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FURTHER SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AUDREY STRAUSS Acting United States Attorney Southern District of New York 86 Chambers Street, Third Floor New York. New York 10007 EFTA00071584 Case 1:20-cv
criminal proceedings. Plaintiff's argument that disclosure pursuant to a protective order would foreclose any possible interference with Noel, see P. MOL at 13, incorrectly conflates disclosure to criminal defendants pursuant to a protective order with public disclosure under FOIA. The Capone Declara
FURTHER SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AUDREY STRAUSS Acting United States Attorney Southern District of New York 86 Chambers Street, Third Floor New York, New York 10007 Telephone: (212) 637-2715
criminal proceedings. Plaintiff's argument that disclosure pursuant to a protective order would foreclose any possible interference with Noel, see P. MOL at 13, incorrectly conflates disclosure to criminal defendants pursuant to a protective order with public disclosure under FOIA. The Capone Declara
FURTHER SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AUDREY STRAUSS Acting United States Attorney Southern District of New York 86 Chambers Street, Third Floor New York, New York 10007 Assistant United States Att
criminal proceedings. Plaintiff's argument that disclosure pursuant to a protective order would foreclose any possible interference with Noel, see P. MOL at 13, incorrectly conflates disclosure to criminal defendants pursuant to a protective order with public disclosure under FOIA. The Declarations e
Entities connected to both Audrey Strauss and P. MOL

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
United States
LOCATIONFederal Bureau of Prisons
ORGANIZATIONNicholas Tartaglione
PERSON
Torres
PERSON
Homeland Security
ORGANIZATION
The New York Times
ORGANIZATIONChristenson
PERSONTova Noel
PERSONthe Acting United States
ORGANIZATION
THE NEW YORK TIMES COMPANY
ORGANIZATIONthe Tenth Circuit's
ORGANIZATIONGarcia
PERSONHomeland Sec
ORGANIZATION
Human Rights Watch
ORGANIZATION
Doherty
PERSON
Hopkins
ORGANIZATIONRobbins Tire & Rubber Co.
ORGANIZATION