7
Shared Docs
4
Same-Page
25 / 7
Mentions
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
Against Nicholas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 (KMK)
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
Against Nicholas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 (KMK)
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
Against Nicholas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 (KMK)
sts filed by the New York Times Company (the "FOIA Requests") that are the subject of this case, which seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP"
rafficking, in violation of 18 U.S.C. § 371, and one count of sex trafficking, in violation of 18 U.S.C. §§ 1591(a), (b)(2), and 2. On July 6, 2019, Epstein was arrested and thereafter incarcerated at the MCC until his death. 5. On July 10, 2019, Epstein was assigned to the Special Housing Unit ("SHU")
ich seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center
to commit a crime of violence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartag
ews never touched the man,' Jeffrey Epstein's former cellmate insists in letter to Daily News NY Daily News By Stephen Rex Brown 9/12/19 Jeffrey Epstein's former cellmate proclaimed "I never touched the man" in a letter to the Daily News Thursday as a probe into the multimillionaire perv's suicide co
Page: EFTA00009966 →ractor]" Subject: RE: 'I never touched the man,' Jeffrey Epstein's former cellmate insists in letter to Daily News
Page: EFTA00009966 →2019 18:11:39 +0000 https://www.cbsnews.com/news/jeffrey-epstein-donated-8-9-million-to-harvard-university ys/ Fro
Page: EFTA00009966 →ractor]" Subject: RE: 'I never touched the man,' Jeffrey Epstein's former cellmate insists in letter to Da
Page: EFTA00009966 →after it was in the mail. "It's a product of the frustration at the entire situation," Barket said. The musclebound ex-cop is charged with killing Martin Luna, 41, Hector Santiago, 32, Miguel Luna, 25, and Hector Gutierrez, 43, in April 2016, as well as conspiring to distribute over five kilos of cocaine.
Page: EFTA00009967 →sts filed by the New York Times Company (the "FOIA Requests") that are the subject of this case, which seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP"
Page: EFTA00015438 →rafficking, in violation of 18 U.S.C. § 371, and one count of sex trafficking, in violation of 18 U.S.C. §§ 1591(a), (b)(2), and 2. On July 6, 2019, Epstein was arrested and thereafter incarcerated at the MCC until his death. 5. On July 10, 2019, Epstein was assigned to the Special Housing Unit ("SHU")
Page: EFTA00015439 →to commit a crime of violence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartag
Page: EFTA00015441 →sts filed by the New York Times Company (the "FOIA Requests") that are the subject of this case, which seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP"
Page: EFTA00031025 →rafficking, in violation of 18 U.S.C. § 371, and one count of sex trafficking, in violation of 18 U.S.C. §§ 1591(a), (b)(2), and 2. On July 6, 2019, Epstein was arrested and thereafter incarcerated at the MCC until his death. 5. On July 10, 2019, Epstein was assigned to the Special Housing Unit ("SHU")
Page: EFTA00031026 →to commit a crime of violence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartag
Page: EFTA00031028 →Entities connected to both Jeffrey Epstein and Martin Luna

George W. Bush
PERSON
United States
LOCATIONthe Southern District
LOCATION
Sarah Ferguson
PERSON
Geoffrey S. Berman
PERSONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Southern District of New York
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Audrey Strauss
PERSON
Supreme Court
ORGANIZATION
Alberto Gonzales
PERSONNicholas Tartaglione
PERSONGarcia
PERSON
Mao Zedong
PERSONDistrict Court for the Southern District of New York
ORGANIZATION
Andrew Cuomo
PERSON
The New York Times
ORGANIZATION
Roger
PERSONTova Noel
PERSON