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From: "M=, (USANYS)" alMIE> To: " SANYS)" I SANYS " SANYS" ' (USANYS " SANYS" (USANYS)" Cc: SaLISS)" (USANYS)" Subject: Epstein FOIA Update Date: Fri, 09 Apr 2021 23:21:46 +0000 All, I'm writing to bring everyone up to speed in the Epstein FOIA. We had a pretty rough, approximately 2 hour oral argument today before Judge Engelmayer. It may be easier to share the transcript (which I have same-day ordered and will circulate once received) and/or to talk things through on a call. In sum, the Court is very skeptical of the breadth of the 7(A) withholdings here and will enter an Order on Monday directing that the withheld documents be produced to the Court for in camera review. In connection with that, the Court will direct that any material withheld under 7(A) in connection with the Tartaglione case be specifically marked out as such (as compared to the broader set of material withheld on account of its likelihood of interference with Noel). Basically, the Court has co
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Case 1:20-cv-00833-PAE Document 52 (Ex Parte) Filed 04/28/21 Page 1 of 2
Case 1:20-cv-00833-PAE Document 52 (Ex Parte) Filed 04/28/21 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 April 28, 2021 Submitted Ex Pane and Under Seal By ECF The Honorable Paul A. Engelmayer United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOR"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times") seeking the release of certain records related to Jeffrey Epstein. I write respectfully to update the Court on the status of United States v. Noel, I 9-cr-830 (AT), and to explain the basis for the Government's request, submitted contemporaneously by public letter motion, to extend the deadlines for t
From: "a"
From: "a" <=MIMIM> To: 'S" aNIMIE> Subject: Fwd: Epstein FOIA Update Date: Fri, 09 Apr 2021 23:50:38 +0000 I called for clarification and apparently PAE was very skeptical of withholding w/r/t Tartaglione. He thinks we actually were narrowest in our withholding and PAE is wrong, but just something to be aware of White Plains Division O: C: Begin forwarded message: From: Date: April 9 2021 at 19:21:47 EDT To: Cc: Subject: Epstein FOIA Update All, I'm writing to bring everyone up to speed in the Epstein FOIA. We had a pretty rough, approximately 2 hour oral argument today before Judge Engelmayer. It may be easier to share the transcript (which I have same-day ordered and will circulate once received) and/or to talk things through on a call. In sum, the Court is very skeptical of the breadth of the 7(A) withholdings here and will enter an Order on Monday directing that the withheld documents be produced to the Court for in camera review. In connection with that, the
(USANYS)" alMliff'
From: (USANYS)" alMliff' To: (USANYS)" <MIMMIN> Cc: ' SANYS)" I. pANL'S I SANYS " Subject: Re: Epstein FOIA Update Date: Sat, 10 Apr 2021 13:07:48 +0000 Sounds good. Thanks, Sent from my iPhone On Apr 10, 2021, at 8:29 AM, (USANYS) alMIE> wrote: Thanks, M. Will review the transcript and then we can find a time to meet early in the week. It may make sense to meet first as a smaller group with youa to best understand the lay of the land and then loop in the substantive case teams. Sent from my iPhone On Apr 9, 2021, at 7:21 PM, All, (USANYS) ' IMIN > wrote: I'm writing to bring everyone up to speed in the Epstein FOIA. We had a pretty rough, approximately 2 hour oral argument today before Judge Engelmayer. It may be easier to share the transcript (which I have same-day ordered and will circulate once received) and/or to talk things through on a call. In sum, the Court is very skeptical of the breadth of the 7(A) withholdings here and will enter an Order on Mo
(USANYS)'
From: (USANYS)' To: "Strauss, Audrey (USANYS)" Cc:" USANYS (1 SANYS)' SANYS (USANYS "Loner an, Jessica (USANYS)" I (11SANYS (USANYS)" gig USANYS)" Sarah (USANYS)" Subject: Request from Judge Engelmayer in Times v. BOP, 20-cv-833 Date: Sat, 10 Apr 2021 03:57:46 +0000 Attachments: Draft_Transcript_of Final_Portion_of 04092 l_Oral_Argument,_Times_v_BOP,_20cv833.p df Audrey, I hope you're doing well. At an oral argument today, Judge Engelmayer asked me to convey a request to you regarding the Government's response to FOIA requests made by the New York Times seeking BOP documents related to Jeffrey Epstein. I will provide some background and paraphrase Judge Engelmayer's request here, but I am also attaching a draft transcript of the final portion of the oral argument because it may be most efficient to read the Court's request there directly, starting at page 11, line 15 of the attached. By way of background, Times v. BOP, 20-cv-833 (PAE), is a FOIA case where the
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From: ' To: ' Subject: RE: Email tom and re MCC Date: Thu, 24 Jun 2021 01:11:21 +0000 This looks good to me. From: Sent: Wednesday, June 23, 2021 7:20 PM To: Cc: Subject: Re: Email to and re MCC Thanks very much. Suggested edits below. My edit to the concluding language was to conform to the letter- submitted to PAE last month (that and I pulled off the docket today and had not seen before). Our read was that we told PAE we are withdrawing our 7a objections based on Noel due to the DPs, without any conditions (like the defendants complying with their DPs or the case actually being nolled). If that's accurate, then I think we should not give the impression that she is deciding anew whether to remove the 7a objections. Happy to discuss if you had a different understanding. On Jun 23, 2021, at 6:27 PM, wrote: Hi and I'm writing to give you an update on the Office of Inspector General interviews with Tova Noel and Michael Thomas, the two MCC guards that were charg
Case 1:20-cv-00833-PAE Document 12 Filed 04/15/20 Page 1 of 2
Case 1:20-cv-00833-PAE Document 12 Filed 04/15/20 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York 86 Cheettbers sum New York New Yoe* 10007 April 15, 2020 By ECF The Honorable Paul A. Engelmayer United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times"). The parties respectfully submit this joint letter pursuant to the Court's Orders of March 5 and 13, 2020. See Dkt. Nos. 8, 10. The initial pretrial conference in this matter is currently scheduled to be held at 11:00 AM on April 20, 2020. See Dkt. No. 10. The parties respectfully propose that the initial pretrial conference be adjourned if this
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