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

TABLE OF AUTHORITIES Cases ACLU v. DOD, Page(s) 389 F. Supp. 2d 547 (S.D.N.Y. 2005) 21, 22 ACLU v. DOI, 844 F.3d 126 (2d Cir. 2016) 15, 16 Adamowitz v. I.R.S., 552 F. Supp. 2d 355 (S.D.N.Y. 2008) 5 Allard K. Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (2d Cir.

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

TABLE OF AUTHORITIES Cases ACLU v. DOD, Page(s) 389 F. Supp. 2d 547 (S.D.N.Y. 2005) 21, 22 ACLU v. DOI, 844 F.3d 126 (2d Cir. 2016) 15, 16 Adamowitz v. I.R.S., 552 F. Supp. 2d 355 (S.D.N.Y. 2008) 5 Allard K. Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (2d Cir.

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

TABLE OF AUTHORITIES Cases ACLU v. DOD, Page(s) 389 F. Supp. 2d 547 (S.D.N.Y. 2005) 21, 22 ACLU v. DOI, 844 F.3d 126 (2d Cir. 2016) 15, 16 Adamowitz v. I.R.S., 552 F. Supp. 2d 355 (S.D.N.Y. 2008) 5 Allard K. Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (2d Cir.