3
Shared Docs
2
Same-Page
5 / 3
Mentions
treatment of Epstein, including psychological treatment, and Epstein's contacts with people who are not associated with BOP. 5 The charges against Tartaglione have nothing to do with Epstein. Tartaglione is charged with one count of conspiracy to distribute narcotics, four counts of intentional killing in
s of confinement at the facility. As a result, those conditions of Tartaglione's confinement at the MCC may be relevant to the penalty phase of the Tartaglione case. The theory falls far short of what the Government needs to show to overcome the presumption of openness that is central to FOIA. The theory w
ORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Perloff-Giles The New York Times Company Legal Department Counsel for Plaintiff EFTA00071624 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 2 of 29
treatment of Epstein, including psychological treatment, and Epstein's contacts with people who are not associated with BOP. 5 The charges against Tartaglione have nothing to do with Epstein. Tartaglione is charged with one count of conspiracy to distribute narcotics, four counts of intentional killing in
s of confinement at the facility. As a result, those conditions of Tartaglione's confinement at the MCC may be relevant to the penalty phase of the Tartaglione case. The theory falls far short of what the Government needs to show to overcome the presumption of openness that is central to FOIA. The theory w
ORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Perloff-Giles The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Phone: 212-556-4031 Facsimile: (212) 556-4634 Email: mccraw@n
nger exists on the backup system because of a technical error. See Letter from the Government dated January 9, 2020, Dkt. No. 182, United States v. Tartaglione, No. 16-cr-832 (KMK). 30. SUICIDE ATTEMPT AND SUICIDE RECORDS - Based on the experience and training of myself and other staff involved in searchi
Page: EFTA00015373 →.S. Department of Justice Office of Information Policy Suite 11050 1425 New York Avenue, NW Washington, DC 20530.0001 Telephone: (202) 514-3642 Alexandra Perloff-Giles, Esq. The New York Times Company 620 8th Avenue Re: Appeal No. DOJ-AP-2020-000123 New York, NY 10018 Request No. 2019-05665 aperloffgiles@nyti
Page: EFTA00015410 →Entities connected to both Nicholas Tartaglione and Alexandra Perloff-Giles

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Geoffrey S. Berman
PERSONLeon Black
PERSONTova Noel
PERSON
George W. Bush
PERSON
United States
LOCATION
Julie K. Brown
PERSON
Donald Trump
PERSONFBI
ORGANIZATION
William Barr
PERSONMichael Thomas
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATION
Harry Reid
PERSON
Mark Epstein
PERSON
Alberto Gonzales
PERSON
Human Rights Watch
ORGANIZATION