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ure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government has clearly explained how SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EF
e the government has put Tartaglione front and center here, I'm entitled to probe. Let me try this: Has a single document here been withheld under Tartaglione that relates to the events of August 10th? MR. KOCHEVAR: So, in some sense, yes, in that I believe -- and I want to be careful here because I don
ething that would reflect essentially which entries, and within the entries which documents, are being withheld, at least in part, on the basis of Tartaglione? MR. KOCHEVAR: No, other than -- well, other than the descriptions of the documents given in the declarations supporting the withholding, no, we
d from a false reports case. I think, second, documents that appear to be assignment rosters and so forth, which you see on the first page of the Vaughn Index, again, it's not clear how those connect. Maybe they can — I think we've heard a couple of theories of possibly getting there — but we'd like
ure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government has clearly explained how SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EF
e the government has put Tartaglione front and center here, I'm entitled to probe. Let me try this: Has a single document here been withheld under Tartaglione that relates to the events of August 10th? MR. : So, in some sense, yes, in that I believe -- and I want to be careful here because I don't have
ething that would reflect essentially which entries, and within the entries which documents, are being withheld, at least in part, on the basis of Tartaglione? MR. : No, other than -- well, other than the descriptions of the documents given in the declarations supporting the withholding, no, we don't h
d from a false reports case. I think, second, documents that appear to be assignment rosters and so forth, which you see on the first page of the Vaughn Index, again, it's not clear how those connect. Maybe they can — I think we've heard a couple of theories of possibly getting there — but we'd like
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
eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re
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
eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re
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
eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re
Entities connected to both Nicholas Tartaglione and Timothy Dalton Vaughn

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSONLeon Black
PERSON
Geoffrey S. Berman
PERSON
Julie K. Brown
PERSON
Ghislaine Maxwell
PERSONTova Noel
PERSON
United States
LOCATION
George W. Bush
PERSON
Donald Trump
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
William Barr
PERSON
Audrey Strauss
PERSONMichael Thomas
PERSON
Harry Reid
PERSON
Alfredo Rodriguez
PERSON