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

on of the law." Exemption 7(E) contains "two alternative clauses," one covering "techniques and procedures," and the other addressing "guidelines." Allard K. Lowenstein Int'l Human Rights Project v. Dep 't of Homeland Sec., 626 F.3d 678, 680-81 (2d Cir. 2010). The first clause of Exemption 7(E) provides categorical

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

on of the law." Exemption 7(E) contains "two alternative clauses," one covering "techniques and procedures," and the other addressing "guidelines." Allard K. Lowenstein Int'l Human Rights Project v. Dep 't of Homeland Sec., 626 F.3d 678, 680-81 (2d Cir. 2010). The first clause of Exemption 7(E) provides categorical

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

on of the law." Exemption 7(E) contains "two alternative clauses," one covering "techniques and procedures," and the other addressing "guidelines." Allard K. Lowenstein Int'l Human Rights Project v. Dep 't of Homeland Sec., 626 F.3d 678, 680-81 (2d Cir. 2010). The first clause of Exemption 7(E) provides categorical

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

dure' is `a particular way of doing or going about the accomplishment of something.'" ACLU v. DHS, 243 F. Supp. 3d 393, 402 (S.D.N.Y. 2017) (quoting Allard K. Lowenstein Int'l Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678, 682 (2d Cir. 2010)); see NYCLU v. DHS, 771 F. Supp. 2d 289, 292 (S.D.N.Y. 2011)

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

dure' is `a particular way of doing or going about the accomplishment of something.'" ACLU v. DHS, 243 F. Supp. 3d 393, 402 (S.D.N.Y. 2017) (quoting Allard K. Lowenstein Int'l Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678, 682 (2d Cir. 2010)); see NYCLU v. DHS, 771 F. Supp. 2d 289, 292 (S.D.N.Y. 2011)

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

edure' is `a particular way of doing or going about the accomplishment of something." ACLU v. DHS, 243 F. Supp. 3d 393, 402 (S.D.N.Y. 2017) (quoting Allard K. Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678, 682 (2d Cir. 2010)); see NYCLU v. DHS, 771 F. Supp. 2d 289, 292 (S.D.N.Y. 2011)