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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
lized. See Supp. Christenson Decl. ¶ 16. These prior versions of the ultimate response document were properly withheld under Exemption 5 as drafts. See American Civil Liberties Union v. Dep't ofJustice, 844 F.3d 126, 133 (2d Cir. 2016); Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479, 518 (S.D.N.Y. 2010) ("It is well- settled that
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
lized. See Supp. Christenson Decl. ¶ 16. These prior versions of the ultimate response document were properly withheld under Exemption 5 as drafts. See American Civil Liberties Union v. Dep't ofJustice, 844 F.3d 126, 133 (2d Cir. 2016); Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479, 518 (S.D.N.Y. 2010) ("It is well- settled that
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
it was finalized. See Supp. Decl. ¶ 16. These prior versions of the ultimate response document were properly withheld under Exemption 5 as drafts. See American Civil Liberties Union v. Dep't ofJustice, 844 F.3d 126, 133 (2d Cir. 2016); Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479, 518 (S.D.N.Y. 2010) ("It is well- settled that
Entities connected to both FOIA Exemption and See American Civil Liberties Union

Jeffrey Epstein
PERSONNicholas Tartaglione
PERSONFederal Bureau of Prisons
ORGANIZATION
Department of Justice
ORGANIZATION
THE NEW YORK TIMES COMPANY
ORGANIZATION
Audrey Strauss
PERSONthe Acting United States
ORGANIZATIONthe Southern District
LOCATION
United States
LOCATIONChristenson
PERSONKimberlin
PERSONHalpern
LOCATIONTova Noel
PERSONThe Bureau of Prisons
ORGANIZATIONRobbins Tire & Rubber Co.
ORGANIZATIONFavish
PERSONCross-Motion for Summary Judgment
ORGANIZATIOND.C. Cir
ORGANIZATIONAction Review
ORGANIZATIONMichael Thomas's
PERSON