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protected from disclosure, this applies when "the manner and circumstances of the various techniques ... [are] not generally known to the public." Coleman v. FBI, 13 F. Supp. 2d 75, 83 (D.D.C. 1998); see also Shapiro v. Dep't of Justice, 249 F. Supp. 3d 502, 507 (D.D.C. 2017) ("Even though the identit
Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-
protected from disclosure, this applies when "the manner and circumstances of the various techniques ... [are] not generally known to the public." Coleman v. FBI, 13 F. Supp. 2d 75, 83 (D.D.C. 1998); see also Shapiro v. Dep't of Justice, 249 F. Supp. 3d 502, 507 (D.D.C. 2017) ("Even though the identit
Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-
protected from disclosure, this applies when "the manner and circumstances of the various techniques ... [are] not generally known to the public." Coleman v. FBI, 13 F. Supp. 2d 75, 83 (D.D.C. 1998); see also Shapiro v. Dep't of Justice, 249 F. Supp. 3d 502, 507 (D.D.C. 2017) ("Even though the identit
Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-
Entities connected to both Coleman and THE NEW YORK TIMES COMPANY

Julie K. Brown
PERSON
George W. Bush
PERSON
Jeffrey Epstein
PERSONSouthern District
LOCATION
Donald Trump
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
United States
LOCATION
Supreme Court
ORGANIZATION
Bloomberg L.P.
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONFBI
ORGANIZATION
William Barr
PERSON
Metropolitan Correctional Center
ORGANIZATION
Andrew Cuomo
PERSON
Homeland Security
ORGANIZATION
Alan Dershowitz
PERSONthe Southern District
LOCATION
Minnesota
LOCATION