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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
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
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
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
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
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 Michael Thomas and Nat'l Sec

Jeffrey Epstein
PERSONTova Noel
PERSONSpecial Housing Unit
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONNicholas Tartaglione
PERSON
United States
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSONAnalisa Torres
PERSONGarcia
PERSON
Audrey Strauss
PERSONChristenson
PERSON
The Washington Post
ORGANIZATION
THE NEW YORK TIMES COMPANY
ORGANIZATION
Andrew Cuomo
PERSON
The New York Times
ORGANIZATIONHector Gutierrez
PERSONMartin Luna
PERSONMiguel Luna
PERSON
Sarah Ferguson
PERSON