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sive video footage was located. 24. SUICIDE ATTEMPT AND SUICIDE RECORDS — With respect to plaintiffs request for "[a]ll BOP documents pertaining to Jeffrey Epstein's suicide and first suicide attempt[,]" in addition to the searches by Central Office described in the Christenson Declaration, MCC staff located res
ed in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request, apart from records relating to Epstein that indicated which cell or part of the facility he was housed in. 10. CIM CLEARANCE SHEET/SEPARATEE DATA — With respect to Plaintiff's request fo
ntries (showing which cells he was housed in) for Jeffrey Epstein at MCC[,]" Central Office conducted a se
respect to Plaintiffs request for a "full log of Mr. Epstein's phone calls to and from the MCC[,]" Central Of
ents. In this capacity, I typically work with staff at BOP's Central Office. In this case, I communicated with BOP Government Information Specialist Kara Christenson regarding Plaintiff's FOIA requests. 3. I submit this declaration in support of the BOP's motion for summary judgment and to 1 EFTA00075372 Cas
sive video footage was located. 24. SUICIDE ATTEMPT AND SUICIDE RECORDS — With respect to plaintiffs request for "[a]ll BOP documents pertaining to Jeffrey Epstein's suicide and first suicide attempt[,]" in addition to the searches by Central Office described in the Christenson Declaration, MCC staff located res
ed in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request, apart from records relating to Epstein that indicated which cell or part of the facility he was housed in. 10. CIM CLEARANCE SHEET/SEPARATEE DATA — With respect to Plaintiff's request fo
ntries (showing which cells he was housed in) for Jeffrey Epstein at MCC[,]" Central Office conducted a se
respect to Plaintiffs request for a "full log of Mr. Epstein's phone calls to and from the MCC[,]" Central Of
ents. In this capacity, I typically work with staff at BOP's Central Office. In this case, I communicated with BOP Government Information Specialist Kara Christenson regarding Plaintiff's FOIA requests. 3. I submit this declaration in support of the BOP's motion for summary judgment and to 1 EFTA00088661 Cas
ow He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019) 5, 6 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2
ords could interfere with the law enforcement proceedings it cites—the prosecution of murder defendant Nicholas Tartaglione, who shared a cell with Epstein for a brief period of time, and the prosecution of the two correctional officers who failed to perform prisoner counts at the time of Epstein's suic
0 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in
nforcement purposes" because they were created "in the exercise of BOP's statutory authority to detain arrested individuals." (Supplemental Decl. of Kara Christenson, ECF No. 39 [hereinafter "Christenson Supp. Decl."], at ¶ 29.) But this sweeping application of Exemption 7(A) would effectively shield every BOP r
sts filed by the New York Times Company (the "FOIA Requests") that are the subject of this case, which seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP")
presented at trial. 8. The risks of interference with the Noel proceedings are heightened by the media coverage of speculation and theories about Epstein's death. Many publicly-discussed theories of Epstein's death are unfounded. Premature release of the withheld records, particularly if the records
ich seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center (
ed Records"), including those reflected as withheld in full at Entries 55- 57 and 60 on the updated index attached to the Supplemental Declaration of Kara Christenson (the "updated BOP index"). The 7(A) Returned Records fall into four categories: documents related to counts of inmates, staffing records, psycholog
ow He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019) 5, 6 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2
ords could interfere with the law enforcement proceedings it cites—the prosecution of murder defendant Nicholas Tartaglione, who shared a cell with Epstein for a brief period of time, and the prosecution of the two correctional officers who failed to perform prisoner counts at the time of Epstein's suic
0 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in
nforcement purposes" because they were created "in the exercise of BOP's statutory authority to detain arrested individuals." (Supplemental Decl. of Kara Christenson, ECF No. 39 [hereinafter "Christenson Supp. Decl."], at ¶ 29.) But this sweeping application of Exemption 7(A) would effectively shield every BOP r
sts filed by the New York Times Company (the "FOIA Requests") that are the subject of this case, which seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP")
presented at trial. 8. The risks of interference with the Noel proceedings are heightened by the media coverage of speculation and theories about Epstein's death. Many publicly-discussed theories of Epstein's death are unfounded. Premature release of the withheld records, particularly if the records
ich seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center (
ed Records"), including those reflected as withheld in full at Entries 55- 57 and 60 on the updated index attached to the Supplemental Declaration of Kara Christenson (the "updated BOP index"). The 7(A) Returned Records fall into four categories: documents related to counts of inmates, staffing records, psycholog
ow He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019) 5, 6 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2
ords could interfere with the law enforcement proceedings it cites—the prosecution of murder defendant Nicholas Tartaglione, who shared a cell with Epstein for a brief period of time, and the prosecution of the two correctional officers who failed to perform prisoner counts at the time of Epstein's suic
0 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in
nforcement purposes" because they were created "in the exercise of BOP's statutory authority to detain arrested individuals." (Supplemental Decl. of Kara Christenson, ECF No. 39 [hereinafter "Christenson Supp. Decl."], at ¶ 29.) But this sweeping application of Exemption 7(A) would effectively shield every BOP r
Entities connected to both Jeffrey Epstein and Kara Christenson

Julie K. Brown
PERSONthe Southern District
LOCATIONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Alberto Gonzales
PERSONNicholas Tartaglione
PERSON
Andrew Cuomo
PERSON
United States Department of Justice
ORGANIZATION
The New York Times
ORGANIZATIONPerez
PERSONColeman
PERSONSuicide
PERSONShapiro
PERSON
Schiller
PERSONthe Inspector General
ORGANIZATIONChristenson
PERSOND.C. Cir
ORGANIZATION
THE NEW YORK TIMES COMPANY
ORGANIZATION
Human Rights Watch
ORGANIZATION