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and Michael Thomas On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and Thomas, they repeatedly failed to
uly 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 Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr
and Michael Thomas On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and Thomas, they repeatedly failed to
uly 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 Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr
and 2. On July 6, 2019, Epstein was arrested and thereafter incarcerated at the MCC until his death. 5. On July 10, 2019, Epstein was assigned to the Special Housing Unit ("SHU") at the MCC due to, among other things, a risk of suicidality and safety concerns relating to housing him with the MCC's general population.
3(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. DECLARATION OF RUSSELL CAPONE I, Russell Capone, hereby declare as follows: I. I am Counsel to the Acting United States Attorney in the United States Attorney's Office for the Southern District of New York ("USAO-SDNY"). I have served in this capacity since June 2020
el trial, and/or influence potential jurors' perceptions of witness testimony or evidence. II. One subcategory of these documents are records from the Special Housing Unit (the "SHU"), specifically rosters of inmates in the SHU on August 9 and 10, 2019, and SHU records showing which BOP employees conducted rounds in t
intiff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. SUPPLEMENTAL DECLARATION OF hereby declare as follows: I. I am Counsel to the Acting United States Attorney for the Southern District of New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details my service in this
ion in the incident report, listed at Entry 1 on the Updated Index, which would reveal specific steps taken in responding to an inmate emergency in the Special Housing Unit. Releasing this type of information would allow inmates to learn the manner in which MCC staff are likely to respond to emergencies and potentially
of Epstein's medical records, but withheld in full 12 pages for reasons explained at Paragraph 20 of the August 5, 2020, declaration of Counsel to the Acting United States Attorney Russell Capone. 14. The Updated Index corrects an inadvertent error that resulted in double counting of seventeen pages of emails listed
el trial, and/or influence potential jurors' perceptions of witness testimony or evidence. II. One subcategory of these documents are records from the Special Housing Unit (the "SHU"), specifically rosters of inmates in the SHU on August 9 and 10, 2019, and SHU records showing which BOP employees conducted rounds in t
HE NEW YORK TIMES COMPANY. Plaintiff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. reby declare as follows: I. I am Counsel to the Acting United States Attorney for the Southern District of New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details my service in this
and Michael Thomas On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and Thomas, they repeatedly failed to
uly 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 Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr
ion in the incident report, listed at Entry 1 on the Updated Index, which would reveal specific steps taken in responding to an inmate emergency in the Special Housing Unit. Releasing this type of information would allow inmates to learn the manner in which MCC staff are likely to respond to emergencies and potentially
of Epstein's medical records, but withheld in full 12 pages for reasons explained at Paragraph 20 of the August 5, 2020, declaration of Counsel to the Acting United States Attorney Russell Capone. 14. The Updated Index corrects an inadvertent error that resulted in double counting of seventeen pages of emails listed
el trial, and/or influence potential jurors' perceptions of witness testimony or evidence. II. One subcategory of these documents are records from the Special Housing Unit (the "SHU"), specifically rosters of inmates in the SHU on August 9 and 10, 2019, and SHU records showing which BOP employees conducted rounds in t
ff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. SUPPLEMENTAL DECLARATION OF I, hereby declare as follows: I. I am Counsel to the Acting United States Attorney for the Southern District of New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details my service in this
Entities connected to both Special Housing Unit and the Acting United States

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATION
Department of Justice
ORGANIZATIONNicholas Tartaglione
PERSONTova Noel
PERSONFBI
ORGANIZATIONCentral Office
ORGANIZATIONSouthern District
LOCATION
Ghislaine Maxwell
PERSONMichael Thomas
PERSON
United States
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSON
Prince Andrew
PERSONAction Review
ORGANIZATION
THE NEW YORK TIMES COMPANY
ORGANIZATION
United States Department of Justice
ORGANIZATION
Audrey Strauss
PERSON
Alberto Gonzales
PERSON