U.S. Department of Justice
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U.S. Department of Justice United States Attorney Southern District of New York October 13, 2020 BY USAfx Montell Figgins, Esq. Law Offices of Montell Fi ins Re: United States v. Michael Thomas, No. 19 Cr. 830 Dear Counsel: This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure. This letter and the materials identified herein are subject to the protective order entered in this case on December 16, 2019, and have been designated as "Protected Materials" as defined in the order where noted below. Accordingly, the materials and information identified herein shall not be disclosed to any third party or referenced publicly except as set forth in the protective order. EFTA00092389 Page 2 Additionally, the Government is producing the following materials only to your client: Very truly yours, AUDREY STRAUSS Acting United States Attorney for the Southern District of New York By: /5/ Assistant United States Attorneys
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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
U.S. Department of Justice
U.S. Department of Justice ".1. • ,•... United States Attorney Southern District of New York The Silvio J. Mono Building One Saint Andrew's Plaza New York. New York 10007 October 14, 2020 BY USAfx Montell Figgins, Esq. Law Offices of Montell Figgins 17 Academy Street, Suite 305 Newark, NJ 07102 Re: United States v. Michael Thomas, No. 19 Cr. 830 Dear Counsel: This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure. This letter and the materials identified herein are subject to the protective order entered in this case on December 16, 2019, and have been designated as "Protected Materials" as defined in the order where noted below. Accordingly, the materials and information identified herein shall not be disclosed to any third party or referenced publicly except as set forth in the protective order. Description Bates Numbers Classification Pursuant to Protective Order SDNY_00008724 — SDNY_000 13257 Confident
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 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 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 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 Telephone: (212) 637-2715 Facsimile: (212) 637-2717 STEVEN J. KOCHEVAR Assistant United States Attorney — Of Counsel — EFTA00088605 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. Wit
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