Epstein Secrets

that would also show that they were compiled for law enforcement purposes. So, overall, I think the point is that even if the Court does not adopt the Tenth Circuit's per-se rule, much of the insights or thinking of the Tenth Circuit is still going to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA0010578

let me start us off on Tartaglione because I may be able to zero in on what is of particular concern. I could not follow, although I've read both Capone declarations, including the first one — which, starting around paragraph 28, engages with Tartaglione — I couldn't think up, except with some degr

uld not implicate the entire document, right? MR. : With the exception that I think some of these documents — and I believe this is noted in the Capone declaration — there are concerns about even releasing them in part because I think the idea, first, in the Tartaglione case that there would be do

that would also show that they were compiled for law enforcement purposes. So, overall, I think the point is that even if the Court does not adopt the Tenth Circuit's per-se rule, much of the insights or thinking of the Tenth Circuit is still going to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA0010570

let me start us off on Tartaglione because I may be able to zero in on what is of particular concern. I could not follow, although I've read both Capone declarations, including the first one — which, starting around paragraph 28, engages with Tartaglione — I couldn't think up, except with some degr

implicate the entire document, right? MR. KOCHEVAR: With the exception that I think some of these documents — and I believe this is noted in the Capone declaration — there are concerns about even releasing them in part because I think the idea, first, in the Tartaglione case that there would be do

t as the Government explained, even if this Court 6 EFTA00071593 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 11 of 25 does not follow the Tenth Circuit's per se rule and instead applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8

isclosure of the Records Would Interfere with Pending Criminal Proceedings BOP properly withheld the Tartaglione Records' under Exemption 7(A). The Capone and Supplemental Capone Declarations explain why release of the Tartaglione Records would interfere with the Tartaglione prosecution, wherein the G

t as the Government explained, even if this Court 6 EFTA00088614 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 11 of 25 does not follow the Tenth Circuit's per se rule and instead applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8

isclosure of the Records Would Interfere with Pending Criminal Proceedings BOP properly withheld the Tartaglione Records' under Exemption 7(A). The Capone and Supplemental Capone Declarations explain why release of the Tartaglione Records would interfere with the Tartaglione prosecution, wherein the G