Epstein Secrets

2020) 9 Neb. Press Ass 'n v. Stuart, 427 U.S. 539 (1976) 4, 5 ii EFTA00105601 Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 4 of 15 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 2 Schiller v. City of New York, 2007 U.S. Dist. LEXIS 4285 (S.D.N.Y. Jan. 19, 2007) 8 Seife v. Dep'

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

2020) 9 Neb. Press Ass 'n v. Stuart, 427 U.S. 539 (1976) 4, 5 ii EFTA00071611 Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 4 of 15 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 2 Schiller v. City of New York, 2007 U.S. Dist. LEXIS 4285 (S.D.N.Y. Jan. 19, 2007) 8 Seife v. Dep'

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

.2d 1088 (D.C. Cir. 1989) 8 Oglesby v. U.S. Army, 920 F.2d 57 (D.C. Cir. 1990) 5 Pinson v. Dept of .htstice, 236 F. Supp. 3d (D.D.C. 2017) 22 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Ru

. 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,

214, 227 (1978) 9, 10 NRDC v. EPA, 2019 U.S. Dist. LEXIS 124353 (S.D.N.Y. July 25, 2019) 20 Pratt v. Webster, 673 F.2d 408 (D.C. Cir. 1982) 9 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 10 United States v. Noel, No. 19-CR-00830-AT (S.D.N.Y. June 9, 2020) 13 U.S. Dep't of Justice v. Ta

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

.2d 1088 (D.C. Cir. 1989) 8 Oglesby v. U.S. Army, 920 F.2d 57 (D.C. Cir. 1990) 5 Pinson v. Dept of .htstice, 236 F. Supp. 3d (D.D.C. 2017) 22 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Ru

. 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,

214, 227 (1978) 9, 10 NRDC v. EPA, 2019 U.S. Dist. LEXIS 124353 (S.D.N.Y. July 25, 2019) 20 Pratt v. Webster, 673 F.2d 408 (D.C. Cir. 1982) 9 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 10 United States v. Noel, No. 19-CR-00830-AT (S.D.N.Y. June 9, 2020) 13 U.S. Dep't of Justice v. Ta

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

.2d 1088 (D.C. Cir. 1989) 8 Oglesby v. U.S. Army, 920 F.2d 57 (D.C. Cir. 1990) 5 Pinson v. Dept of .htstice, 236 F. Supp. 3d (D.D.C. 2017) 22 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Ru

. 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,