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iii EFTA00071587 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 5 of 25 PRELIMINARY STATEMENT This case involves records at the core of FOIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of
Housing Unit, sources typically relied upon and information-gathering steps taken in investigating incidents at the MCC, details about how BOP After Action Review teams conduct their work, and information about where evidence is stored. See Supp. Christenson Decl. q¶ 18- 25; see also, e.g., Human Rights Watch,
iii EFTA00088608 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 5 of 25 PRELIMINARY STATEMENT This case involves records at the core of FOIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of
Housing Unit, sources typically relied upon and information-gathering steps taken in investigating incidents at the MCC, details about how BOP After Action Review teams conduct their work, and information about where evidence is stored. See Supp. Christenson Decl. q¶ 18- 25; see also, e.g., Human Rights Watch,
iii EFTA00099601 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 5 of 25 PRELIMINARY STATEMENT This case involves records at the core of FOIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of
Housing Unit, sources typically relied upon and information-gathering steps taken in investigating incidents at the MCC, details about how BOP After Action Review teams conduct their work, and information about where evidence is stored. See Supp. Decl. 11118- 25; see also, e.g., Human Rights Watch, 2015 WL 54
Entities connected to both FOIA Exemption and Action Review

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATION
Department of Justice
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONNicholas Tartaglione
PERSONTova Noel
PERSONthe Southern District
LOCATIONthe Acting United States
ORGANIZATION
Audrey Strauss
PERSON
United States
LOCATION
Torres
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATIONMichael Thomas's
PERSONSouthern District
LOCATIONChristenson
PERSONHomeland Sec
ORGANIZATIONRadcliffe
PERSONthe Tenth Circuit's
ORGANIZATIONAllard K. Lowenstein
PERSON