Epstein Secrets

y service in this capacity and prior service in the USAO-SDNY. As noted therein, I am familiar with the Freedom of Information Act requests filed by the New York Times Company (the "FOIA Requests") that are the subject of this case, which seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Cor

this declaration are based on my personal knowledge, documents maintained in the files of the USAO-SDNY, conversations with members of the Noel and Tartaglione prosecution teams at the USAO-SDNY, public court filings, and conclusions made in accordance therewith. EFTA00015517 --- PAGE BREAK --- Case 1:2

ed in the psychological records and in the entry in the lieutenant's log may be relevant evidence in any possible penalty phase of the case against Tartaglione. In that event, premature release of the information could reasonably be expected to 6 EFTA00015522 --- PAGE BREAK --- Case 1:20-cv-00833-PAE Do

thouse White Plains, NY 10601 Re: United States v. Tartaglione, 16-cr-832 — Unsealing of Judicial Records Dear Judge Karas: I write on behalf of The New York Times Company and reporter Benjamin Weiser (jointly, "The Times") regarding the Government's application to seal two recent filings in this case. The Times agree

d States District Judge The Hon. Charles L. Brieant Jr. Federal Buildin and United States Courthouse White Plains, NY 10601 Re: United States v. Tartaglione, 16-cr-832 — Unsealing of Judicial Records Dear Judge Karas: I write on behalf of The New York Times Company and reporter Benjamin Weiser (jointly

ured in Jail Cell, New York Times (July 25, 2019) htips://nyti.ms/2kbOXbe. 9 See, e.g., Emily Saul, Jail guards threatening former Epstein cellmate Nicholas Tartaglione: lawyer, New York Post (Aug. 20, 2019), httos://bit.lv/2m2hiFg. EFTA00017100

y service in this capacity and prior service in the USAO-SDNY. As noted therein, I am familiar with the Freedom of Information Act requests filed by the New York Times Company (the "FOIA Requests") that are the subject of this case, which seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Cor

this declaration are based on my personal knowledge, documents maintained in the files of the USAO-SDNY, conversations with members of the Noel and Tartaglione prosecution teams at the USAO-SDNY, public court filings, and conclusions made in accordance therewith. EFTA00031018 --- PAGE BREAK --- Case 1:2

ed in the psychological records and in the entry in the lieutenant's log may be relevant evidence in any possible penalty phase of the case against Tartaglione. In that event, premature release of the information could reasonably be expected to 6 EFTA00031023 --- PAGE BREAK --- Case 1:20-cv-00833-PAE Do

ember 10, 2019 4:46 PM To: Cc: Davi • McCraw Subject: US v. Tartaglione, 16-cr-832 - Unsealing of Records All, Attached is a letter on behalf of the New York Times Company and reporter Ben Weiser regarding the above- referenced case, which was sent to the Court today by fax. Regards, Al-Amyn Sumar Legal Department T

From: To: Cc: Subject: FW: US v. Tartaglione, 16-cr-832 - Unsealing of Records Date: Tue, 10 Sep 2019 20:56:29 +0000 Attachments: NYTLEGAL-_64879-v2-Tartaglione_Access_Letter.pdf See attached

tember 10, 2019 4:46 PM To: Cc: David McCraw Subject: US v. Tartaglione, 16-cr-832 - Unsealing of Records All, Attached is a letter on behalf of the New York Times Company and reporter Ben Weiser regarding the above- referenced case, which was sent to the Court today by fax. Regards, Al-Amyn Sumar Legal Department C

From: To: Cc: Subject: FW: US v. Tartaglione, 16-cr-832 - Unsealing of Records Date: Tue, 10 Sep 2019 21:00:44 +0000 Attachments: NYTLEGAL-_64879-v2-Tartaglione_Access_Letterpdf FYI — As disc

exander Klein; Donna Aldca. Cc: David McCraw Subject: US v. Tartaglione, 16-cr-832 - Unsealing of Records All, Attached is a letter on behalf of the New York Times Company and reporter Ben Weiser regarding the above- referenced case, which was sent to the Court today by fax. Regards, Al-Amyn Sumar Legal Department T

From: Bruce Barket To: "'Sumar, Al-Amyn'" Aida Leisenring" , Alexander Klein "Donna Aldea" Cc: David McCraw Subject: RE: US v. Tartaglione, 16-cr-832 - Unsealing of Records Date: Tue, 10 Sep 2019 20:52:10 +0000 Received. Thank you. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea &

nger exists on the backup system because of a technical error. See Letter from the Government dated January 9, 2020, Dkt. No. 182, United States v. Tartaglione, No. 16-cr-832 (KMK). 30. SUICIDE ATTEMPT AND SUICIDE RECORDS - Based on the experience and training of myself and other staff involved in searchi

ce of Information Policy Suite 11050 1425 New York Avenue, NW Washington, DC 20530.0001 Telephone: (202) 514-3642 Alexandra Perloff-Giles, Esq. The New York Times Company 620 8th Avenue Re: Appeal No. DOJ-AP-2020-000123 New York, NY 10018 Request No. 2019-05665 [email protected] CDT:CCG VIA: Email Dear