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

st be either pending or reasonably foreseeable at the time of the withholding. See, e.g.,Kay v. F.C.C., 976 F. Supp. 23, 37-38 (D.D.C. 1997) (citing N.L.R.B. v. Robbins Tire & Rubber Co.,437 U.S. 214, 220 (1978)). The government's burden to establish the applicability of Exemption 7(A) is not high; the gov

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

st be either pending or reasonably foreseeable at the time of the withholding. See, e.g.,Kay v. F.C.C., 976 F. Supp. 23, 37-38 (D.D.C. 1997) (citing N.L.R.B. v. Robbins Tire & Rubber Co.,437 U.S. 214, 220 (1978)). The government's burden to establish the applicability of Exemption 7(A) is not high; the gov

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

st be either pending or reasonably foreseeable at the time of the withholding. See, e.g.,Kay v. F.C.C., 976 F. Supp. 23, 37-38 (D.D.C. 1997) (citing N.L.R.B. v. Robbins Tire & Rubber Co.,437 U.S. 214, 220 (1978)). The government's burden to establish the applicability of Exemption 7(A) is not high; the gov

s at DOJ-OIG tasked with preparing this report, the Government understands that the report will likely focus on the events surrounding the death of Jeffrey Epstein and BOP policies and procedures. 4 EFTA00027315 --- PAGE BREAK --- Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 10 of 34 written state

ely focus on the events surrounding the death of Jeffrey Epstein and BOP policies and procedures. 4 EFTA

the Indictment relates to a 14-hour time period); count slips, thirty minute round forms, and staffing rosters for the three-week period surrounding Epstein's suicide; internal MCC phone records; employee files and staffing history for Noel and Thomas; and a wide range of written Bureau of Prison polici

ich governmental decisions and policies are formulated.'" Dep't of Interior v. Klamath Water Users Protective Ass 'n, 532 U.S. 1, 8 (2001) (quoting N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132, 150 (1975)). The privilege is applicable in criminal and civil cases involving the government. See, e.g., United

s at DOJ-OIG tasked with preparing this report, the Government understands that the report will likely focus on the events surrounding the death of Jeffrey Epstein and BOP policies and procedures. 4 EFTA00031271 --- PAGE BREAK --- written statements, photos, videos, and incident reports created, manufacture

ely focus on the events surrounding the death of Jeffrey Epstein and BOP policies and procedures. 4 EFTA

the Indictment relates to a 14-hour time period); count slips, thirty minute round forms, and staffing rosters for the three-week period surrounding Epstein's suicide; internal MCC phone records; employee files and staffing history for Noel and Thomas; and a wide range of written Bureau of prison polici

ich governmental decisions and policies are formulated.'" Dep't of Interior v. Klamath Water Users Protective Ass 'n, 532 U.S. 1, 8 (2001) (quoting N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132, 150 (1975)). The privilege is applicable in criminal and civil cases involving the government. See, e.g., United