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vely "Radar Online") seeks records at the core of the criminal prosecution of Jeffrey Epstein, prior to his passing, and the current prosecution of Ghisaille Maxwell. Congress did not intend the Freedom of Information Act, 5 U.S.C. § 552 et seq., to interfere with pending criminal prosecutions. To make sure this
District of New York and one of the lead prosecutors in this matter. )ecl. ¶¶ 1, 9-10, 13-32. The withheld records include possible exhibits at the Maxwell trial, information about which numerous witnesses are expected to testify, and information and documents authored by potential trial witnesses. See
d interfere with the pending prosecution against Ghislaine Maxwell, as logically and plausibly explained in
The withheld records include possible exhibits at the Maxwell trial, information about which numerous witnesse
cier Jeffrey Epstein, who plead guilty to one count of felony solicitation of prostitution in August 2006. Dkt. No. 12-2, Ex. B; see Declaration of Michael G. Seidel, dated June 2021 ("Seidel Decl.") 1 6, Ex. A. By letter dated April 28, 2017, the FBI acknowledged receipt of Plaintiff's FOIA request, and that b
istrict of New York since 1 EFTA00098826 November 2015. Currently, I am one of the Assistant United States Attorneys handling the prosecution of Ghislaine Maxwell, an individual who associated with Jeffrey Epstein. Prior to his death, I was also one of the Assistant United States Attorneys in charge of the pr
emptions 3, 5, 6, 7(A), 7(C), 7(D), and 7(E) of FOIA, 5 U.S.C. § 552(b)(5)-(7). In addition, I am familiar with the proceedings in United States v. Maxwell, 20-cr-330 (AJN) (S.D.N.Y.), and United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). The statements contained in this declaration are based on
ted States Attorneys handling the prosecution of Ghislaine Maxwell, an individual who associated with Jeffre
ation 18 U.S.C. 1623. See id., Dkt. No. 187. 8. The Maxwell case is pending before the Honorable Alison J. Na
e FOIA requests withheld in full or in part under Exemption 7(A), including those reflected on the index prepared by the FBI and the declaration of Michael G. Seidel (the "FBI index"). All of these records fall within the scope of Exemption 7(A). 11. Public disclosure of the records withheld in full or in part
in the United States Attorney's Office for the Southern District of New York. (Third Comey Decl. (Dkt. No. 59)1 1), and a revised declaration from Michael G. Seidel, the Section Chief of the Record/Information Dissemination Section ("RIDS") of the FBI's Information Management Division ("IMD"). (Second Seidel De
Page: EFTA00038653 →e the charges against him were pending. OA (citing United States v. Epstein 19 Cr. 490 (RMB), Nolle Prosequi (Dkt. No. 52))) B. The Prosecution of Ghislaine Maxwell On June 29, 2020, Ghislaine Maxwell was indicted by a grand jury in this District on "one count of conspiracy to entice minors to travel to engage
Page: EFTA00038654 →Prosequi (Dkt. No. 52))) B. The Prosecution of Ghislaine Maxwell On June 29, 2020, Ghislaine Maxwell was
Page: EFTA00038654 →ntent to engage in criminal sexual activity"; "and two counts of perjury." (Third Comey Decl. (Dkt. No. 59) 1 6) On December 29, 2021, a jury found Maxwell guilty of enticing a minor to travel to engage in illegal sex acts, transporting minors with the intent to engage in criminal sexual activity, and
Page: EFTA00038655 →Entities connected to both Ghislaine Maxwell and Michael G. Seidel

Jeffrey Epstein
PERSON
United States
LOCATION
Julie K. Brown
PERSONFBI
ORGANIZATIONDistrict Court for the Southern District of New York
ORGANIZATION
Sarah Ferguson
PERSON
James Comey
PERSON
Andrew Cuomo
PERSONGarcia
PERSON
The New York Times
ORGANIZATIONCarney
PERSON
Robertson
PERSONSeidel
PERSONFBI Headquarters
ORGANIZATIONRobbins Tire & Rubber Co.
ORGANIZATIONTimothy Dalton Vaughn
PERSONRADAR ONLINE LLC
ORGANIZATIONAmnesty Int'l USA
ORGANIZATION