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

0-cv-00833-PAE Document 27 Filed 09/10/20 Page 16 of 29 interfere with enforcement proceedings. See 5 U.S.C. § 552(b)(7)(A); NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214, 236 (1978); see also, e.g., Radcliffe v. IRS, 536 F. Supp. 2d 423, 437 (S.D.N.Y. 2008) ("Affidavits must contain more than mere concl

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

0-cv-00833-PAE Document 27 Filed 09/10/20 Page 16 of 29 interfere with enforcement proceedings. See 5 U.S.C. § 552(b)(7)(A); NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214, 236 (1978); see also, e.g., Radcliffe v. IRS, 536 F. Supp. 2d 423, 437 (S.D.N.Y. 2008) ("Affidavits must contain more than mere concl

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

onably 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 government need only show that

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

onably 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 government need only show that

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

onably 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 government need only show that

WAIVED ANY PRIVILEGE THAT IT MIGHT OTHERWISE POSSESS 5 11. THE QUALIFIED JOURNALIST PRIVILEGE IS OVERCOME BY EDWARDS' COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE OF MINOR GIRLS AND HIS LACK OF REMORSE 8 A. Edwards Needs Epstein's Own Words to Defend Against Epstein's Civil

Damages 8 B. Epstein's Statements Are Not Available from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80656-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores

S OVERCOME BY EDWARDS' COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE OF MI

le sources" since "the record is quite clear that Mr. Epstein has regularly been asserting, and will continue

6-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores v. Cooper Tire and Rubber Co., 178P.Id 1176, 1183 (Ariz. App. 2008) Ulrich v. Coast Dental Services. Inc., 739 So.21d 142, 144 (Fla. App. 1999) 7 Cooper Indus., Inc. v. Leather

S. 427, 87 S.Ct. 1 , 18 L. Ed.2d 865 (1967); Buchanan Rhodes. 885 U.S. 3, 87 S.Ct. 83, 17 .Ed.2d 9 (1966); Idlewild Bon Voyage Liquor Corp. v. Epstein, 370 U.S. 713, 82 S.Ct. 1294, 8 L.Ed2d 794 (1962). Since in this case we affirm that refusal, we need not now decide whether or not there is juri

, Gary A. Hughes, J.D, Steven D. Najarian, J.D., Jeffrey A. Schafer, J.D., and Jeffrey J. Shampo, J.D. II

rally applied to proceedings under Fed.R.Crim.Proc. 41(e) which are summary in character, even when these are pre.indletment. Cf. Goodyear Tire & Rubber Co. v. N.L.R.B., U Cir.. 1011, 122 F.2d 450. 451, 136 A.L.R. 8S3. EFTA00191885 170 282 FEDERAL REPORTER, 2d SERIES the return of property alleged t