📧 Communication

This document is a legal declaration by Russell Capone filed in the SDNY regarding a FOIA lawsuit by the New York Times against the Bureau of Prisons. It argues for withholding records related to Jeffrey Epstein's detention and death to avoid interfering with the pending criminal prosecutions of correctional officers Tova Noel and Michael Thomas (for falsifying records) and inmate Nicholas Tartaglione (for multiple murders). Attached as exhibits are the indictments for Noel/Thomas, detailing the night of Epstein's death, and Tartaglione, detailing the 'Likquid Lounge' quadruple homicide.