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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
pond to them. "Governmental decisions and policies can include the formulation of an agency's statements to the public and other outside entities." Leopold v. Office ofDirector ofNational Intelligence, No. 16-2517 15 EFTA00071574 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 22 of 30 (CKK), 2020 WL 8
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
pond to them. "Governmental decisions and policies can include the formulation of an agency's statements to the public and other outside entities." Leopold v. Office ofDirector ofNational Intelligence, No. 16-2517 15 EFTA00075457 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 22 of 30 (CKK), 2020 WL 8
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
pond to them. "Governmental decisions and policies can include the formulation of an agency's statements to the public and other outside entities." Leopold v. Office ofDirector ofNational Intelligence, No. 16-2517 15 EFTA00088691 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 22 of 30 (CKK), 2020 WL 8
Entities connected to both Nicholas Tartaglione and Leopold v. Office

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONTova Noel
PERSON
George W. Bush
PERSON
United States
LOCATIONthe Southern District
LOCATIONMichael Thomas
PERSON
Audrey Strauss
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATION
Alberto Gonzales
PERSONChristenson
PERSON
Human Rights Watch
ORGANIZATION
The Washington Post
ORGANIZATION
The New York Times
ORGANIZATIOND.C. Cir
ORGANIZATIONRadcliffe
PERSONthe Acting United States
ORGANIZATIONNicole McFarland
PERSON
Hopkins
ORGANIZATION