Epstein Secrets

E Document 42 Filed 02/10/21 Page 7 of 15 attempt; (4) reports and evidence of Epstein's death on August 10, 2019; (5) email correspondence between Tartaglione's attorneys and legal counsel at the MCC; and (6) medical and psychological records of Epstein prepared by BOP. (Decl. of Russell Capone, ECF No. 22

e documents appear to be largely factual in nature and therefore are not subject to a blanket withholding under Exemption 5. (Pl.'s Br., at 19); see Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473, 482 (2d Cir. 1999) ("Purely factual material not reflecting the agency's deliberative process is not protected.")

E Document 42 Filed 02/10/21 Page 7 of 15 attempt; (4) reports and evidence of Epstein's death on August 10, 2019; (5) email correspondence between Tartaglione's attorneys and legal counsel at the MCC; and (6) medical and psychological records of Epstein prepared by BOP. (Decl. of Russell Capone, ECF No. 22

e documents appear to be largely factual in nature and therefore are not subject to a blanket withholding under Exemption 5. (Pl.'s Br., at 19); see Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473, 482 (2d Cir. 1999) ("Purely factual material not reflecting the agency's deliberative process is not protected.")

E Document 42 Filed 02/10/21 Page 7 of 15 attempt; (4) reports and evidence of Epstein's death on August 10, 2019; (5) email correspondence between Tartaglione's attorneys and legal counsel at the MCC; and (6) medical and psychological records of Epstein prepared by BOP. (Decl. oaa, ECF No. 22 [hereinafter

e documents appear to be largely factual in nature and therefore are not subject to a blanket withholding under Exemption 5. (Pl.'s Br., at 19); see Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473, 482 (2d Cir. 1999) ("Purely factual material not reflecting the agency's deliberative process is not protected.")