EFTA00031025Set 8
2019-11-1955p11,904w
Plaintiff,
No. 20-CV-833(PAE)
v.
FEDERAL BUREAU OF PRISONS,
Defendant.
DECLARATION OF RUSSELL CAPONE
I, Russell Capone, hereby declare as follows:
1. I am Counsel to the Acting ... best of my knowledge and belief.
Executed this 5 day of August 2020.
Russell Capone
Counsel to the Acting United States Attorney
United States Attorney's Office for the
Southern
https://www.justice.gov/epstein/files/DataSet%208/EFTA00031025.pdf
EFTA00075382Set 9
2019-11-1955p11,931w
Plaintiff,
No. 20-CV-833(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 ... best of my knowledge and belief.
Executed this 5 day of August 2020.
Russell Capone
Counsel to the Acting United States Attorney
United States Attorney's Office for the
Southern
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075382.pdf
EFTA00015438Set 8
2019-11-1955p11,904w
Plaintiff,
No. 20-CV-833(PAE)
v.
FEDERAL BUREAU OF PRISONS,
Defendant.
DECLARATION OF RUSSELL CAPONE
I, Russell Capone, hereby declare as follows:
1. I am Counsel to the Acting ... best of my knowledge and belief.
Executed this 5 day of August 2020.
Russell Capone
Counsel to the Acting United States Attorney
United States Attorney's Office for the
Southern
https://www.justice.gov/epstein/files/DataSet%208/EFTA00015438.pdf
EFTA00015517Set 8
2020-08-057p2,118w
FEDERAL BUREAU OF PRISONS,
Defendant.
SUPPLEMENTAL DECLARATION OF RUSSELL CAPONE
I, Russell Capone, hereby declare as follows:
I. I am Counsel to the Acting United States Attorney for the Southern ... knowledge and belief.
Executed this p2- day of January 2021.
4,44.2-2 {
Russell Capone
Counsel to the Acting United States Attorney
United States Attorney's Office for the
Southern
https://www.justice.gov/epstein/files/DataSet%208/EFTA00015517.pdf
EFTA00031018Set 8
2020-08-057p2,118w
FEDERAL BUREAU OF PRISONS,
Defendant.
SUPPLEMENTAL DECLARATION OF RUSSELL CAPONE
I, Russell Capone, hereby declare as follows:
I. I am Counsel to the Acting United States Attorney for the Southern ... knowledge and belief.
Executed this p2- day of January 2021.
4,44.2-2 {
Russell Capone
Counsel to the Acting United States Attorney
United States Attorney's Office for the
Southern
https://www.justice.gov/epstein/files/DataSet%208/EFTA00031018.pdf
EFTA00105599Set 9
2021-02-1015p4,181w
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 ... those concerns. (See Capone Decl.
18-22, 24-25; Supplemental Decl. of Russell Capone, ECF No. 40 [hereinafter "Capone Supp.
Decl."], at ¶¶ 6-7, 10-13). Generic concerns that some
https://www.justice.gov/epstein/files/DataSet%209/EFTA00105599.pdf
EFTA00071609Set 9
2021-02-1015p4,167w
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 ... those concerns. (See Capone Decl.
18-22, 24-25; Supplemental Decl. of Russell Capone, ECF No. 40 [hereinafter "Capone Supp.
Decl."], at ¶¶ 6-7, 10-13). Generic concerns that some
https://www.justice.gov/epstein/files/DataSet%209/EFTA00071609.pdf
EFTA00071584Set 9
2020-08-0525p7,810w
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 ... testify, and
information and documents prepared by potential trial witnesses. See Supplemental Declaration
of Russell Capone ("Supp. Capone Decl.") ¶¶ 6-14. In addition, information contained in two of
the withheld ... Government has gone well beyond this requirement here by
submitting two declarations of Russell Capone, a supervising prosecutor and Counsel to the
Acting United States Attorney, that logically and plausibly
https://www.justice.gov/epstein/files/DataSet%209/EFTA00071584.pdf
EFTA00088605Set 9
2020-08-0525p7,830w
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 ... testify, and
information and documents prepared by potential trial witnesses. See Supplemental Declaration
of Russell Capone ("Supp. Capone Decl.") ¶¶ 6-14. In addition, information contained in two of
the withheld ... Government has gone well beyond this requirement here by
submitting two declarations of Russell Capone, a supervising prosecutor and Counsel to the
Acting United States Attorney, that logically and plausibly
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088605.pdf
EFTA00088671Set 9
2020-08-0530p8,403w
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 ... against Noel, Thomas, and Tartaglione, as logically and plausibly
explained in the declaration of Russell Capone, who serves as Counsel to the Acting United
States Attorney for the Southern District
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088671.pdf
EFTA00075437Set 9
2020-08-0530p8,449w
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 ... against Noel, Thomas, and Tartaglione, as logically and plausibly
explained in the declaration of Russell Capone, who serves as Counsel to the Acting United
States Attorney for the Southern District
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075437.pdf
EFTA00071554Set 9
2020-08-0530p8,407w
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 ... against Noel, Thomas, and Tartaglione, as logically and plausibly
explained in the declaration of Russell Capone, who serves as Counsel to the Acting United
States Attorney for the Southern District
https://www.justice.gov/epstein/files/DataSet%209/EFTA00071554.pdf
EFTA00071624Set 9
2020-09-1029p9,138w
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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00071624.pdf
EFTA00088701Set 9
2020-09-1029p9,170w
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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088701.pdf