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

No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se rule for BOP records, and followed a "practical approach," observing that "[t]he ordinary understanding of the term [law enforcement] includ

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

No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se rule for BOP records, and followed a "practical approach," observing that "[t]he ordinary understanding of the term [law enforcement] includ

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

No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se rule for BOP records, and followed a "practical approach," observing that "[t]he ordinary understanding of the term [law enforcement] includ

ure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government has clearly explained how SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EF

e the government has put Tartaglione front and center here, I'm entitled to probe. Let me try this: Has a single document here been withheld under Tartaglione that relates to the events of August 10th? MR. : So, in some sense, yes, in that I believe -- and I want to be careful here because I don't have

ething that would reflect essentially which entries, and within the entries which documents, are being withheld, at least in part, on the basis of Tartaglione? MR. : No, other than -- well, other than the descriptions of the documents given in the declarations supporting the withholding, no, we don't h

that would also show that they were compiled for law enforcement purposes. So, overall, I think the point is that even if the Court does not adopt the Tenth Circuit's per-se rule, much of the insights or thinking of the Tenth Circuit is still going to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA0010578

ure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government has clearly explained how SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EF

e the government has put Tartaglione front and center here, I'm entitled to probe. Let me try this: Has a single document here been withheld under Tartaglione that relates to the events of August 10th? MR. KOCHEVAR: So, in some sense, yes, in that I believe -- and I want to be careful here because I don

ething that would reflect essentially which entries, and within the entries which documents, are being withheld, at least in part, on the basis of Tartaglione? MR. KOCHEVAR: No, other than -- well, other than the descriptions of the documents given in the declarations supporting the withholding, no, we

that would also show that they were compiled for law enforcement purposes. So, overall, I think the point is that even if the Court does not adopt the Tenth Circuit's per-se rule, much of the insights or thinking of the Tenth Circuit is still going to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA0010570

withheld Returned Records relates to the circumstances of Epstein's apparent suicide attempt and could reasonably be expected to interfere with the Tartaglione prosecution. See id. ¶¶ 15-16. B. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 6 and 7(C) Each of the Returned R

elease of the Tartaglione Records could reasonably be expected to interfere with any potential penalty-phase hearing required by 18 U.S.C. § 3593 in Tartaglione. Second, plaintiff mischaracterizes the Government's legitimate and reasonable concern about interference with any potential penalty phase of Tarta

t as the Government explained, even if this Court 6 EFTA00071593 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 11 of 25 does not follow the Tenth Circuit's per se rule and instead applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8

withheld Returned Records relates to the circumstances of Epstein's apparent suicide attempt and could reasonably be expected to interfere with the Tartaglione prosecution. See id. ¶¶ 15-16. B. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 6 and 7(C) Each of the Returned R

elease of the Tartaglione Records could reasonably be expected to interfere with any potential penalty-phase hearing required by 18 U.S.C. § 3593 in Tartaglione. Second, plaintiff mischaracterizes the Government's legitimate and reasonable concern about interference with any potential penalty phase of Tarta

t as the Government explained, even if this Court 6 EFTA00088614 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 11 of 25 does not follow the Tenth Circuit's per se rule and instead applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8

withheld Returned Records relates to the circumstances of Epstein's apparent suicide attempt and could reasonably be expected to interfere with the Tartaglione prosecution. See id. ¶¶ 15-16. B. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 6 and 7(C) Each of the Returned R

elease of the Tartaglione Records could reasonably be expected to interfere with any potential penalty-phase hearing required by 18 U.S.C. § 3593 in Tartaglione. Second, plaintiff mischaracterizes the Government's legitimate and reasonable concern about interference with any potential penalty phase of Tarta

t as the Government explained, even if this Court 6 EFTA00099607 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 11 of 25 does not follow the Tenth Circuit's per se rule and instead applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8