Epstein Secrets

gically and plausibly explains the relationship between the documents and those pending criminal cases. Plaintiff also relies on a decision by Judge Torres in Noel, but this decision and subsequent proceedings in that case cut against plaintiff's position. The Government has already disclosed to the No

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF

ey had not done so. (The focus of those prosecutions is on the false certifications they are alleged to have signed.) A June 9, 2020 order by Judge Torres, denying Thomas's motion to compel "disclosure of `reports generated by 7 The Government's vague allegations of the impact of disclosure on juror te

Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 1 of 29 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 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR S

gically and plausibly explains the relationship between the documents and those pending criminal cases. Plaintiff also relies on a decision by Judge Torres in Noel, but this decision and subsequent proceedings in that case cut against plaintiff's position. The Government has already disclosed to the No

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF

ey had not done so. (The focus of those prosecutions is on the false certifications they are alleged to have signed.) A June 9, 2020 order by Judge Torres, denying Thomas's motion to compel "disclosure of `reports generated by 7 The Government's vague allegations of the impact of disclosure on juror te

Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 1 of 29 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 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR S

gically and plausibly explains the relationship between the documents and those pending criminal cases. Plaintiff also relies on a decision by Judge Torres in Noel, but this decision and subsequent proceedings in that case cut against plaintiff's position. The Government has already disclosed to the No

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF