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Act ("FOIA"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times") seeking the release of certain records related to Jeffrey Epstein. Enclosed please find the Government's first in camera production. As directed by the Court, this production consists of certain records identified
tioned at some point in a chain of emails and also possibly because Tartaglione's defense counsel, Bruce Barket, is associated with the firm Barket, Epstein, Kearon, Aldea & LoTurco, LLP, and so the name "Epstein" typically appears in the signature block of his emails. If the Court would benefit from fu
seeking the release of certain records related to Jeffrey Epstein. Enclosed please find the Government's f
te redactions. Pursuant to the Court's directions, the Government has, for each page, indicated which portions of the page are withheld under which FOIA Exemption and, if a portion or the entire page is withheld under FOIA Exemption 7(A), indicated which criminal case, United States v. Tartaglione, 16-cr- 832
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")
presented at trial. 8. The risks of interference with the Noel proceedings are heightened by the media coverage of speculation and theories about Epstein's death. Many publicly-discussed theories of Epstein's death are unfounded. Premature release of the withheld records, particularly if the records
ich seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center (
pecifically, this declaration addresses the bases for the withholding in whole or in part of certain records provided back to BOP by OIG pursuant to FOIA Exemption 7(A). Records Withheld in Full or in Part from Disclosure Pursuant to FOIA Exemption 7(A) on Account of Likely Interference with Noel 4. 5 U.S.C
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")
presented at trial. 8. The risks of interference with the Noel proceedings are heightened by the media coverage of speculation and theories about Epstein's death. Many publicly-discussed theories of Epstein's death are unfounded. Premature release of the withheld records, particularly if the records
ich seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center (
pecifically, this declaration addresses the bases for the withholding in whole or in part of certain records provided back to BOP by OIG pursuant to FOIA Exemption 7(A). Records Withheld in Full or in Part from Disclosure Pursuant to FOIA Exemption 7(A) on Account of Likely Interference with Noel 4. 5 U.S.C
Act ("FOR"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times") seeking the release of certain records related to Jeffrey Epstein. Enclosed please find the Government's first in camera production. As directed by the Court, this production consists of certain records identified
tioned at some point in a chain of emails and also possibly because Tartaglione's defense counsel, Bruce Barket, is associated with the firm Barket, Epstein, Kearon, Aldea & LoTurco, LLP, and so the name "Epstein" typically appears in the signature block of his emails. If the Court would benefit from fu
seeking the release of certain records related to Jeffrey Epstein. Enclosed please find the Government's f
ages of emails. Pursuant to the Court's directions, the Government has, for each page, indicated which portions of the page are withheld under which FOIA Exemption and, if a portion or the entire page is withheld under FOIA Exemption 7(A), indicated which criminal case, United States v. Tartaglione, 16-cr-832
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")
presented at trial. 8. The risks of interference with the Noel proceedings are heightened by the media coverage of speculation and theories about Epstein's death. Many publicly-discussed theories of Epstein's death are unfounded. Premature release of the withheld records, particularly if the records
ich seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center (
pecifically, this declaration addresses the bases for the withholding in whole or in part of certain records provided back to BOP by OIG pursuant to FOIA Exemption 7(A). Records Withheld in Full or in Part from Disclosure Pursuant to FOIA Exemption 7(A) on Account of Likely Interference with Noel 4. 5 U.S.C
Act ("FOR"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times") seeking the release of certain records related to Jeffrey Epstein. Enclosed please find the Government's first in camera production. As directed by the Court, this production consists of certain records identified
tioned at some point in a chain of emails and also possibly because Tartaglione's defense counsel, Bruce Barket, is associated with the firm Barket, Epstein, Kearon, Aldea & LoTurco, LLP, and so the name "Epstein" typically appears in the signature block of his emails. If the Court would benefit from fu
seeking the release of certain records related to Jeffrey Epstein. Enclosed please find the Government's f
te redactions. Pursuant to the Court's directions, the Government has, for each page, indicated which portions of the page are withheld under which FOIA Exemption and, if a portion or the entire page is withheld under FOIA Exemption 7(A), indicated which criminal case, United States v. Tartaglione, 16-cr- 832
IA) appeal number AP-2013-01397 to the U.S. Department of Justice, Federal Bureau of Investigation (FBI) seeking documents on behalf of your client Jeffrey Epstein. On June 28, 2017, the FBI referred to U.S. Customs and Border Protection (CBP) 11 pages of records for our review and determination. CBP has deter
eking documents on behalf of your client Jeffrey Epstein. On June 28, 2017, the FBI referred to U.S. Custo
(FBI) seeking documents on behalf of your client Jeffrey Epstein. On June 28, 2017, the FBI referred to U.
52 (b)(6), (b)(7)(C), and (b)(7)(E) of the Freedom of Information Act. Enclosed are 11 pages with certain information withheld as described below: FOIA Exemption (bX6) exempts from disclosure personnel or medical files and similar files the release of which would cause a clearly unwarranted invasion of person
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
iii EFTA00071587 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 5 of 25 PRELIMINARY STATEMENT This case involves records at the core of FOIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of
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
iii EFTA00088608 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 5 of 25 PRELIMINARY STATEMENT This case involves records at the core of FOIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of
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
iii EFTA00099601 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 5 of 25 PRELIMINARY STATEMENT This case involves records at the core of FOIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of
Entities connected to both Jeffrey Epstein and FOIA Exemption

United States
LOCATIONSouthern District
LOCATION
Larry Summers
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Audrey Strauss
PERSONNicholas Tartaglione
PERSONBates
PERSONGarcia
PERSON
White Plains
LOCATION
The New York Times
ORGANIZATION
Homeland Security
ORGANIZATIONTova Noel
PERSONKearon
PERSON
Hopkins
ORGANIZATIONAldea & LoTurco
ORGANIZATION
Torres
PERSON