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uly 6, 2019, and thereafter incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr
xpression for 13 EFTA00071572 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 20 of 30 which the protection is claimed." United States v. Schwinanzer, 892 F.2d 237, 243 (2d Cir. 1989). "[T]he traditional rationale for the [attorney-client] privilege applies with special force in the government co
uly 6, 2019, and thereafter incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr
xpression for 13 EFTA00075455 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 20 of 30 which the protection is claimed." United States v. Schwinanzer, 892 F.2d 237, 243 (2d Cir. 1989). "[T]he traditional rationale for the [attorney-client] privilege applies with special force in the government co
uly 6, 2019, and thereafter incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr
xpression for 13 EFTA00088689 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 20 of 30 which the protection is claimed." United States v. Schwinanzer, 892 F.2d 237, 243 (2d Cir. 1989). "[T]he traditional rationale for the [attorney-client] privilege applies with special force in the government co
Entities connected to both the Acting United States and Schwinanzer

Jeffrey Epstein
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATIONNicholas Tartaglione
PERSONthe Southern District
LOCATION
United States
LOCATIONSpecial Housing Unit
ORGANIZATION
Audrey Strauss
PERSONTova Noel
PERSON
Metropolitan Correctional Center
ORGANIZATION
Hopkins
ORGANIZATIONGarcia
PERSONRobbins Tire & Rubber Co.
ORGANIZATIONFavish
PERSON
Human Rights Watch
ORGANIZATIONHomeland Sec
ORGANIZATION
Doherty
PERSONJudicial Watch, Inc.
ORGANIZATIONRadcliffe
PERSONNat'l Aeronautics & Space Admin
ORGANIZATIONAllard K. Lowenstein
PERSON