📧 Communication

This document is a supplemental declaration by Russell Capone, Counsel to the Acting US Attorney, filed in response to a FOIA lawsuit by The New York Times. Capone argues that specific BOP records, including staffing rosters, psychology notes, and SHU logs from July and August 2019, must be withheld under Exemption 7(A) to prevent interference with the pending criminal trials of 'Noel' (prison guards) and 'Tartaglione' (Epstein's former cellmate). The declaration emphasizes that premature release of these documents could influence witness testimony and prejudice jury selection, particularly given the 'unfounded' media theories surrounding Epstein's death.