DOJ-OGR-00000744.jpg
522 KB
Extraction Summary
3
People
3
Organizations
0
Locations
1
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing / court motion (page 4 of 4)
File Size:
522 KB
Summary
This is the final page of a legal filing in the Epstein case (1:19-cr-00490) submitted by Kel McClanahan, counsel for MSW Media. The filing argues that the Court should not issue an opinion on the Government's redaction of non-victim PII, as this could negatively influence a separate pending FOIA case. It notes that the Government does not oppose MSW Media's intervention and that the author did not consult with the former defendant's (Epstein's) representatives. The header date appears to contain a typo (reading '25' instead of '19').
People (3)
| Name | Role | Context |
|---|---|---|
| Kel McClanahan | Counsel for Proposed Intervenor |
Signatory of the document representing MSW Media.
|
| Judge Berman | Judge |
Presiding judge mentioned in a hypothetical argument the Government might make ('Judge Berman agreed that this inform...
|
| Former defendant | Defendant |
Likely Jeffrey Epstein (implied by case number 1:19-cr-00490). McClanahan notes he did not consult with their represe...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| MSW Media |
The Proposed Intervenor in the case.
|
|
| The Government |
Refers to the prosecution/DOJ, mentioned regarding their position on intervention and redaction motions.
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|
| DOJ-OGR |
Department of Justice - Office of Government Information Services (implied by footer stamp).
|
Timeline (1 events)
Relationships (1)
Signed as 'Counsel for Proposed Intervenor' for MSW Media
Key Quotes (3)
"We are concerned that, if this Court explicitly or implicitly blesses the Government’s proposed redactions of non-victim-related personally identifiable information... that opinion will be treated as a proverbial thumb on the scale in our FOIA case"Source
DOJ-OGR-00000744.jpg
Quote #1
"The Government takes no position on the intervention of MSW Media."Source
DOJ-OGR-00000744.jpg
Quote #2
"I did not consult with a representative for the former defendant."Source
DOJ-OGR-00000744.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,358 characters)
Case 1:19-cr-00490-RMB Document 64 Filed 07/25/25 Page 4 of 4
withheld is a question best left to the court adjudicating that future case. We are concerned that,
if this Court explicitly or implicitly blesses the Government’s proposed redactions of non-victim-
related personally identifiable information (even in passing), that opinion will be treated as a
proverbial thumb on the scale in our FOIA case without materially affecting the Court’s decision
in this case.
if this Court explicitly or implicitly blesses the Government’s proposed redactions of non-victim-
related personally identifiable information (even in passing), that opinion will be treated as a
proverbial thumb on the scale in our FOIA case without materially affecting the Court’s decision
in this case.
In other words, if this Court mentions in its decision that it was swayed at all by the
Government’s promise to redact personally identifiable information, we are concerned that the
Government will then argue in its FOIA case that “Judge Berman agreed that this information
should not be publicly disclosed.” Therefore, we respectfully request that this Court not take the
Government’s statements regarding non-victim-related personally identifiable information into
account when reaching its decision regarding the Government’s motion, and we further request
that the Court specify that it is not opining on that question, should it grant the Government’s
motion.
Government’s promise to redact personally identifiable information, we are concerned that the
Government will then argue in its FOIA case that “Judge Berman agreed that this information
should not be publicly disclosed.” Therefore, we respectfully request that this Court not take the
Government’s statements regarding non-victim-related personally identifiable information into
account when reaching its decision regarding the Government’s motion, and we further request
that the Court specify that it is not opining on that question, should it grant the Government’s
motion.
The Government takes no position on the intervention of MSW Media. I did not consult
with a representative for the former defendant.
with a representative for the former defendant.
Sincerely,
[Signature]
Kel McClanahan
Counsel for Proposed Intervenor
[Signature]
Kel McClanahan
Counsel for Proposed Intervenor
DOJ-OGR-00000744
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