Epstein Secrets

equest Seeking Photos Of Jeffrey Epstein And Records Surrounding His Apparent Suicide (Aug. 12, 2019) 8 Nick Bryant, Here Is Pedophile Billionaire Jeffrey Epstein's Little Black Book, Gawker (Jan. 23, 2015) 16 Office of the Inspector General, Audit of the Federal Bureau of Prisons ' Monitoring of Inmate Commu

rtment of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has suggested that Epstein was "killed" while in federal custody. Matt Zapotosky, Trump questions whether Jeffrey Epstein was killed in federal custody. His attorney general a

ive is his brother Mark, who has said they "were not that close" and is himself eager for more documents to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019), hups://hrld.us/3ibIANJ (noting that "Mark Epstein

m OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in

s to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Hi

710 (S.D.N.Y. Apr. 30, 2020) 17 N.Y. Times Co. v. U.S. Dep't ofJustice, 872 F. Supp. 2d 309 (S.D.N.Y. 2012) 3 Nat'l Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 15 Nat'l Council of La Raza v. Dep't ofJustice, 411 F.3d 350 (2d Cir. 2005) 6 iv EFTA00071627 Case 1:20-cv-00833-PAE D

m OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in

s to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Hi

equest Seeking Photos Of Jeffrey Epstein And Records Surrounding His Apparent Suicide (Aug. 12, 2019) 8 Nick Bryant, Here Is Pedophile Billionaire Jeffrey Epstein's Little Black Book, Gawker (Jan. 23, 2015) 16 Office of the Inspector General, Audit of the Federal Bureau of Prisons ' Monitoring of Inmate Commu

rtment of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has suggested that Epstein was "killed" while in federal custody. Matt Zapotosky, Trump questions whether Jeffrey Epstein was killed in federal custody. His attorney general a

ive is his brother Mark, who has said they "were not that close" and is himself eager for more documents to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019), hups://hrld.us/3ibIANJ (noting that "Mark Epstein

710 (S.D.N.Y. Apr. 30, 2020) 17 N.Y. Times Co. v. U.S. Dep't ofJustice, 872 F. Supp. 2d 309 (S.D.N.Y. 2012) 3 Nat'l Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 15 Nat'l Council of La Raza v. Dep't ofJustice, 411 F.3d 350 (2d Cir. 2005) 6 iv EFTA00088704 Case 1:20-cv-00833-PAE D

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

. Dep't of Haus. & Urban Dev., No. 07 Civ. 3378 (GEL), 2007 WL 4233008 (S.D.N.Y. Nov. 30, 2 00 7) 15 National Archives & Records Administration v. Favish, 541 U.S. 157 (200 4) 19 Nat 7 Assoc. of Homebuilders v. Norton, 309 F.3d 26 (D.C. Cir. 2 002) 17 iii EFTA00071557 Case 1:20-cv-00833-PAE Do

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

. Dep't of Haus. & Urban Dev., No. 07 Civ. 3378 (GEL), 2007 WL 4233008 (S.D.N.Y. Nov. 30, 2 00 7) 15 National Archives & Records Administration v. Favish, 541 U.S. 157 (200 4) 19 Nat 7 Assoc. of Homebuilders v. Norton, 309 F.3d 26 (D.C. Cir. 2 002) 17 iii EFTA00075440 Case 1:20-cv-00833-PAE Do

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

. Dep't of Haus. & Urban Dev., No. 07 Civ. 3378 (GEL), 2007 WL 4233008 (S.D.N.Y. Nov. 30, 2 00 7) 15 National Archives & Records Administration v. Favish, 541 U.S. 157 (200 4) 19 Nat 7 Assoc. of Homebuilders v. Norton, 309 F.3d 26 (D.C. Cir. 2 002) 17 iii EFTA00088674 Case 1:20-cv-00833-PAE Do

oceed. The Court should uphold BOP's logical and plausible reliance on Exemption 7(A). BOP's reliance on Exemptions 6 and 7(C) to protect images of Epstein's body and the names of his associates was also proper. Epstein's surviving family member retains a privacy interest in the details of Epstein's su

-6078-TC, 2011 WL 2619538 (D. Or. July 1, 2011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 11, 13, 14 New York Times Co. v. Dep't of Justice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711 (S.D.N.Y. Aug. 18, 2016) 6

oceed. The Court should uphold BOP's logical and plausible reliance on Exemption 7(A). BOP's reliance on Exemptions 6 and 7(C) to protect images of Epstein's body and the names of his associates was also proper. Epstein's surviving family member retains a privacy interest in the details of Epstein's su

-6078-TC, 2011 WL 2619538 (D. Or. July 1, 2011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 11, 13, 14 New York Times Co. v. Dep't of Justice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711 (S.D.N.Y. Aug. 18, 2016) 6

oceed. The Court should uphold BOP's logical and plausible reliance on Exemption 7(A). BOP's reliance on Exemptions 6 and 7(C) to protect images of Epstein's body and the names of his associates was also proper. Epstein's surviving family member retains a privacy interest in the details of Epstein's su

-6078-TC, 2011 WL 2619538 (D. Or. July 1, 2011) 19 N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214 (1978) 6 Nat? Archives & Records Admin. v. Favish, 541 U.S. 157 (2004) 11, 13, 14 New York Times Co. v. Dep't of Justice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711 (S.D.N.Y. Aug. 18, 2016) 6

aware of the FBI's handling of Plaintiff James Robertson's FOIA request for records related to the FBI's investigation and prosecution of financier Jeffrey Edward Epstein. In response to Plaintiff's request, the FBI processed on a document-by-document basis a total of 11,571 pages of responsive records. Of these page

FBI's investigation and prosecution of financier Jeffrey Edward Epstein. In response to Plaintiff's request, the

RMATION CONCERNING JEFFREY EDWARD EPSTEIN (5) In June 2008, Jeffrey Epstein pled guilty to a criminal charge of procuring prostitution of a minor. Epstein served 13 months of his 18-month sentence. On July 2, 2019, Jeffrey Epstein was indicted by a federal grand jury in the United States District Court

ts in response to Plaintiffs' request long before Mr. Epstein was arrested in 2019. When Mr. Epstein's arrest

, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Int

British tabloids, described Maxwell's alleged role as someone who recruited or facilitated the recruitment of young females for sexual activity with Jeffrey Epstein ("Epstein"), that she, M, had been interviewed by the Federal Bureau of Investigation ("FBI") in 2011, and that she had discussed Maxwell's involv

described Maxwell's alleged role as someone who recruited or facilitated the recruitment of young females for sexual activity with Jeffrey Epstein ("Epstein"), that she, M, had been interviewed by the Federal Bureau of Investigation ("FBI") in 2011, and that she had discussed Maxwell's involvement in t

identifying information in records containing allegations of abuse by military personnel and by other detainees); Nat'l Archives & Records Admin. v. Favish, 541 U.S. 157, 124 S.Ct. 1570, 158 L.Ed.2d 319 (2004) (holding Freedom of Information Act ("FOIA") recognizes surviving family members' right to pe