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cFarland, declare as follows: 1.1 am employed by the United States Department of Justice, Federal Bureau of Prisons ("BOP"), as a Staff Attorney at the Metropolitan Correctional Center ("MCC"). My employment history with the BOP is described in a declaration I submitted in the above- captioned case on August 5, 2020 (the "Declarati
Page: EFTA00015515 →RICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, v. FEDERAL BUREAU OF PRISONS, Defendant. 20-CV-00833 (PAE) SUPPLEMENTAL DECLARATION OF NICOLE MCFARLAND 1, Nicole McFarland, declare as follows: 1.1 am employed by the United States Department of Justice, Federal Bureau of Prisons ("BOP"), as a Staff
Page: EFTA00015515 →) Dear Judge Engelmayer: We write in advance of tomorrow's conference to further update the Court regarding Justin Rivera's access to discovery at the Metropolitan Correctional Center ("MCC") and his access to counsel. i. Mr. Rivera's Access to His Laptop As we previously indicated, Mr. Rivera received his laptop on Tuesday, D
Page: EFTA00016118 →access to his laptop from December 11, 2020 until December 14, 2020. In response to MCC's non-compliance, Your Honor ordered that general counsel, Nicole McFarland file a daily letter with the Court regarding Mr. Rivera's access to his laptop. Upon review of such letters, it is correct that Mr. Rivera did not a
Page: EFTA00016118 →ictment, Dkt. No. 2, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). Epstein was arrested on July 6, 2019, and thereafter incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone
the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be likely to have records responsive to the Times's request and identified eight suc
RELIMINARY STATEMENT Financier Jeffrey Epstein's suicide in August 2019, and subsequent revelations about what Attorney General William Barr called the Metropolitan Correctional Center's (MCC) "failure to adequately secure this prisoner," led to widespread calls for accountability and reform. Ali Watkins, Katie Benner & Danielle Ivo
l (`OIG') on or about August 22, 2019," and therefore "the BOP is no longer in possession of the log books" (Christenson Decl. 1 13; Declaration of Nicole McFarland, ECF No. 23 [hereinafter "McFarland Decl."], at ¶ 8). But, as BOP concedes, BOP received a FOIA request from The Times on August 13, 2019, seeking
ictment, Dkt. No. 2, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). Epstein was arrested on July 6, 2019, and thereafter incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone
the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be likely to have records responsive to the Times's request and identified eight suc
RELIMINARY STATEMENT Financier Jeffrey Epstein's suicide in August 2019, and subsequent revelations about what Attorney General William Barr called the Metropolitan Correctional Center's (MCC) "failure to adequately secure this prisoner," led to widespread calls for accountability and reform. Ali Watkins, Katie Benner & Danielle Ivo
l (`OIG') on or about August 22, 2019," and therefore "the BOP is no longer in possession of the log books" (Christenson Decl. 1 13; Declaration of Nicole McFarland, ECF No. 23 [hereinafter "McFarland Decl."], at ¶ 8). But, as BOP concedes, BOP received a FOIA request from The Times on August 13, 2019, seeking
ictment, Dkt. No. 2, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). Epstein was arrested on July 6, 2019, and thereafter incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone
the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be likely to have records responsive to the Times's request and identified eight suc
ect: draft >» Please review " 08/13/2019 09:02 >» Today, the Attorney General directed the Bureau of Prisons to temporarily assign the warden at the Metropolitan Correctional Center in New York to the Bureau's Northeast Regional Office pending the outcome of the FBI and OIG investigations into the apparent suicide of Jeffrey Ep
ame Cody Kkrier Entail cicinier@bortigov (lull) 77BC0440-091334:000-8F07-909C8F0A 1644 Distribution Type CC Recipient Ts-pc User Recipient Nicole McFarland Display Name Nicole McFaituld Email till D C4117510-04FF-00C0-B3IC-4A46EB8DCC96 Distribution 1 ype CC Recipient Type User Recipient NYM/Ex
an email dated August 13, 2019, the BOP received a FOIA request from Plaintiff. The FOIA request sought documents "about Jeffrey Epstein who died at the Metropolitan Correctional Center (MCC) on Aug. 10, 2019." See Attachment 1, Plaintiff's FOIA request dated August 13, 2019. Specifically, Plaintiff sought the following records: (1
Page: EFTA00015362 →r Scott; (8) Associate Warden Charisma Edge; (9) Associate Warden Brian Best; (10) Executive Assistant Lee Plourde; (11) Supervisory Attorney Nicole McFarland; 12) Captain Jermaine Darden; and (13) Chief of Psychology Elissa Miller. 45. Based on the scope of the FOIA request, the search terms used for
Page: EFTA00015380 →Entities connected to both Metropolitan Correctional Center and Nicole McFarland

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATION
Department of Justice
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONPark Row
LOCATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATIONthe Southern District
LOCATION
George W. Bush
PERSON
United States
LOCATION
Julie K. Brown
PERSONLeon Black
PERSON
Donald Trump
PERSON
Geoffrey S. Berman
PERSONNicholas Tartaglione
PERSON
William Barr
PERSON
Prince Andrew
PERSONCentral Office
ORGANIZATIONTova Noel
PERSONMartin Weinberg
PERSON