Epstein Secrets

RELIMINARY STATEMENT Financier Jeffrey Epstein's suicide in August 2019, and subsequent revelations about what Attorney General William Barr called the Metropolitan Correctional Center's (MCC) "failure to adequately secure this prisoner," led to widespread calls for accountability and reform. Ali Watkins, Katie Benner & Danielle Ivo

ORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Perloff-Giles The New York Times Company Legal Department Counsel for Plaintiff EFTA00071624 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 2 of 29

uests properly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the pub

uch other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00074145 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New York Times Company 620 8th Avenue New Yo

RELIMINARY STATEMENT Financier Jeffrey Epstein's suicide in August 2019, and subsequent revelations about what Attorney General William Barr called the Metropolitan Correctional Center's (MCC) "failure to adequately secure this prisoner," led to widespread calls for accountability and reform. Ali Watkins, Katie Benner & Danielle Ivo

ORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Perloff-Giles The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Phone: 212-556-4031 Facsimile: (212) 556-4634 Email: mccraw@n

uests properly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the pub

uch other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00091291 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New York Times Company 620 8th Avenue New Yo

uests properly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the pub

uch other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00094146 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New York Times Company 620 8th Avenue New Yo

uests properly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the pub

uch other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00095065 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New York Times Company 620 8th Avenue New Yo

uests properly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the pub

uch other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00098064 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New York Times Company 620 8th Avenue New Yo

an email dated August 13, 2019, the BOP received a FOIA request from Plaintiff. The FOIA request sought documents "about Jeffrey Epstein who died at the Metropolitan Correctional Center (MCC) on Aug. 10, 2019." See Attachment 1, Plaintiff's FOIA request dated August 13, 2019. Specifically, Plaintiff sought the following records: (1

.S. Department of Justice Office of Information Policy Suite 11050 1425 New York Avenue, NW Washington, DC 20530.0001 Telephone: (202) 514-3642 Alexandra Perloff-Giles, Esq. The New York Times Company 620 8th Avenue Re: Appeal No. DOJ-AP-2020-000123 New York, NY 10018 Request No. 2019-05665 aperloffgiles@nyti