Epstein Secrets

1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 2 of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FO

loyees on duty the night Jeffrey Epstein died. Some of the same records could also affect the penalty phase of a pending death penalty case against Epstein's former cell mate. Congress did not intend the Freedom of Information Act, 5 U.S.C. § 552 et seq., to interfere with pending criminal prosecutions.

BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova

information, and other personal details of third-party individuals other than Epstein.4 One category of records implicates the privacy interests of Epsteies surviving family members because these records contain highly personal details about his death, including images As a threshold matter, each of the

Y. Mar. 24, 2014) 22, 23 Crooke,- v. Bureau of Alcohol, Tobacco, and Firearms, 789 F.2d 64 (D.C. Cir. 1986) 8 Cut for Nall Sec. Studies v. U.S. Dept of Justice, 331 F.3d 918 (D.C. Cir. 2003) 8 DOD v. FLRA, 510 U.S. 487(1994) 18 Doherty v. U.S. Dep't of Justice, 775 F.2d 49 (2d Cir. 1985) 20 Eil v. U

BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova

1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 2 of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FO

loyees on duty the night Jeffrey Epstein died. Some of the same records could also affect the penalty phase of a pending death penalty case against Epstein's former cell mate. Congress did not intend the Freedom of Information Act, 5 U.S.C. § 552 et seq., to interfere with pending criminal prosecutions.

information, and other personal details of third-party individuals other than Epstein.4 One category of records implicates the privacy interests of Epsteies surviving family members because these records contain highly personal details about his death, including images As a threshold matter, each of the

Y. Mar. 24, 2014) 22, 23 Crooke,- v. Bureau of Alcohol, Tobacco, and Firearms, 789 F.2d 64 (D.C. Cir. 1986) 8 Cut for Nall Sec. Studies v. U.S. Dept of Justice, 331 F.3d 918 (D.C. Cir. 2003) 8 DOD v. FLRA, 510 U.S. 487(1994) 18 Doherty v. U.S. Dep't of Justice, 775 F.2d 49 (2d Cir. 1985) 20 Eil v. U

BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova

1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 2 of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FO

loyees on duty the night Jeffrey Epstein died. Some of the same records could also affect the penalty phase of a pending death penalty case against Epstein's former cell mate. Congress did not intend the Freedom of Information Act, 5 U.S.C. § 552 et seq., to interfere with pending criminal prosecutions.

information, and other personal details of third-party individuals other than Epstein.4 One category of records implicates the privacy interests of Epsteies surviving family members because these records contain highly personal details about his death, including images As a threshold matter, each of the

Y. Mar. 24, 2014) 22, 23 Crooke,- v. Bureau of Alcohol, Tobacco, and Firearms, 789 F.2d 64 (D.C. Cir. 1986) 8 Cut for Nall Sec. Studies v. U.S. Dept of Justice, 331 F.3d 918 (D.C. Cir. 2003) 8 DOD v. FLRA, 510 U.S. 487(1994) 18 Doherty v. U.S. Dep't of Justice, 775 F.2d 49 (2d Cir. 1985) 20 Eil v. U

ted. Continental Casualty Co. v. Fibreboard Corp., 4 F.3d 777, 778 (' Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 2008, in Florida circuit court. I k was sentenced by the state court, and has served his sentence. Individuals

n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste

hether a charging document was ever filed against Jeffrey Epstein in the United States District Court for

in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V

orney could neither confirm nor deny the information presented by the 'external party.'" Senate of the Commonwealth of Puerto Rico v. United States Dept of Justice, 1992 WL 119127 at '3 (D.D.C. May 13, 1992) (citing Bony v. United States, 740 F. Supp. 888, 891 (D.D.C. 1990) ("Rule 6(e) does not create a type o

e • Sex Offender Registry at GERS Building Second Floor, 488-SOC Kronprindsens Gade, St Thomas, VI, 00802 Sent to NYCPD Sex Offender Unit Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTER, 83, ST THOMAS. VI, 00802 Sent to Virgin Islands Dept of Justice - Sex Offender Registry at GERS Building Second Mar, 488

Nov 7, 2018 SCR Change Notification Nov 7, 2018 SCR Change Officer Telephone Number UNKNOWN O Sent To/ Received From Sent to Virgin Islands Dept of Justice - Sex Offender Registry at GERS Building Second Mar, 488.50C Kronpnndsens Gade. St Thomas, VI, 00802 Sent to New Mexico Dept of Public Safety • Se

to Virgin Islands Dept of Justice - Sex Offender Registry at GERS Building Second Floor, 488-50C Kronprindsens Gade, St Thomas, VI. 00802 Sent to JEFFREY E EPSTEIN at 6100 RED 1100K QUARTER, ST THOMAS, VI, 00802 Sent to JEFFREY E EPSTEIN at 6100 RED NOOK QUARTER. 53, ST THOMAS, VI, 00802 Sent to Virgin Islan

From: To: Date: Subject: 12112+2019 3:05 PM NYT FOIA to BOP, Epstein logs Hi. I am enclosing a FOIA request. below. Please let me know if I can be of any help in explaining this or narrowing it. Many thanks, Daniel

ntrol of OSHA. Pursuant to the Freedom of Information Act, 5 U.S.C. Section 552 et seq ("FOIA"), I request copies of (or access to) documents about Jeffrey Epstein who died at the Metropolitan Correctional Center (MCC) on Aug. 10, 2019, specifically (hereafter described as - the records"): (1) The full

escribed as - the records"): (1) The full log of Mr. Epstein's phone calls to and from the MCC. (2) All email

to conduct record-level reviews at the administrative level before refusing to produce records contained in its investigative files.-- Tipognph v. Dept of Justice, 83 F. Supp. 2d 234 (D.D.C. Mar. 18, 2015) In addition, the FOIA Improvement Act of 2016 added a provision instructing federal agencies to withhol

requester." 5 U.S.C. § 552(aX4)(AXiii). EXPEDITED PROCESSING There is extreme public interest in records concerning the prison stay and death of Jeffrey Epstein, who was accused of sexually abusing scores of women and underage girls. Not only has a person died in federal custody. but the death has generated

SOR Change Notification Jun 17, 2019 e-SOR Change Notification Officer UNKNOWN Telephone Number 51.0Cfgaesgividfcco Sent to Virgin Islands Dept of Justice - Sex Offender Registry at GERS Building Second Floor, 48B-50C Kronprindsens Gade, St Thomas, VI, 00802 Sent to NYCPD Sex Offender Unit Sent to V

to Virgin Islands Dept of Justice - Sex Offender Registry at GERS Building Second floor, 48B-50C Kronprindsens Gade, St Thomas, VI, 00802 Sent to JEFFREY E EPSTEIN at 6100 RED HOOK QUARTER, B3, ST THOMAS, VI, 00802 Sent to Virgin Islands Dept of Justice - Sex Offender Registry at GERS Building Second Floor, 4