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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
e Admin., 782 F. Supp. 628 (D.D.C. 1991) 19 NLRB v. Sears, Roebuck, 421 U.S. 132 (1975) 13 North v. Walsh, 881 F.2d 1088 (D.C. Cir. 1989) 8 Oglesby v. U.S. Army, 920 F.2d 57 (D.C. Cir. 1990) 5 Pinson v. Dept of .htstice, 236 F. Supp. 3d (D.D.C. 2017) 22 Radcliffe v. IRS, 536 F. Supp. 2d 42
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
e Admin., 782 F. Supp. 628 (D.D.C. 1991) 19 NLRB v. Sears, Roebuck, 421 U.S. 132 (1975) 13 North v. Walsh, 881 F.2d 1088 (D.C. Cir. 1989) 8 Oglesby v. U.S. Army, 920 F.2d 57 (D.C. Cir. 1990) 5 Pinson v. Dept of .htstice, 236 F. Supp. 3d (D.D.C. 2017) 22 Radcliffe v. IRS, 536 F. Supp. 2d 42
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
e Admin., 782 F. Supp. 628 (D.D.C. 1991) 19 NLRB v. Sears, Roebuck, 421 U.S. 132 (1975) 13 North v. Walsh, 881 F.2d 1088 (D.C. Cir. 1989) 8 Oglesby v. U.S. Army, 920 F.2d 57 (D.C. Cir. 1990) 5 Pinson v. Dept of .htstice, 236 F. Supp. 3d (D.D.C. 2017) 22 Radcliffe v. IRS, 536 F. Supp. 2d 42
dar Online submitted a FOIA requests to the FBI collectively seeking "all documents relating to the FBI's investigation and prosecution of financier Jeffrey Epstein, who plead guilty to one count of felony solicitation of prostitution in August 2006. Dkt. No. 12-2, Ex. B; see Declaration of Michael G. Seidel, da
(b)(7)(A). Many of the records sought by the Radar Online fall at the heart of this exemption, and the FBI has withheld them individually, prior to Esptein's arrest, and categorically, after Esptein's arrest. Other FOIA exemptions also justify the FBI's withholding of records in response to the FOIA re
ecords at the core of the criminal prosecution of Jeffrey Epstein, prior to his passing, and the current p
Y. June 1, 1995), aft" d, 83 F.3d 41 (2d Cir. 1996). 6 EFTA00069317 those "files likely to contain responsive materials (if such records exist)." Oglesby v. U.S Anny, 920 F.2d 57,68 (D.C. Cir. 1990). Where an agency's declaration demonstrates that it has conducted a reasonable search, "the FOIA reque
and remains to their countries of origin, with about 96% of the seized items having been returned to countries including Peru, Canada, and China. Epstein Claimed Prosecutors Offered His Freedom if He Agreed to Implicate President Trump The New York Post (11/05, Tillett) reported that Jeffrey Epstein c
d China. Epstein Claimed Prosecutors Offered His Freedom if He Agreed to Implicate President Trump The New York Post (11/05, Tillett) reported that Jeffrey Epstein claimed New York federal prosecutors told him he could walk free if he agreed to implicate Donald Trump, according to his ex-cellmate. The article d
The New York Post (11/05, Tillett) reported that Jeffrey Epstein claimed New York federal prosecutors told
turned himself in. According to the Montgomery County Jail website, Quandric Lavar Morris-Ogelsby is in custody as of 12:08 a.m. Wednesday. Morris- Oglesby was arrested on Tuesday night at 11:43 p.m. According to the article, the Dayton Police Department as well as a video streamed live on Facebook conf
Entities connected to both Jeffrey Epstein and Oglesby

Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Alfredo Rodriguez
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Sarah Ferguson
PERSON
Paul Ryan
PERSON
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Audrey Strauss
PERSON
Supreme Court
ORGANIZATION
Alberto Gonzales
PERSONNicholas Tartaglione
PERSONGarcia
PERSON
Andrew Cuomo
PERSON
The New York Times
ORGANIZATION
James Comey
PERSON
Roger
PERSONTova Noel
PERSON