3
Shared Docs
3
Same-Page
3 / 9
Mentions
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,
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
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,
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
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,
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
Entities connected to both the Central Office and Nicholas Tartaglione

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATIONPark Row
LOCATION
Metropolitan Correctional Center
ORGANIZATION
Department of Justice
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
South
LOCATIONLeon Black
PERSONComputer Services
ORGANIZATION
United States
LOCATIONTova Noel
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATIONthe Southern District
LOCATION
the United States Government
ORGANIZATIONthe Inspector General Act
ORGANIZATIONAgoura Hills
LOCATIONCentral Office
ORGANIZATIONMichael Thomas
PERSON