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4 United States v. Perez, 2004 U.S. Dist. LEXIS 7500 (D. Conn. June 16, 2006) 3 STATUTES 5 U.S.C. § 552 2, 10 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum,
dence 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 [hereinafter "Capone Decl."], at ¶¶ 24-25, 28). These sorts of records logically have no nexus with the prosecutions and therefore cann
4 United States v. Perez, 2004 U.S. Dist. LEXIS 7500 (D. Conn. June 16, 2006) 3 STATUTES 5 U.S.C. § 552 2, 10 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum,
dence 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 [hereinafter "Capone Decl."], at ¶¶ 24-25, 28). These sorts of records logically have no nexus with the prosecutions and therefore cann
A, 592 F.3d 60 (2d Cir. 2009) 6 Wood v. F.B.I., 432 F.3d 78 (2d Cir. 2005) 6 STATUTES 5 U.S.C. § 552 passim OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 16 Ali Watkins, Danielle Ivory & Christina Goldbaum
to commit sex trafficking, in violation of 18 U.S.C. § 371, and one count of sex trafficking, in violation of 18 U.S.C. § 1591. (See Declaration of Russell Capone, ECF No. 22 [hereinafter "Capone Decl."], at ¶ 4.) On July 6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated
A, 592 F.3d 60 (2d Cir. 2009) 6 Wood v. F.B.I., 432 F.3d 78 (2d Cir. 2005) 6 STATUTES 5 U.S.C. § 552 passim OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 16 Ali Watkins, Danielle Ivory & Christina Goldbaum
to commit sex trafficking, in violation of 18 U.S.C. § 371, and one count of sex trafficking, in violation of 18 U.S.C. § 1591. (See Declaration of Russell Capone, ECF No. 22 [hereinafter "Capone Decl."], at ¶ 4.) On July 6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated
Entities connected to both Michael Gold and Russell Capone

Jeffrey Epstein
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Geoffrey S. Berman
PERSONNicholas Tartaglione
PERSON
Andrew Cuomo
PERSOND.C. Cir
ORGANIZATION
Alberto Gonzales
PERSON
Human Rights Watch
ORGANIZATIONRadcliffe
PERSONSuicide
PERSONJustice Nat'l Inst
ORGANIZATIONNational Study of Jail
ORGANIZATIONDep't of
ORGANIZATIONDavid E. McCraw
PERSON
The Washington Post
ORGANIZATION
George W. Bush
PERSONChristina Goldbaum
PERSONSpecial Housing Unit
ORGANIZATION
Julie K. Brown
PERSON