Epstein Secrets

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

. John Doe Corp., 493 U.S. 146 (1 989) 4 Jordan v. U.S. Dep .t of Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C.C., 976 F. Supp. 23 (D.

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

. John Doe Corp., 493 U.S. 146 (1 989) 4 Jordan v. U.S. Dep .t of Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C.C., 976 F. Supp. 23 (D.

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

. John Doe Corp., 493 U.S. 146 (1 989) 4 Jordan v. U.S. Dep .t of Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C.C., 976 F. Supp. 23 (D.

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

neral explanations" that disclosure would impair or chill deliberations alone do not satisfy the foreseeable harm standard. Judicial Watch, Inc. v. U.S. Dept of Commerce, 375 F. Supp. 3d 93, 100 (D.D.C. 2019); see also N.Y. Times Co v. Dep't of Health and Human Sews., 2021 U.S. Dist. Lexis 6267, at *30-31 (S.D.N.Y. J

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

neral explanations" that disclosure would impair or chill deliberations alone do not satisfy the foreseeable harm standard. Judicial Watch, Inc. v. U.S. Dept of Commerce, 375 F. Supp. 3d 93, 100 (D.D.C. 2019); see also N.Y. Times Co v. Dep't of Health and Human Sews., 2021 U.S. Dist. Lexis 6267, at *30-31 (S.D.N.Y. J

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

neral explanations" that disclosure would impair or chill deliberations alone do not satisfy the foreseeable harm standard. Judicial Watch, Inc. v. U.S. Dept of Commerce, 375 F. Supp. 3d 93, 100 (D.D.C. 2019); see also N.Y. Times Co v. Dep't of Health and Human Sews., 2021 U.S. Dist. Lexis 6267, at *30-31 (S.D.N.Y. J