Epstein Secrets

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

ofJustice, 872 F. Supp. 2d 309 (S.D.N.Y. 2012) 3 Nat'l Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 15 Nat'l Council of La Raza v. Dep't ofJustice, 411 F.3d 350 (2d Cir. 2005) 6 iv EFTA00071627 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 5 of 29 NLRB v. Robbins Tire & Rubber Co

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

ofJustice, 872 F. Supp. 2d 309 (S.D.N.Y. 2012) 3 Nat'l Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 15 Nat'l Council of La Raza v. Dep't ofJustice, 411 F.3d 350 (2d Cir. 2005) 6 iv EFTA00088704 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 5 of 29 NLRB v. Robbins Tire & Rubber Co

E Document 42 Filed 02/10/21 Page 7 of 15 attempt; (4) reports and evidence of Epstein's death on August 10, 2019; (5) email correspondence between Tartaglione's attorneys and legal counsel at the MCC; and (6) medical and psychological records of Epstein prepared by BOP. (Decl. oaa, ECF No. 22 [hereinafter

access to agency investigatory files" that would bear on the prosecution than he would under the rules of criminal procedure. New York Times Co. v. Dep't ofJustice, 390 F. Supp. 3d 499, 512 (S.D.N.Y. 2019). But, as to least one important category, emails of Tartaglione's counsel, he already has access to those