Johansson
PERSON