Epstein Secrets

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

(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

hibits A and B, respectively. The statements contained in 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

5447 --- PAGE BREAK --- Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 11 of 13 defendants') ability to seat a fair and impartial jury in Tartaglione, particularly for purposes of a potential penalty-phase hearing required by 18 U.S.C. § 3593, by influencing potential juror perceptions of any int

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

(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

hibits A and B, respectively. The statements contained in 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

1034 --- PAGE BREAK --- Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 11 of 13 defendants') ability to seat a fair and impartial jury in Tartaglione, particularly for purposes of a potential penalty-phase hearing required by 18 U.S.C. § 3593, by influencing potential juror perceptions of any int

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

ust 5, 2020, declaration. 2. The statements contained in 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 accordanc

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

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

ust 5, 2020, declaration. 2. The statements contained in 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 accordanc

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

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

individuals and detail their association with Epstein or their involvement or interest in Epstein's incarceration, death, or the response of BOP or the USAO-SDNY to Epstein's death. Release of this information - particularly in light of the intense media interest in and public speculation concerning Epstein's