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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
Page: EFTA00015517 →SUPPLEMENTAL DECLARATION OF RUSSELL CAPONE I, Russell Capone, 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 capacity and prior service in the USAO-SDNY. As
Page: EFTA00015517 →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
Page: EFTA00015522 →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 →can't imagine how they can claim a complete investigation without speaking to the person who was in the cell in that first event." A spokesman for the Southern District of New York declined comment. Attorney General William Barr said "irregularities" have been uncovered at the nightmarish lockup. The jail staff on duty at the
Page: EFTA00009967 →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
Page: EFTA00031018 →SUPPLEMENTAL DECLARATION OF RUSSELL CAPONE I, Russell Capone, 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 capacity and prior service in the USAO-SDNY. As
Page: EFTA00031018 →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
Page: EFTA00031023 →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 →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
Page: EFTA00015448 →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 →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
Page: EFTA00031035 →inmates. Mr. Epstein's roommate until Tuesday was Nicholas Tartaglione, a retired police officer accused of killing four people, according to Mr. Tartaglione's lawyer, Bruce Barket. "It is dark and it's disgusting," Mr. Barket said of the jail cell Messrs. Epstein and Tartaglione shared. Mr. Epstein, 66
Page: EFTA00016125 →out mice and insect infestations, as well as standing water on the floor, according to lawyers of inmates. Mr. Epstein's roommate until Tuesday was Nicholas Tartaglione, a retired police officer accused of killing four people, according to Mr. Tartaglione's lawyer, Bruce Barket. "It is dark and it's disgusting," Mr
Page: EFTA00016125 →ied as sexual battery. EFTA00016128 --- PAGE BREAK --- Epstein, who registered as a sex offender after a 2008 case, is being held without bail in the Southern District of New York on charges of sex trafficking of minors and conspiracy involving dozens of underage girls from at least 2002 to 2005. Epstein has pleaded not guilt
Page: EFTA00016129 →erwork to sign to be released. lie knew he was awaiting sentencing, scheduled for Sept 20, but didn't speak up. Richard Donoghue, U.S. Attorney for the Eastern District of New York, stated in a letter obtained by Fox News on Thursday that Matthews — who previously served time for bank robbery — was released, despite being held
Page: EFTA00019402 →bad combination of laziness and cruelty and this is one of the results." He described conditions at MCC "border on inhumane," and said one day, when Tartaglione woke up, he discovered that while sleeping he'd rolled onto a rodent, smothering it. Separately, a representative from the American Federation of G
Page: EFTA00019403 →checked on for "several hours." Additionally, he didn't have a cellmate on the night of his death. A lawyer for one of Epstein's former cellmates, Nicholas Tartaglione, a former police officer in New York who was charged in 2016 with the deaths of four men stemming from an alleged cocaine conspiracy, told Fox News
Page: EFTA00019403 →surveillance in its possession for July 23, 2019 for the Special Housing Unit. The Government attaches hereto two public filings in United States v. Tartaglione, 16 Cr. 832 (KMK), which reference these issues. 06.20.2018 EFTA00018948 --- PAGE BREAK --- Page 2 Noel Requests No. 14-5, 17-23. These reques
Page: EFTA00018948 →on August 10, 2019. We are available at your convenience to discuss any further. Very truly yours, GEOFFREY S. BERMAN United States Attorney for the Southern District of New York By: /s/ Assistant United States Attorneys 06.20.2018 EFTA00018950
Page: EFTA00018950 →Entities connected to both Nicholas Tartaglione and District Court for the Southern District of New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Geoffrey S. Berman
PERSON
Audrey Strauss
PERSONSpecial Housing Unit
ORGANIZATION
United States
LOCATION
Marc Rich
PERSONU.S. Attorney's Office
ORGANIZATION
Donald Trump
PERSONFBI
ORGANIZATION
White Plains
LOCATION
Julie K. Brown
PERSONSecond Circuit
ORGANIZATION
Bill Clinton
PERSONTova Noel
PERSONLeon Black
PERSON