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

4, 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. 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

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

4, 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. 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

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

4, 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. 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

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

ordan v. U.S. Dep't of Justice. See, 668 F.3d 1188 (10th Cir 2011) 6 Judicial Watch v. U.S. Dep't of State, 875 F. Supp. 2d 37 (D.D.C. 2012) 14 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Insti

treatment of Epstein, including psychological treatment, and Epstein's contacts with people who are not associated with BOP. 5 The charges against Tartaglione have nothing to do with Epstein. Tartaglione is charged with one count of conspiracy to distribute narcotics, four counts of intentional killing in

s of confinement at the facility. As a result, those conditions of Tartaglione's confinement at the MCC may be relevant to the penalty phase of the Tartaglione case. The theory falls far short of what the Government needs to show to overcome the presumption of openness that is central to FOIA. The theory w

d 81 (2d Cir. 1991) 19 Human Rights Watch v. Dep't ofJustice & Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) 9 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 375 F. Supp. 3d 93 (D.D.C. 2019) 20 Knight First Amendment Inst. v. U.S. Dep't of Homeland Sec., 407 F. Supp. 3d 334 (

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

ordan v. U.S. Dep't of Justice. See, 668 F.3d 1188 (10th Cir 2011) 6 Judicial Watch v. U.S. Dep't of State, 875 F. Supp. 2d 37 (D.D.C. 2012) 14 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Insti

treatment of Epstein, including psychological treatment, and Epstein's contacts with people who are not associated with BOP. 5 The charges against Tartaglione have nothing to do with Epstein. Tartaglione is charged with one count of conspiracy to distribute narcotics, four counts of intentional killing in

s of confinement at the facility. As a result, those conditions of Tartaglione's confinement at the MCC may be relevant to the penalty phase of the Tartaglione case. The theory falls far short of what the Government needs to show to overcome the presumption of openness that is central to FOIA. The theory w

d 81 (2d Cir. 1991) 19 Human Rights Watch v. Dep't ofJustice & Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) 9 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 375 F. Supp. 3d 93 (D.D.C. 2019) 20 Knight First Amendment Inst. v. U.S. Dep't of Homeland Sec., 407 F. Supp. 3d 334 (

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

ordan v. U.S. Dep't of Justice. See, 668 F.3d 1188 (10th Cir 2011) 6 Judicial Watch v. U.S. Dep't of State, 875 F. Supp. 2d 37 (D.D.C. 2012) 14 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Insti