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

ns Tire & Rubber Co., 437 U.S. 214 (1 978) 7, 8, 12 N.Y. Times v. Dep of Justice, 872 F. Supp. 2d 309 (S.D.N.Y. 2012) 5 NAACP Legal Dtf & Educ. Fund, Inc. v. U.S. Dep't of Haus. & Urban Dev., No. 07 Civ. 3378 (GEL), 2007 WL 4233008 (S.D.N.Y. Nov. 30, 2 00 7) 15 National Archives & Records Administrat

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

ns Tire & Rubber Co., 437 U.S. 214 (1 978) 7, 8, 12 N.Y. Times v. Dep of Justice, 872 F. Supp. 2d 309 (S.D.N.Y. 2012) 5 NAACP Legal Dtf & Educ. Fund, Inc. v. U.S. Dep't of Haus. & Urban Dev., No. 07 Civ. 3378 (GEL), 2007 WL 4233008 (S.D.N.Y. Nov. 30, 2 00 7) 15 National Archives & Records Administrat

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

ns Tire & Rubber Co., 437 U.S. 214 (1 978) 7, 8, 12 N.Y. Times v. Dep of Justice, 872 F. Supp. 2d 309 (S.D.N.Y. 2012) 5 NAACP Legal Dtf & Educ. Fund, Inc. v. U.S. Dep't of Haus. & Urban Dev., No. 07 Civ. 3378 (GEL), 2007 WL 4233008 (S.D.N.Y. Nov. 30, 2 00 7) 15 National Archives & Records Administrat

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

upp. 2d 479, 518 (S.D.N.Y. 2010) (quotation marks and brackets omitted); see ACLU v. DOJ, 844 F.3d 126, 133 (2d Cir. 2016); NAACP Legal Def & Educ. Fund, Inc. v. U.S. Del)? of Haus. & 17 EFTA00069328 UrbanDev.,No. 07 Civ. 3378 (GEL), 2007 WL 4233008, at ■11 (S.D.N.Y. Nov. 30, 2007) ("Draft documents, b