EFTA00031018.pdf

"THE NEW YORK TIMES COMPANY, Plaintiff, v. FEDERAL BUREAU OF PRISONS, Defendant. ... seek records related to the incarceration of Jeffrey Epstein"

"I, Russell Capone, hereby declare as follows: I am Counsel to the Acting United States Attorney for the Southern District of New York (USAO-SDNY)"

"seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center (MCC)"

"I submit this declaration in further support of BOP's motion for summary judgment... the risks of interference with the Noel proceedings are heightene"

"Russell Capone Counsel to the Acting United States Attorney United States Attorney's Office for the Southern District of New York"

"interfere with the Tartaglione prosecution. ... United States v. Tartaglione, No. 16 Cr. 832 (KMK)"

"certain psychological notes and records of Epstein prepared by BOP may be trial exhibits"

"Epstein's apparent suicide attempt on July 23, 2019"

"conversations with members of the Noel and Tartaglione prosecution teams at the USAO-SDNY"

"conversations with members of the Noel and Tartaglione prosecution teams at the USAO-SDNY"

"Tartaglione's interactions with Epstein in July 2019 have been placed at issue by Tartaglione's defense counsel"

"Public disclosure of the 7(A) Returned Records could reasonably be expected to interfere with the pending Noel prosecutions."

"premature disclosure of these records could reasonably be expected to prejudice potential jurors for or against the defendants in the Noel action"

"records provided back to BOP by the Office of the Inspector General of the Department of Justice (OIG)"

"I declare under penalty of perjury that the foregoing is true and correct... Russell Capone Counsel to the Acting United States Attorney"