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visitor, that would only heighten that individual's privacy interest in avoiding public disclosure of his or her name and contact information. See Halpern v. F.B.I., 181 F.3d 279, 297 (2d Cir. 1999) (describing privacy interests of third parties "insofar as the material in question demonstrates or sug
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
visitor, that would only heighten that individual's privacy interest in avoiding public disclosure of his or her name and contact information. See Halpern v. F.B.I., 181 F.3d 279, 297 (2d Cir. 1999) (describing privacy interests of third parties "insofar as the material in question demonstrates or sug
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
visitor, that would only heighten that individual's privacy interest in avoiding public disclosure of his or her name and contact information. See Halpern v. F.B.I., 181 F.3d 279, 297 (2d Cir. 1999) (describing privacy interests of third parties "insofar as the material in question demonstrates or sug
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
Entities connected to both Halpern and THE NEW YORK TIMES COMPANY

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATIONNicholas Tartaglione
PERSONthe Southern District
LOCATIONRadcliffe
PERSON
Human Rights Watch
ORGANIZATIONthe Acting United States
ORGANIZATION
United States
LOCATIOND.C. Cir
ORGANIZATIONTova Noel
PERSON
The New York Times
ORGANIZATIONHomeland Sec
ORGANIZATION
Audrey Strauss
PERSON
Doherty
PERSONChristenson
PERSON
Hopkins
ORGANIZATIONJudicial Watch, Inc.
ORGANIZATIONRobbins Tire & Rubber Co.
ORGANIZATIONthe Tenth Circuit's
ORGANIZATIONGarcia
PERSON