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w 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 Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has withheld pursuant to exemptions 5,
Honorable Richard M. Berman, after which the Court granted the government's motion for remand and denied Epstein's motion for pretrial release. See Noel Indictment(' 10. 6. On July 23, 2019, MCC officers responded to an emergency call and found Epstein on the floor of his cell with a strip of bedsheet around
w 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 Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has withheld pursuant to exemptions 5,
July 23, 2019, MCC officers responded to an emergency call and found Epstein on the floor of his cell with a strip of bedsheet around his neck. See Noel Indictment 1 11. Michael Thomas, a correctional officer at the MCC and one of the defendants in the Noel case, was one of the MCC officials who responded to t
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
United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment. The Noel prosecution is pending before the Honorable Analisa Torres, U.S.D.J., with trial scheduled to begin on January 4, 2021. Capone DecL ¶ 9.
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
United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment. The Noel prosecution is pending before the Honorable Analisa Torres, U.S.D.J., with trial scheduled to begin on January 4, 2021. Capone DecL ¶ 9.
w 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 Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has withheld pursuant to exemptions 5,
July 23, 2019, MCC officers responded to an emergency call and found Epstein on the floor of his cell with a strip of bedsheet around his neck. See Noel Indictment 1 11. Michael Thomas, a correctional officer at the MCC and one of the defendants in the Noel case, was one of the MCC officials who responded to t
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
United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment. The Noel prosecution is pending before the Honorable Analisa Torres, U.S.D.J., with trial scheduled to begin on January 4, 2021. Capone DecL ¶ 9.
Entities connected to both Metropolitan Correctional Center and Noel Indictment

Jeffrey Epstein
PERSONSpecial Housing Unit
ORGANIZATION
New York
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSON
United States
LOCATION
Geoffrey S. Berman
PERSONNicholas Tartaglione
PERSONTova Noel
PERSONMichael Thomas
PERSON
Richard M. Berman
PERSON
Alberto Gonzales
PERSON
Vicky Ward
PERSON
Sarah Ferguson
PERSON
Supreme Court
ORGANIZATIONPsychology Services
ORGANIZATION
THE NEW YORK TIMES COMPANY
ORGANIZATION
The New York Times
ORGANIZATIONControl Center
ORGANIZATION
Audrey Strauss
PERSON