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From: ' (USANYS)" ' IMIE> To: =a:Sr <a l Cc: allitaa" <a, "- (USANYS)" (USANYS)" Subject: MCC Discovery Requests Date: Mon, 10 Feb 2020 17:32:02 +0000 Attachments: Response_to_1-24-20 _letter from_the_Govemment.pdf; Michael_Thomas_- _Discovery_Request.pdf Hi Chiefs, we received the attached from defense counsel and would like to discuss our proposed responses with you. Let us know if you have time this week, thanks. Assistant United States Attorney Southern District of Ne EFTA00075608
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Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25
Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AUDREY STRAUSS Acting United States Attorney Southern District of New York 86 Chambers Street, Third Floor New York, New York 10007 Assistant United States Attorney — Of Counsel — EFTA00099598 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 2 of 25 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 I. BOP's Productions Since August 5, 2020 2 II. BOP's Withholdings of Returned Records 3 A. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 7(A) 4 B. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 6
Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 1 of 30
Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 1 of 30 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. 20 Civ. 833 (PAE) MEMORANDUM OF LAW IN SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AUDREY STRAUSS Acting United States Attorney Southern District of New York 86 Chambers Street, Third Floor T - I . ../11".• EFTA00071554 Case 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 FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Search for Responsive Records 5 III. BOP's Withholdings Were Proper 6 IV. BOP Ha
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 1 of 13
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. DECLARATION OF RUSSELL CAPONE I, Russell Capone, hereby declare as follows: I. I am Counsel to the Acting United States Attorney in the United States Attorney's Office for the Southern District of New York ("USAO-SDNY"). I have served in this capacity since June 2020. Prior to my current role, I served as Deputy Chief and then Chief of the Public Corruption Unit in the USAO-SDNY from July 2017 and as an Assistant United States Attorney from January 2011. I supervised the Noel prosecution directly in my prior role as Chief of the Public Corruption Unit, and I play a supervisory role over both the Noel and Tartaglione prosecutions in my current role as Counsel to the Acting United States Attorney. 2. I am familiar with the Freedom of Information Act r
90A-NY-3151227 Serial 64
90A-NY-3151227 Serial 64 FD-302 (Rev. 5-8-10) •1 of 1. FEDERAL BUREAU OF INVESTIGATION Date of entry 08/28/2019 On August 16, 2019, at the Metropolitan Correctional Center (MCC) III , New York, NY, Special Agent (SA) , SA , TFO , OIG Investigator and MCC Lt. interviewed LEONARDO FERNANDEZ, MCC Inmate #86824-054. After being advised of the identities of the agents and the purpose of the interview, FERNANDEZ provided the following information: On Friday (August 09, 2019), FERNANDEZ was housed in Cell 218 on L-TIER of the Special Housing Unit within MCC. He received a visit from his girlfriend, TYRELYSHANTI CRIAG, that day. He was suspected of receiving contraband at the visit and was placed in the dry room for approximately 25 hours. FERNANDEZ was then moved to K tier Cell 111. FERNANDEZ last day being housed in L Tier was Friday (August 9, 2019) prior to his visit. FERNANDEZ remembers that JEFFREY EPSTEIN would be in legal from approximately 9am to 9pm and he was
Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25
Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AUDREY STRAUSS Acting United States Attorney Southern District of New York 86 Chambers Street, Third Floor New York. New York 10007 EFTA00071584 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 2 of 25 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 I. BOP's Productions Since August 5, 2020 2 II. BOP's Withholdings of Returned Records 3 A. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 7(A) 4 B. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 6 and 7(C) ...4 C. Withholding of Some Returned
Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 1 of 30
Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 1 of 30 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. 20 Civ. 833 (PAE) MEMORANDUM OF LAW IN SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AUDREY STRAUSS Acting United States Attorney Southern District of New York 86 Chambers Street, Third Floor New York, New York 10007 Telephone: (212) 637-2715 Facsimile: (212) 637-2717 STEVEN J. KOCHEVAR Assistant United States Attorney — Of Counsel — EFTA00075437 Case 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 FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment S
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