Epstein Secrets

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

61 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

92), but lbJecause the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice,331 F.3d 918, 926 Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

44 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

92), but lbJecause the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice,331 F.3d 918, 926 Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

78 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

92), but lbJecause the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice,331 F.3d 918, 926 Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal

48 Re: FOIA Case Number 76098 - Jeffrey E. Epstein Dear FOIA Appeals Officer: This is a timely appeal pursuant to 5 U.S.C. §552(a)(6), concerning the United States National Security Agency's (the "Agency") denial of a request for records within its control in Case Number 76098. I am writing this letter on beha

oreign Surveillance Program and the Metadata Program. Inasmuch as Epstein is a United States Citizen who resides in the U. S. Virgin Islands, he is a United States Person, and Section 702 of FISA, would prohibit the Agency from conducting targeted surveillance of Epstein either in the United States or indeed a

ACLU v. Dep't of Def, 389 F. Supp. 2d 547, 561, 565-66 2005) (rejecting government's Glomar response as to one part of plaintiffs' FOIA request); Nat'l Sec. Archive v. CIA, No. 99-1160, slip op. at 15-16, 19 (=. July 31, 2000) (holding that CIA had waived Glomar response by previous official disclosur