r penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. Executed this 5 day of August 2020. Counsel to the Acting United States Attorney United States Attorney's Office for the Southern District of New York 1 EFTA00017794

nalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. Executed this 5 day of August 2020. Counsel to to the Acting United States Attorney United States Attorney's Office for the Southern District of New York 13 EFTA00022616

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

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

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

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

intiff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. SUPPLEMENTAL DECLARATION OF hereby declare as follows: I. I am Counsel to the Acting United States Attorney for the Southern District of New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details my service in this

of Epstein's medical records, but withheld in full 12 pages for reasons explained at Paragraph 20 of the August 5, 2020, declaration of Counsel to the Acting United States Attorney Russell Capone. 14. The Updated Index corrects an inadvertent error that resulted in double counting of seventeen pages of emails listed

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

HE NEW YORK TIMES COMPANY. Plaintiff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. reby declare as follows: I. I am Counsel to the Acting United States Attorney for the Southern District of New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details my service in this

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

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

of Epstein's medical records, but withheld in full 12 pages for reasons explained at Paragraph 20 of the August 5, 2020, declaration of Counsel to the Acting United States Attorney Russell Capone. 14. The Updated Index corrects an inadvertent error that resulted in double counting of seventeen pages of emails listed

ff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. SUPPLEMENTAL DECLARATION OF I, hereby declare as follows: I. I am Counsel to the Acting United States Attorney for the Southern District of New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details my service in this

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

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

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