3
Shared Docs
3
Same-Page
3 / 3
Mentions
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
han recite the boilerplate rationale for protecting deliberative documents. (Gov't Reply Br., at 17-18.) That is not enough. In order to satisfy the Amendment's standard, BOP "must explain how a particular Exemption 5 withholding would harm [its] deliberative process." Nat? Day Laborer Org. Network v. U.S
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
han recite the boilerplate rationale for protecting deliberative documents. (Gov't Reply Br., at 17-18.) That is not enough. In order to satisfy the Amendment's standard, BOP "must explain how a particular Exemption 5 withholding would harm [its] deliberative process." Nat? Day Laborer Org. Network v. U.S
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
han recite the boilerplate rationale for protecting deliberative documents. (Gov't Reply Br., at 17-18.) That is not enough. In order to satisfy the Amendment's standard, BOP "must explain how a particular Exemption 5 withholding would harm [its] deliberative process." Nat? Day Laborer Org. Network v. U.S
Entities connected to both Nicholas Tartaglione and Amendment

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
George W. Bush
PERSON
Julie K. Brown
PERSON
United States
LOCATION
THE NEW YORK TIMES COMPANY
ORGANIZATION
Alberto Gonzales
PERSON
The New York Times
ORGANIZATION
Human Rights Watch
ORGANIZATIONSuicide
PERSOND.C. Cir
ORGANIZATIONRadcliffe
PERSON
Andrew Cuomo
PERSONHomeland Sec
ORGANIZATIONPerez
PERSONChristina Goldbaum
PERSONAli Watkins
PERSONAl-Amyn Sumar
PERSONRussell Capone
PERSON