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E Document 42 Filed 02/10/21 Page 7 of 15 attempt; (4) reports and evidence of Epstein's death on August 10, 2019; (5) email correspondence between Tartaglione's attorneys and legal counsel at the MCC; and (6) medical and psychological records of Epstein prepared by BOP. (Decl. of Russell Capone, ECF No. 22
to the defendants—they fall short of actually connecting these specific types of records to any of those concerns. (See Capone Decl. 18-22, 24-25; Supplemental Decl. of Russell Capone, ECF No. 40 [hereinafter "Capone Supp. Decl."], at ¶¶ 6-7, 10-13). Generic concerns that some administrative documents in some ca
E Document 42 Filed 02/10/21 Page 7 of 15 attempt; (4) reports and evidence of Epstein's death on August 10, 2019; (5) email correspondence between Tartaglione's attorneys and legal counsel at the MCC; and (6) medical and psychological records of Epstein prepared by BOP. (Decl. of Russell Capone, ECF No. 22
to the defendants—they fall short of actually connecting these specific types of records to any of those concerns. (See Capone Decl. 18-22, 24-25; Supplemental Decl. of Russell Capone, ECF No. 40 [hereinafter "Capone Supp. Decl."], at ¶¶ 6-7, 10-13). Generic concerns that some administrative documents in some ca
E Document 42 Filed 02/10/21 Page 7 of 15 attempt; (4) reports and evidence of Epstein's death on August 10, 2019; (5) email correspondence between Tartaglione's attorneys and legal counsel at the MCC; and (6) medical and psychological records of Epstein prepared by BOP. (Decl. oaa, ECF No. 22 [hereinafter
age to the defendants—they fall short of actually connecting these specific types of records to any of those concerns. (See Decl. ¶¶ 18-22, 24-25; Supplemental Decl. of Russell ECF No. 40 [hereinafter a Supp. Decl."], at ¶¶ 6-7, 10-13). Generic concerns that some administrative documents in some cases may int
Entities connected to both Nicholas Tartaglione and Supplemental Decl

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Julie K. Brown
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATION
Alberto Gonzales
PERSONSuicide
PERSON
Human Rights Watch
ORGANIZATION
The New York Times
ORGANIZATIOND.C. Cir
ORGANIZATIONRadcliffe
PERSON
Andrew Cuomo
PERSONHomeland Sec
ORGANIZATIONPerez
PERSONChristina Goldbaum
PERSONAl-Amyn Sumar
PERSONRussell Capone
PERSONAli Watkins
PERSONU.S. Dept of Commerce
ORGANIZATIONShapiro
PERSON