Epstein Secrets

FTA00105600 Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 3 of 15 TABLE OF AUTHORITIES CASES Am. Immigration Lawyers Ass 'n v. Dep't of Homeland Sec., 852 F. Supp. 2d 66 (D.D.C. 2012) 10 Assoc. Press v. Dep't of Del, 554 F.3d 274 (2d Cir. 2009) 5, 9 Coleman v. FBI, 13 F. Supp. 2d 75 (D.D.C.

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

FTA00071610 Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 3 of 15 TABLE OF AUTHORITIES CASES Am. Immigration Lawyers Ass 'n v. Dep't of Homeland Sec., 852 F. Supp. 2d 66 (D.D.C. 2012) 10 Assoc. Press v. Dep't of Del, 554 F.3d 274 (2d Cir. 2009) 5, 9 Coleman v. FBI, 13 F. Supp. 2d 75 (D.D.C.

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

26 (2d Cir. 2016) 15, 16 Adamowitz v. I.R.S., 552 F. Supp. 2d 355 (S.D.N.Y. 2008) 5 Allard K. Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (2d Cir. 2010) 20 Am. Civil Liberties Union v. United States Dep't of, Del, 901 F.3d 125 (2d Cir. 2018) 5 Amnesty Intl USA v. CI

. Epstein was arrested on July 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,

26 (2d Cir. 2016) 15, 16 Adamowitz v. I.R.S., 552 F. Supp. 2d 355 (S.D.N.Y. 2008) 5 Allard K. Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (2d Cir. 2010) 20 Am. Civil Liberties Union v. United States Dep't of, Del, 901 F.3d 125 (2d Cir. 2018) 5 Amnesty Intl USA v. CI

. Epstein was arrested on July 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,

26 (2d Cir. 2016) 15, 16 Adamowitz v. I.R.S., 552 F. Supp. 2d 355 (S.D.N.Y. 2008) 5 Allard K. Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (2d Cir. 2010) 20 Am. Civil Liberties Union v. United States Dep't of, Del, 901 F.3d 125 (2d Cir. 2018) 5 Amnesty Intl USA v. CI

. Epstein was arrested on July 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,