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, and thereafter did perform a crime of violence to further the unlawful activity, and did aid and abet the same, and death resulted, to wit, after Hector 12 ' EFTA00039954 Came F 23-w-00832-RAE 02amanertt 2242. Rad 08/051/IND Pagg aff 211 Gutierrez accompanied Martin Luna to the Likquid Lounge, whe
n set. 11. Tartaglione has been detained since he was arrested on December 19, 2016. For certain periods of his detention, including in July 2019, Tartaglione was housed at the MCC. In early July 2019, Tartaglione was transferred to the MCC's SHU. For a time, including on July 23, 2019, Tartaglione was ho
(KMK). True and correct copies of the Indictment filed in Noel on November 19, 2019 (the "Noel Indictment"), and the Superseding Indictment filed in Tartaglione on April 16, 2019 (the "Tartaglione Indictment"), are attached hereto as Exhibits A and B, respectively. The statements contained in this declarati
, and thereafter did perform a crime of violence to further the unlawful activity, and did aid and abet the same, and death resulted, to wit, after Hector 12 ' EFTA00075428 Came F 23-w-00832-RAE 02amanertt 2242. Rad 08/051/IND Pagg aff 211 Gutierrez accompanied Martin Luna to the Likquid Lounge, whe
n set. 11. Tartaglione has been detained since he was arrested on December 19, 2016. For certain periods of his detention, including in July 2019, Tartaglione was housed at the MCC. In early July 2019, Tartaglione was transferred to the MCC's SHU. For a time, including on July 23, 2019, Tartaglione was ho
(KMK). True and correct copies of the Indictment filed in Noel on November 19, 2019 (the "Noel Indictment"), and the Superseding Indictment filed in Tartaglione on April 16, 2019 (the "Tartaglione Indictment"), are attached hereto as Exhibits A and B, respectively. The statements contained in this declarati
pervised 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 requests fil
Page: EFTA00015438 →(KMK). True and correct copies of the Indictment filed in Noel on November 19, 2019 (the "Noel Indictment"), and the Superseding Indictment filed in Tartaglione on April 16, 2019 (the "Tartaglione Indictment"), are attached hereto as Exhibits A and B, respectively. The statements contained in this declarati
Page: EFTA00015439 →5447 --- PAGE BREAK --- Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 11 of 13 defendants') ability to seat a fair and impartial jury in Tartaglione, particularly for purposes of a potential penalty-phase hearing required by 18 U.S.C. § 3593, by influencing potential juror perceptions of any int
Page: EFTA00015448 →pervised 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 requests fil
Page: EFTA00031025 →(KMK). True and correct copies of the Indictment filed in Noel on November 19, 2019 (the "Noel Indictment"), and the Superseding Indictment filed in Tartaglione on April 16, 2019 (the "Tartaglione Indictment"), are attached hereto as Exhibits A and B, respectively. The statements contained in this declarati
Page: EFTA00031026 →1034 --- PAGE BREAK --- Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 11 of 13 defendants') ability to seat a fair and impartial jury in Tartaglione, particularly for purposes of a potential penalty-phase hearing required by 18 U.S.C. § 3593, by influencing potential juror perceptions of any int
Page: EFTA00031035 →Entities connected to both Hector and Nicholas Tartaglione

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Department of Justice
ORGANIZATIONJermaine Ruan
PERSON
Geoffrey S. Berman
PERSONTova Noel
PERSON
United States
LOCATION
Richard Kahn
PERSONthe Southern District
LOCATION
Donald Trump
PERSONMichael Thomas
PERSON
Marc Rich
PERSON
Richard M. Berman
PERSON
New York
LOCATION
Alan Dershowitz
PERSONNICHOLAS
PERSONChristenson
PERSON
Vicky Ward
PERSON