3
Shared Docs
3
Same-Page
9 / 3
Mentions
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
BOP, No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) 9, 10, 11, 20 In re County of Erie, 473 F.3d 413 (2d Cir. 2 007) 14, 17 John Doe Agency v. 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
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
BOP, No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) 9, 10, 11, 20 In re County of Erie, 473 F.3d 413 (2d Cir. 2 007) 14, 17 John Doe Agency v. 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
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
BOP, No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) 9, 10, 11, 20 In re County of Erie, 473 F.3d 413 (2d Cir. 2 007) 14, 17 John Doe Agency v. 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
Entities connected to both Nicholas Tartaglione and John Doe Agency

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONTova Noel
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Julie K. Brown
PERSONthe Southern District
LOCATIONMichael Thomas
PERSON
Audrey Strauss
PERSON
Alberto Gonzales
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATION
Alfredo Rodriguez
PERSON
Human Rights Watch
ORGANIZATIONChristenson
PERSON
The Washington Post
ORGANIZATION
The New York Times
ORGANIZATIONRadcliffe
PERSOND.C. Cir
ORGANIZATION