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mation about she Government's allegations against Mr. Epstein. The Assistant U.S. Attorney also revealed the s
por with EPSTEIN. after leaving EPSTEIN's 911 to get the police was unsure of which police e incident that had occurred stated that there from EPSTE or is assistants. were no telephone calls to or Influigationm 10/03/2007 at West Palm Beach, rite a 31E-MM-108032 SA E. Nesbitt Kuyrkendall
adline set by the I /SIMI was done without any ruspee4 an' (lie turmal rum:tip ll tt and scheduling of state judicial neuters. It require< den Mr. Ep stein's counsel persuade the Slate Attorney of l'alen peach tu issue a criminal in !brit union EFTA00225692 uoiuzive AWN 14:3a /AA 305 530 6440 EXECUTI
ls at his house and that his house was a place to hang out and have fun. DICENSO and a friend, ANGELIQUE GARCIA, maiden name CAVALLARO, traveled to JEFFREY EPSTEIN's residence in Palm Beach via a taxi cab. DICENSO believed this occurred during her 10th grade year, while attending Wellington High School. DICENSO
. 2008. OW! conirmaneation. we urgently requested that your Office etualuel an independent 'reeitm the moused federal pro•annitIon of our client. Miley Epstein. The dual Iti:INONIS Jill' that you review this newer am lit the bedrock need fin integrity in the enfiteentrat flitfe: ud ell "'MI laws. and iii
of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #14. (117) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY ERIN digitally penetrated Jane Doe #14, who was then a seventeen-year-old girl. (118) In or around the end of 2004 and the beginning of 2005, Defendant
if Just ice 050 Pennsylvania Avenue, N.W. Washington. 0.4'. 70530 Dc.ir Judy.: Filip: May :7, 2008 Pk 0. I: it /c., & Bird LLP The t dated Kidder: ' 19. 1 .mteet. NW *.e .!:“;;;;;Pti. ; ":5‘4 rdh -i1P"-; pv who lin.w.d.e. y 1 .1 C'ONI•%p/::'\'7'/..11. •_ • 'Ibis letter briefly suppleme
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
2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C.C., 976 F. Supp. 23 (D.D.C. 199 7) 7 Kidder v. FBI, 517 F. Supp. 2d 17 (D.D.C. 200 7) 8 Leopold v. Office ofDirector of National Intelligence, No. 16-2517 (CKK), 2020 WL 805380 (D.D.C. Feb.
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
2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C.C., 976 F. Supp. 23 (D.D.C. 199 7) 7 Kidder v. FBI, 517 F. Supp. 2d 17 (D.D.C. 200 7) 8 Leopold v. Office ofDirector of National Intelligence, No. 16-2517 (CKK), 2020 WL 805380 (D.D.C. Feb.
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
2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C.C., 976 F. Supp. 23 (D.D.C. 199 7) 7 Kidder v. FBI, 517 F. Supp. 2d 17 (D.D.C. 200 7) 8 Leopold v. Office ofDirector of National Intelligence, No. 16-2517 (CKK), 2020 WL 805380 (D.D.C. Feb.
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
poses 3 Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal proceedings, such as an appeal. See, e.g., Kidder v. FBI, 517 F. Supp. 2d 17, 27-28 (D. D.C. 2007); Kansi v. U.S Dep't ofJustice, II F. Supp. 2d 42, 44 (D. D.C. 1998). 8 EFTA00069319 As a thresh
Entities connected to both Jeffrey Epstein and Kidder

Marc Rich
PERSON
George W. Bush
PERSON
United States
LOCATIONthe Southern District
LOCATION
Wilbur Ross
PERSON
U.S. Virgin Islands
LOCATIONFBI
ORGANIZATION
Sarah Ferguson
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
Roger
PERSONTova Noel
PERSONMichael Thomas
PERSON