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to begin on January 4, 2021. 3 EFTA00039897 Case 1:20-cv-00833-PAE Document 21 Filed 08/05/20 Page 4 of 13 The Prosecution and Incarceration of Nicholas Tartaglione 10. In a superseding indictment filed on April 16, 2019, Nicholas Tartaglione was charged with one count of conspiracy to distribute narcotics, in
n set. II. 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
itle 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is pending before the Hon
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
iminal Proceedings Against Nicholas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
iminal Proceedings Against Nicholas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-
e of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put di
Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Sear
taglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the allege
iminal Proceedings Against Nicholas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-
of inmates to choose from yet I was their first choice," Tartglione wrote. Epstein's first attempted suicide on July 23 in the cell he shared with Tartaglione. Sources previously told The News that Tartaglione believed he may have saved Epstein's life by quickly alerting jail staff to the attempted hangin
Page: EFTA00009966 →ribute over five kilos of cocaine. Prosecutors say two of the victims had ties to a Mexican drug cartel. The four men's bodies were found buried on Tartaglione's sprawling animal rescue farm in Otisville, Orange County. Tartaglione has been locked up since December 2016 and still does not have a trial date.
Page: EFTA00009967 →on at the entire situation," Barket said. The musclebound ex-cop is charged with killing Martin Luna, 41, Hector Santiago, 32, Miguel Luna, 25, and Hector Gutierrez, 43, in April 2016, as well as conspiring to distribute over five kilos of cocaine. Prosecutors say two of the victims had ties to a Mexican drug ca
Page: EFTA00009967 →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 →itle 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is pending before the Hon
Page: EFTA00015441 →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 →itle 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is pending before the Hon
Page: EFTA00031028 →Entities connected to both Nicholas Tartaglione and Hector Gutierrez

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Geoffrey S. Berman
PERSONTova Noel
PERSON
George W. Bush
PERSON
United States
LOCATIONthe Southern District
LOCATIONMichael Thomas
PERSON
Audrey Strauss
PERSON
Richard M. Berman
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATIONChristenson
PERSON
Alberto Gonzales
PERSON
Human Rights Watch
ORGANIZATION
The Washington Post
ORGANIZATION
The New York Times
ORGANIZATIONMiguel Luna
PERSOND.C. Cir
ORGANIZATION