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20 Eil v. U.S. Drug Enf 't Admin., 878 F.3d 392 (1st Cir. 2017) 19 EFTA00071556 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 4 of 30 Ferguson v. FBI, 957 F.2d 1059 (2d Cir. 1992) 8 Ferguson v. FBI, No. 89 Civ. 5071 (RPP), 1995 WL 329307 (S.D.N.Y. June 1, 19 95) 5 Garcia v. U.S. Dept o
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
20 Eil v. U.S. Drug Enf 't Admin., 878 F.3d 392 (1st Cir. 2017) 19 EFTA00075439 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 4 of 30 Ferguson v. FBI, 957 F.2d 1059 (2d Cir. 1992) 8 Ferguson v. FBI, No. 89 Civ. 5071 (RPP), 1995 WL 329307 (S.D.N.Y. June 1, 19 95) 5 Garcia v. U.S. Dept o
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
20 Eil v. U.S. Drug Enf 't Admin., 878 F.3d 392 (1st Cir. 2017) 19 EFTA00088673 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 4 of 30 Ferguson v. FBI, 957 F.2d 1059 (2d Cir. 1992) 8 Ferguson v. FBI, No. 89 Civ. 5071 (RPP), 1995 WL 329307 (S.D.N.Y. June 1, 19 95) 5 Garcia v. U.S. Dept o
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
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 FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
$ LWOP Allard-rich $ LWOP(M) Albanese, P Crawford, S Johnson, lb Shakir. a 9 AWOL Cruz, J Ortiz, day $ Rivera, c $ Fehciano. W Peden, A Ferguson, S Pelrowski, r $ Matthews, A Flaida.1. SUSPENSION Akparanta, c $ OFFICIAL TIME Covington. T 7/23/2019 7:02:34 AM EFTA00052829 TuesdayJuly
d been harassing him. He stated that the inmate had indicated that he'd informed his attorney of this matter. I photographed and spoke with inmate Tartaglione, Nicholas #78514-054 who stated that he was asleep with his headphones on when he felt something hit his legs and said, "Jeff, what you're doing?"
nts afterwards, inmate Epstein became responsive. While observing inmate Epstein he sat up on the bed and began telling me that he think his Bunkie, Tartaglione, Nicholas #78514-054 tried to kill him. Inmate Epstein also stated that his Bunkie also tried to extort money from him and stated that if he didn't
do no something that isn't there. Additionally, Epstein stated he can recall an incident that occurred two days prior wh went out to court and when Tartaglione returned he was upset. Epstein stated he attempted to talk to Tartagl called him a pedophile. Epstein also stated he knew Tartaglione was upset and
for the Northern District of Mississippi Thomas Ferguson III to be United States Attorney for the Wester
-trafficking charges in July 2019, Epstein was transferred to the Metropolitan Correctional Center in Manhattan — where he shared a cell with ex-cop Nicholas Tartaglione, who was awaiting trial before being convicted on a quadruple-murder charge. Tartaglione, 57, now claims that Epstein, who died a month after being
for the Northern District of Mississippi Thomas Ferguson III to be United States Attorney for the Wester
-trafficking charges in July 2019, Epstein was transferred to the Metropolitan Correctional Center in Manhattan — where he shared a cell with ex-cop Nicholas Tartaglione, who was awaiting trial before being convicted on a quadruple-murder charge. Tartaglione, 57, now claims that Epstein, who died a month after being
Matas, a $ LWOP Avaragith $ LWOP(M) Albanese, P Crawford. S Johnson, sh Shalt. s AWOL J Oft, day $ Rivera, c $ Fe:Jciano. W Parlays, A Ferguson. S Petrowskl, Mathews, A Pipkin, L SUSPENSION AkPeranb3. c $ OFFICIAL TIME Covington, T tt23)2019 7:02:34 AM EFTA00049130 Tuesday July 23,
nts aftenvards, inmate Epstein became responsive. While observing inmate Epstein he sat up on the bed and began telling me that he think his Bunkie, Tartaglione, Nicholas #78514-054 tried to kill him. Inmate Epstein also stated that his Bunkic also tried to extort money from him and stated that if he didn't
S LWOP Allard-rich $ LWOP(M) Albanese, P Crawford, S Johnson, sh Shaldr, s $ AWOL Cruz J Ortiz. day $ Rivera. c Feliciano, W Perlaza, A Ferguson, S Petrowski, r $ Matthews, A Pipkin, L SUSPENSION Akparanta, c $ OFFICIAL TIME Covington, T 1/23/2019 7:02.34 AM EFTA00049487 Tuesday Jul
nts afterwards, inmate Epstein became responsive. While observing inmate Epstein he sat up on the bed and began telling me that he think his Bunkie, Tartaglione, Nicholas #78514-054 tried to kill him. Inmate Epstein also stated that his Bunkic also tried to extort money from him and stated that if he didn't
Entities connected to both Sarah Ferguson and Nicholas Tartaglione

Jeffrey Epstein
PERSON
Prince Andrew
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Richard Kahn
PERSON
George W. Bush
PERSON
Marc Rich
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSON
U.S. Virgin Islands
LOCATION
Julie K. Brown
PERSON
Bill Clinton
PERSON
Woody Allen
PERSON
Prince Charles
PERSON
Alan Dershowitz
PERSONFederal Bureau of Prisons
ORGANIZATION
Paul Ryan
PERSON
Stephen Hawking
PERSON