Epstein Secrets

, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or.

ecifically, the events of the night of Epstein's apparent suicide attempt, at issue in Tartaglione. See Letter dated January 13, 2020, Dkt. No. 186, United States v. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January 21, 2020, Dkt. No. 193, 8 EFTA00071595 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/

d Records The bases for BOP's withholdings in full or in part of certain Returned Records are set out in the Supplemental Declaration of Counsel to the Acting United States Attorney Russell Capone and the Supplemental Declaration of Kara Christenson. The bases for these withholdings are substantially the same as the ba

p. 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, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

61 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

uly 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, United States v. Epstein, No. 19-cr

p. 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, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

44 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

uly 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, United States v. Epstein, No. 19-cr

, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or.

ecifically, the events of the night of Epstein's apparent suicide attempt, at issue in Tartaglione. See Letter dated January 13, 2020, Dkt. No. 186, United States v. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January 21, 2020, Dkt. No. 193, 8 EFTA00088616 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/

d Records The bases for BOP's withholdings in full or in part of certain Returned Records are set out in the Supplemental Declaration of Counsel to the Acting United States Attorney Russell Capone and the Supplemental Declaration of Kara Christenson. The bases for these withholdings are substantially the same as the ba

p. 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, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

78 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

uly 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, United States v. Epstein, No. 19-cr

, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or.

ecifically, the events of the night of Epstein's apparent suicide attempt, at issue in Tartaglione. See Letter dated January 13, 2020, Dkt. No. 186, United States v. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January 21, 2020, Dkt. No. 193, 8 EFTA00099609 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/

d Records The bases for BOP's withholdings in full or in part of certain Returned Records are set out in the Supplemental Declaration of Counsel to the Acting United States Attorney' and the Supplemental Declaration o . The bases for these withholdings are substantially the same as the bases for BOP's prior withholdin

rauss, by Assistant United States Attorney Alex Rossmiller; It is found that the Indictment in the above-captioned case is currently sealed and the United States Attorney's Office has applied to have that Indictment unsealed, and it is therefore: ORDERED that the Indictment in the above-captioned action be un

ICT OF NEW YORK UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. Unsealing Order 20 Cr. 330 Upon the application of the United States, by the Acting United States Attorney for the Southern District of New York, Audrey Strauss, by Assistant United States Attorney Alex Rossmiller; It is found that the Indictme

ted such counts. See id. II 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun

3(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. DECLARATION OF RUSSELL CAPONE I, Russell Capone, hereby declare as follows: I. I am Counsel to the Acting United States Attorney in the United States Attorney's Office for the Southern District of New York ("USAO-SDNY"). I have served in this capacity since June 2020

rauss, by Assistant United States Attorney Alex Rossmiller; It is found that the Indictment in the above-captioned case is currently sealed and the United States Attorney's Office has applied to have that Indictment unsealed, and it is therefore: ORDERED that the Indictment in the above-captioned action be un

ICT OF NEW YORK UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. Unsealing Order 20 Cr. 330 Upon the application of the United States, by the Acting United States Attorney for the Southern District of New York, Audrey Strauss, by Assistant United States Attorney Alex Rossmiller; It is found that the Indictme

ane Doe in Jane Doe v. Indyke et aL, No. 20-cv-484 (S.D.N.Y.). Your request is governed by federal regulations, referred to as "Touhy regulations." See United States a reL Touhy v. Ragen, 340 U.S. 462 (1951). Pursuant to these regulations, the Acting United States Attorney has authorized DOJ to provide certain d

ederal regulations, referred to as "Touhy regulations." See United States a reL Touhy v. Ragen, 340 U.S. 462 (1951). Pursuant to these regulations, the Acting United States Attorney has authorized DOJ to provide certain documents responsive to your request. Please find electronic versions of these documents enclosed. T