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Case 1:20-cv-00833-PAE Document 21 Filed 08/05/20 Page 1 of 13
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE NEW YORK TIMES COMPANY,
Plaintiff,
No. 20-CV-833(PAE)
v.
FEDERAL BUREAU OF PRISONS,
Defendant.
DECLARATION OF RUSSELL CAPONE
hereby declare as follows:
2.
I am familiar with the Freedom of Information Act requests filed by the New
York Times Company (the "FOIA Requests") that are the subject of this case, which seek
records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center
("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of
Prisons ("BOP") has withheld pursuant to exemptions 5, 6, 7(A), 7(C), 7(E), and 7(F) of FOIA, 5
U.S.C. § 552(b)(5)-(7). In addition, I am familiar with the proceedings in United States of
EFTA00039895