Epstein Secrets

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

that would also show that they were compiled for law enforcement purposes. So, overall, I think the point is that even if the Court does not adopt the Tenth Circuit's per-se rule, much of the insights or thinking of the Tenth Circuit is still going to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA0010578

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

that would also show that they were compiled for law enforcement purposes. So, overall, I think the point is that even if the Court does not adopt the Tenth Circuit's per-se rule, much of the insights or thinking of the Tenth Circuit is still going to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA0010570

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

No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se rule for BOP records, and followed a "practical approach," observing that "[t]he ordinary understanding of the term [law enforcement] includ

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

No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se rule for BOP records, and followed a "practical approach," observing that "[t]he ordinary understanding of the term [law enforcement] includ

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

No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se rule for BOP records, and followed a "practical approach," observing that "[t]he ordinary understanding of the term [law enforcement] includ